Requirement for Companies, Foreign Companies and Limited Liability Partnerships to maintain Register of Registrable Controllers
With effect from 31 March 2017, companies, foreign companies and LLPs (unless exempted) will be required to maintain beneficial ownership information in the form of a register of registrable controllers, and to make the information available to public agencies upon request.
The aims is to make the ownership and control of corporate entities more transparent and reduce opportunities for the misuse of corporate entities for illicit purposes. This will bring Singapore in line with international standards, and boost Singapore’s on-going efforts to maintain our strong reputation as a trusted and clean financial hub.
(Source: https://www.acra.gov.sg/Register_of_controllers/)
Key points about the Register of Registrable Controllers
- The registers of registrable controllers is to be maintained at prescribed places, e.g. the company’s/LLP’s registered office or the registered office of the registered filing agent.
- The register can be maintained in paper or electronic format.
- The registers of registrable controllers will be kept only by the corporate entity and will not be made available to the public.
- Companies and LLPs must give the Registrar and ACRA officers, as well as public agencies administering or enforcing any written law (e.g. Commercial Affairs Department, Corrupt Practices Investigation Bureau and the Inland Revenue Authority of Singapore) access to their registers of registrable controllers upon request.
- The information therein can only be used by public agencies for the purpose of administering or enforcing the laws under their purview (e.g. investigation of money laundering offences).
- Companies and LLPs will have to declare with ACRA the location of the company’s register of registrable controllers when filing the company’s annual returns or annual declaration .
- Companies and LLPs can discharge their duties by sending notices to the relevant parties and recording their particulars, as well as sending further notices to any other parties that have been revealed as potential controllers. Notices can be sent and replies may be received, in electronic or hard copy format.The company or LLP is not liable should recipients of these notices fail to respond or provide inaccurate responses.
- A controller is required to provide and update information to the company/LLP
Transitional Arrangements for New and Existing Companies and LLPs on maintaining Registers of Registrable Controllers
To help companies and LLPs’ prepare to comply with this new requirement, existing companies and LLPs will be given a transitional period of 60 days from the date of commencement of the new law (31 Mar 2017) to set up the register of controllers, after which they must have and continue to maintain the required registers. Companies incorporated on or after 31 Mar 2017 and LLPs registered on or after 31 Mar 2017 will have a transitional period of 30 days to set up the register.
To comply with this new requirement, the Companies are required to set up and maintain the Register of Registrable Controller and Register of Nominee Director, we would appreciate your confirmation for the parties on the register of controllers and Nominee director for updating the secretarial records.
Our fee is $200 for this update, please confirm if you are engaging our services.
Please reply us latest by 30 April 2017 for our processing.
If you intend to update your own registers, please scan / email us a copy for secretarial record purposes.
Yours truly,
NSC MANAGEMENT SERVICES PTE LTD
