PTC Requirements in Singapore: What MAS Expects
A private trust company (PTC) in Singapore is a company that acts as trustee for one family’s trusts, and only that family’s. To use it without a trust business licence, you must meet three tests. The trusts it serves must be specific, connected-party trusts. It must do no trust business with the public. It must also engage a licensed trust company to carry out the administration checks that the Monetary Authority of Singapore (MAS) requires for anti-money laundering. Since 1 July 2025, it must also follow MAS’s AML/CFT notice for exempt PTCs.
This guide goes through each requirement in order, then covers the practical questions families ask before they commit: who sits on the board, what ongoing duties apply, and when a PTC is the wrong tool.
TL;DR
A PTC is exempt from the trust business licence only if it serves specific trusts with connected settlors and beneficiaries, and takes no business from the public.
It must appoint a licensed trust company (LTC) to do the administration checks needed for MAS’s AML/CFT directions.
MAS Notice TCA-N03 applies to exempt PTCs from 1 July 2025: risk assessments, customer due diligence, documentation and senior-management sign-off.
A PTC is a live company with directors and duties. It suits families with real complexity, not a simple estate.
Take legal advice before setting one up, and choose who sits as trustee with care.
Table of Contents
What a private trust company is, and how it differs from a licensed one
A licensed trust company is a business that offers trustee services to the public and holds a MAS licence to do so. A PTC is the opposite in purpose. It is set up to serve a defined group of related people, so it is not licensed. Under the MAS FAQs on the Trust Companies Act, a PTC solely provides trust services for specific trusts whose settlors are connected and whose beneficiaries are connected to the settlor or are charities, and it cannot serve the public.
That last limit explains most of the rest. Because a PTC does not take outside clients, Singapore treats it as a family vehicle. The licence regime is built for firms that handle other people’s money as a business.
In practice, a family sets up a company whose only job is to be trustee of the family trust. The family, or advisers they pick, sit on its board. Instead of handing the trust assets to an outside trustee, they keep decisions closer to home. We cover the pros and cons in our piece on PTC benefits for HNW families.
The core requirements for the licensing exemption
The exemption comes from section 15 of the Trust Companies Act (TCA). The MAS FAQs state that a PTC is exempt from the requirement to hold a trust business licence under section 15, provided it adheres to strict limits on the trusts and beneficiaries it serves. Think of the requirements as four checks.
Requirement | What it means for your family |
Specific trusts only | The PTC acts as trustee only for trusts that fit the connected-party tests |
Connected settlors | Where there are several settlors, they must be connected to one another |
Connected beneficiaries | Beneficiaries must be connected to their settlor, or be charities |
No public business | The PTC cannot offer trustee services to outsiders |
Licensed trust company engaged | An LTC carries out administration checks for AML/CFT |
Who counts as a connected person
The phrase “connected person” is not left to interpretation. It is defined in regulation 2 and the Schedule to the Trust Companies (Exemption) Regulations. Before you design the structure, check every named settlor and beneficiary against that schedule. A cousin, a business partner or a friend’s child may not qualify, and one non-qualifying beneficiary can put the exemption at risk.
This matters most in blended families, in multi-branch family businesses and where a trust is meant to benefit a wider circle. Map the people first, then pick the structure.
No trust business with the public
A PTC cannot take on a second family as a client, even as a favor. If two unrelated families want shared trustee arrangements, a PTC is not the vehicle. A licensed trustee is.
You must appoint a licensed trust company
This is the requirement that surprises families most. A PTC is exempt from licensing, yet it is not free of oversight. The MAS FAQs say a PTC must engage an LTC to carry out trust administration services for the checks needed to comply with MAS written directions on AML/CFT.
So the family keeps decision-making. A regulated firm handles the screening and compliance checks. Two things follow:
Budget for it. The LTC is an ongoing service provider, not a one-time formality. We do not publish a PTC fee, and quotes depend on the structure, so ask each LTC for a written scope and fee.
Agree the boundary early. Decide in writing what the LTC does (checks, records, reporting support) and what the board decides (investments, distributions, family matters).
Our PTC compliance guide sets out five trustee terms that families should settle before the structure goes live.
AML/CFT duties from 1 July 2025
The most recent change for PTCs is in anti-money laundering. MAS Notice TCA-N03 explicitly applies to all PTCs exempted under section 15 of the TCA as of 1 July 2025. It requires them to put robust AML/CFT policies, procedures and controls in place.
The notice asks a PTC to:
apply AML/CFT controls across its activity;
carry out risk assessments and customer due diligence (CDD);
document its risk assessments and its findings on transactions;
obtain senior-management approval for its policies.
For a family company, senior management means the board. Directors cannot treat the notice as the LTC’s problem. They sign off the policies, so they need to read them. If you set up a PTC before this date, review whether your documents and board minutes now reflect the notice. Read the full text on the MAS site, because a short summary like this one will miss detail.
On investing, trustees also owe duties when they place money. We explain the overlap in trustee investment powers and AML duties.
