InsightsMAS Circular on Observations and Supervisory Expectations for VCCs and VCC Managers and other updates
On 26 June 2025, the Monetary Authority of Singapore (“MAS”) issued a circular after conducting a thematic review of Variable Capital Companies (“VCCs”) and their managers (“VCC Managers”) in 2024 (“Circular”). The Circular highlights key observations from MAS’ review, sets out supervisory expectations and good practices that VCC Managers may consider adopting in relation to the governance and management of VCCs, and reiterates expectations in relation to anti-money laundering and countering the financing of terrorism (“AML/CFT”).
Relatedly, on 8 April 2025 MAS published the Consultation Paper on the Proposed Amendments to Anti-Money Laundering and Countering the Financing of Terrorism Notices for Financial Institutions and Variable Capital Companies (“Consultation Paper”) proposing changes to the AML/CFT Notices governing financial institutions (“FIs”) and VCCs. The response to feedback received on the Consultation Paper (“Response Consultation Paper”) was published on 8 May 2025. In furtherance of this, the MAS implemented changes to the AML/CFT Notices for FIs and VCCs on 30 June 2025, which take effect on 1 July 2025.
In this client update, Director Ian Phung and Associate Justin Hoo summarises the key takeaways from the recent updates.
If you have any questions, please feel free to reach out to our team.
