PTC Compliance in Singapore: 5 Trustee Terms Families Must Set
A Singapore private trust company is exempt from a MAS trust business licence, but it is not exempt from oversight. Three obligations carry the most weight: engaging a licensed trust company for AML/CFT checks under the Trust Companies (Exemption) Regulations, meeting IRAS CRS and FATCA duties, and keeping ACRA filings, including RORC, current. Missing any of them can be an offence.
TL;DR:
The licensed trustee must perform AML/CFT checks; define onboarding, screening, monitoring, evidence retention, escalation, audit access, and higher risk review frequency in a written engagement.
A Reporting SGFI must register by March 31 of the following year and file by May 31; confirm in writing whether its trustee reports.
From June 16, 2025, new PTCs must file Central RORC the same day; previously exempt entities have two business days, and penalties can reach $25,000.
A PTC must remain closed and family only; serving or soliciting public clients risks loss of exempt status, so check before taking outside work.
ACRA grants a paid extension of 60 days for annual returns, while controller details must match across ACRA and MAS records; assign one person to own filings.
Table of Contents
How do MAS and the Exemption Regulations apply to a private trust company?
A private trust company, or PTC, is defined under the Trust Companies (Exemption) Regulations, which also set the conditions for exemption. Check the Regulations to confirm whether your proposed activities meet those conditions.
The exemption removes the licensing requirement. It does not remove MAS supervision. The Regulations require a PTC to engage a licensed trust company to conduct the necessary AML/CFT checks.
MAS publishes a Compliance Toolkit that sets out the submissions you will encounter in practice:
Forms 5, 6, 7, 8, 9 and 10: notifications, approvals and reporting items lodged with MAS, each tied to a specific trigger or timing.
Other notifications and submissions: check the toolkit to confirm which apply to your entity and the relevant filing requirements.
Financial and statistical returns: required where the toolkit says they apply to your entity type.
Our guide to PTC directors and MAS notification forms walks through the appointment side in more detail.
What AML/CFT duties apply, and what must the licensed trustee do?
MAS’s AML/CFT notice for trust companies is the benchmark. It expects risk assessment, customer due diligence, enhanced measures for higher-risk relationships, screening including politically exposed persons, ongoing monitoring, recordkeeping, and an appointed AML/CFT compliance officer, backed by training and audit.
The PTC cannot do this alone. Regulation 4(2) of the Exemption Regulations requires you to engage a licensed trust company to carry out the checks needed to meet MAS’s AML/CFT directions. Treat the engagement letter as a compliance document, not a formality. Build it around these points:
Define exactly which AML tasks the trustee performs: onboarding checks, screening and monitoring.
Require the trustee to give you evidence of every check, and keep copies inside the PTC.
Agree reporting lines for suspicious activity and escalation.
Secure audit access to the trustee’s files on your relationships.
Set the refresh frequency for due diligence on higher-risk parties.
Pro Tip: Require a written annual AML attestation from the licensed trustee, and keep a joint register of higher-risk relationships that both sides review.
Duties around record retention are covered in our piece on the five-year record rule, and our article on trustee AML duties covers the gaps we see most often.
When do CRS, FATCA and Reporting SGFI rules reach your PTC?
A PTC or trust may be classed as a Reporting Singaporean Financial Institution. IRAS’s CRS compliance guidance/crs-compliance) says Reporting SGFIs must register, perform due diligence on financial accounts and file annual returns, or a nil return. An entity that becomes a Reporting SGFI registers by 31 March of the following year, and late registration can mean back-year returns. Returns are due by 31 May after the reporting year.
Where the trust is a Trustee-Documented Trust, a Reporting SGFI trustee can take on these obligations. If your PTC is not that reporting trustee, confirm in writing who files.
Watch for these recurring pitfalls:
Misclassifying entity accounts.
Missing required information in reports.
Failing to follow up on changes in circumstances.
Skipping a reconciliation of the filed data against your own records.
Failure to register or file can lead to penalties under Section 105M of the Income Tax Act, so treat the registration deadline as a hard deadline. Our note on trust taxation covers the wider IRAS picture.
What corporate filings does ACRA require?
Beyond trust rules, your PTC is a company. ACRA expects it to maintain a Register of Registrable Controllers and send annual verification notices to controllers. New PTCs often overlook these duties.
Central RORC filing: timelines differ by registration date. ACRA’s Central RORC guidance sets same-day filing for new registrations from 16 June 2025 and two business days for previously exempt entities.
Penalties: failing to send notices or update the Central RORC can bring fines up to $25,000.
Annual returns: ACRA’s annual return rules allow a 60-day extension for a fee, but late filing is penalized.
Ownership: name one person in the PTC to own corporate compliance.
Controllers and trustee roles must match across ACRA and MAS records. Inconsistencies create regulatory risk.
Which governance steps should owners complete first?
Work through these in order, and keep dated evidence of each:
Confirm the applicable management requirements, name an AML/CFT compliance officer, and document fit-and-proper checks.
Sign a scoped engagement letter with a licensed trust company covering AML/CFT, CRS support, record access, annual attestations and audit rights.
Build one filing calendar: MAS notifications, IRAS registration and the 31 May return, and ACRA RORC and annual return dates.
Set recordkeeping and training routines, then book an external compliance review.
Confirm professional indemnity insurance evidence where it applies.
Pro Tip: Put every deadline on one shared calendar owned by the board, with a named person and a backup for each filing.
Families preparing for succession should also read our overview of wealth transfer essentials.
Why does compliance protect family control?
Compliance is governance, not paperwork. A PTC that files on time, documents its checks and keeps controller records consistent gives regulators little reason to intervene, and keeps decisions about the trust assets with the family. Specialist advice matters most at setup and at each change of directors or controllers. We are glad to discuss your estate planning needs with you.
— Joseph
How do we support your PTC compliance?
We help families with trust consultations and PTC setup:
Trust consultations and PTC setup support
When you are ready, explore our services and enquire.
This article is general information, not a substitute for advice from a qualified lawyer. Consult a qualified legal professional about your own circumstances before acting on anything here.
FAQ
Does a private trust company need a MAS licence in Singapore?
No, a PTC that meets the conditions of the Exemption Regulations is exempt from holding a trust business licence. It must still engage a licensed trust company for trust administration services, and it stays under MAS supervision.
Who files CRS returns for a trust with a PTC?
It depends on classification. If the trust is a Reporting SGFI, it registers with IRAS and files annually. If it is a Trustee-Documented Trust, the Reporting SGFI trustee can file on its behalf, so confirm this in writing.
What happens if a PTC misses ACRA RORC filings?
Failing to send verification notices or update the Central RORC can attract fines of up to $25,000 under ACRA’s guidance. Assign one owner and calendar every date.
Can a PTC serve clients outside the family?
Not safely. A PTC must keep its closed, family-only structure, and soliciting the public risks losing exempt status.
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