Confidentiality and record-keeping
Families often choose a PTC for privacy. The law supports privacy, but within limits. Under section 49 of the TCA, information about a protected party must be kept confidential by trust companies, with limited exceptions and heavy penalties for unauthorized disclosure.
Privacy does not mean there are no records. Trustees must keep them, and regulators and other authorities can ask for them in the right circumstances. Our article on the 5 year record rule and trust confidentiality explains what to keep and for how long.
Governance: directors, residency and the trust deed
A PTC is a company, so it needs people to run it. Choosing them is the most practical decision in the whole project. Think about:
Continuity. If the founder dies or loses capacity, who is on the board next? Write succession for directors into the constitution.
Independence. A board made entirely of family members can struggle when siblings disagree. Many families add a professional director.
Willingness. Directors take on real duties. The Ministry of Law’s guidance says families should choose a trustee carefully, make sure they are willing to take on trustee duties, and seek legal advice when setting up a trust.
Residency. Singapore residency questions affect both the company and the trust. See trustee residency in Singapore and our PTC directors checklist.
The law that governs the trust itself is separate. The TCA regulates companies that provide trust services, while the Trustees Act provides the basic legislative framework for trustees of trusts under Singapore law. A PTC therefore sits under both.
Tax and control traps to check before you commit
Two issues catch families who focus only on the PTC.
Tax. Trust income can be taxed in the trustee’s hands in some situations, and the surprise is usually bigger than expected. Read our summary of trust taxation rules for Singapore trustees before you finalize the structure, and confirm your position with a tax adviser.
Settlor control. If the settlor keeps too much power, the trust can look like a shell around the settlor’s own estate. The risk is described in our piece on settlor interested trusts and Section 31 deeming. A PTC makes it easy to put control back in the founder’s hands, so draft the deed with that in mind.
Is a PTC the right choice?
A PTC adds a company, a board, an LTC contract, compliance work and annual upkeep. That is worth it when the family has:
an operating business or concentrated holdings that need hands-on, informed trustee decisions;
several generations or branches who want a voice in how the trust is run;
assets such as private companies, property or art that a standard trustee may handle reluctantly;
a strong wish to keep decisions inside the family.
It is probably too much when the estate is mainly listed investments, insurance and CPF-linked assets, and a straightforward will or a professional trustee will do the job. Compare the options in how to choose the right trustee, and see whether a family constitution or a trust answers your real need.
A practical sequence for setting one up
The steps below are the order we recommend. Costs vary with the structure and are agreed in writing with each provider, so we give no figures here.
Map the family and assets. List settlors, beneficiaries and what each trust will hold.
Test every person against the connected-person definition. Fix any gaps before drafting.
Choose the LTC. Agree scope, fees and reporting lines.
Design the board. Name directors, a succession plan and a decision process.
Draft the trust deed and the PTC constitution together. Keep the powers consistent.
Incorporate, then fund. Put assets in once the structure and checks are in place.
Run the calendar. Board meetings, minutes, AML reviews and a yearly check that the connected-party tests still hold.
Our perspective
Most families who ask about PTCs are really asking whether they can keep control without losing safety. We think the PTC answers that well for the right family, and badly for the wrong one.
The errors we see are rarely in the incorporation. They are in the people and the paperwork around it. A beneficiary who is not a connected person. A board with no plan for the next generation. A trust deed that gives the settlor so much power that the tax or legal position becomes uncertain. Each is cheap to fix at the drafting stage and costly after.
We also think a PTC should be the last piece you add, not the first. Get the will, the nominations, the liquidity plan and the underlying trust right. Then ask whether a family trustee company improves on a professional trustee. For some families it does, and for many it does not. We will say so plainly.
— Joseph
How we can help
A PTC works best on top of a sound estate foundation. We help with the pieces around it: a comprehensive will (testamentary trust) at $1,250 to $1,900 one-off, portfolio structuring and estate optimisation from $1,500 one-off, and a schedule of assets, estate liquidity analysis and asset nomination from $500 one-off. A business value protection trust starts from $8,000 one-off. PTC setup itself has no published price, so we scope it in a consultation.
See the full list on our estate planning services page, or start a conversation through Elite Legacy Planning.
FAQ
Does a PTC need a MAS licence?
No, if it qualifies for the section 15 exemption. It must serve only specific trusts with connected settlors and beneficiaries, and take no public business. It must also use a licensed trust company for the administration checks MAS requires.
Can a PTC act for another family?
No. A PTC cannot provide trust services to the public, and that includes unrelated families. Shared arrangements across families need a licensed trustee.
Do AML rules apply to a PTC?
Yes. MAS Notice TCA-N03 has applied to exempt PTCs since 1 July 2025. It covers risk assessments, customer due diligence, documentation and senior-management approval of policies.
Who counts as a connected person?
The definition is in regulation 2 and the Schedule to the Trust Companies (Exemption) Regulations. Check every settlor and beneficiary against it before you design the trust, with a lawyer.
Should I take advice first?
Yes. The Ministry of Law advises families to choose trustees carefully and take legal advice when setting up a trust or a PTC. Tax and family-law questions often need their own adviser.
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