Singapore CSP Act 2024: Compliance Guide for Corporate Service Providers

The Corporate Service Providers Act 2024 (CSP Act) and Regulations 2025: What You Need to Know for Singapore Compliance

As of June 9, 2025, Singapore's landscape for corporate service providers (CSPs) will undergo a significant transformation with the enactment of the Corporate Service Providers Act 2024 (CSP Act) and its accompanying Corporate Service Providers Regulations 2025 (CSP Regulations). This pivotal legislative shift, spearheaded by the Accounting and Corporate Regulatory Authority (ACRA), marks a strategic strengthening of Singapore's commitment to combating financial crime, including money laundering (ML), terrorism financing (TF), and proliferation financing (PF).

1. Understanding the New CSP Regime: Purpose and Scope

The introduction of the CSP Act 2024 and CSP Regulations 2025 is a critical step in enhancing Singapore's reputation as a clean and trusted financial hub. It aims to close regulatory gaps, elevate industry standards, and align Singapore with international best practices from bodies like the Financial Action Task Force (FATF).

1.1. Core Objectives of the CSP Act 2024

The new legislation is designed with clear goals in mind:

• Strengthen Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Proliferation Financing (PF) Measures: The primary driver is to ensure all entities providing corporate services adhere to stringent obligations in preventing financial crime. This expanded scope ensures that Singapore's corporate structures are not misused for illicit activities.
• Enhance Transparency: By imposing stricter requirements on the disclosure of beneficial ownership and nominee arrangements, the Act seeks to provide greater clarity on who ultimately owns and controls companies in Singapore.
• Elevate Industry Standards: The Act formalizes the regulation of CSPs, ensuring a higher level of professionalism and compliance across the sector.
• Level the Playing Field: It ensures that all entities providing corporate services operate under the same set of robust obligations, regardless of whether they were previously regulated as Registered Filing Agents (RFAs).

1.2. Who is Affected? Defining "Corporate Service Provider"

The CSP Act broadly defines a "corporate service" (Section 2 CSP Act 2024) to include:

• Forming a corporation or other legal person on behalf of another.
• Acting, or arranging for another person to act, as a director or secretary of a corporation, or a partner of a partnership, by way of business.
• Providing a registered office or a business address.
• Carrying out designated activities in relation to the provision of accounting services (e.g., managing client money, securities, real estate transactions).

Essentially, if your business provides any of these services in or from Singapore, you fall under the purview of the CSP Act and are considered a Corporate Service Provider (CSP).

2. Key Changes and Compliance Obligations for CSPs

For existing and new CSPs, the CSP Act 2024 and CSP Regulations 2025 introduce several significant changes that demand immediate attention and robust compliance frameworks.

2.1. Mandatory ACRA Registration for All CSPs

From June 9, 2025, it becomes mandatory for all business entities providing corporate services in or from Singapore to register with ACRA as a registered CSP (Section 7 CSP Act 2024). This applies even if they don't file transactions with ACRA on behalf of their clients.

• Expanded Scope: Previously, only Registered Filing Agents (RFAs) were regulated. The new Act extends registration requirements to all who provide corporate services by way of business.
• Qualified Individual Requirement: Every registered CSP must have at least one Registered Qualified Individual (RQI) who holds a relevant qualification and has completed mandatory AML/CFT/PF training (Section 9 CSP Act 2024).
• Transition Period: Entities not currently registered as RFAs have a six-month grace period (until December 9, 2025) to complete their registration. Failure to register is a serious offence, carrying substantial penalties, including fines of up to S$50,000 and/or imprisonment for up to two years (Section 7(4) of the CSP Act 2024).

2.2. Enhanced AML/CFT/PF Obligations

All registered CSPs are now subject to comprehensive AML/CFT/PF obligations, which are more stringent than previous requirements.

• Customer Due Diligence (CDD): CSPs must conduct rigorous CDD measures before providing any service, including identifying and verifying the identity of the customer, their beneficial owners, and the purpose of the business relationship. This ongoing monitoring also requires keeping client documentation updated (Section 20 CSP Regulations 2025).
• Risk Assessments: CSPs must undertake regular risk assessments for their customers, countries, products, services, and transactions to identify and mitigate potential ML/TF/PF risks (Section 19 CSP Regulations 2025).
• Internal Policies & Controls: Registered CSPs are required to develop, implement, and maintain adequate internal policies, procedures, and controls (IPPC) to prevent financial crime. This includes robust record-keeping, staff training, and an independent audit function (Section 33 CSP Regulations 2025).
• Suspicious Transaction Reporting (STR): CSPs must promptly file STRs if they suspect any property or transaction may be connected to ML/TF/PF.

2.3. Stricter Nominee Director and Shareholder Requirements

The new regime brings increased scrutiny and transparency to nominee arrangements.

• Fit and Proper Assessment: Only ACRA-registered CSPs can arrange for persons to act as nominee directors by way of business. Before appointment, the CSP must conduct a diligent assessment to ensure the proposed nominee director is "fit and proper." Failure to do so can result in a fine of up to S$100,000 for the CSP (Section 15 CSP Act 2024).
• Disclosure Requirements: The CSP Act enhances transparency by requiring nominee directors and nominee shareholders to disclose their nominee status to ACRA, along with the identities of their nominators. This helps prevent the concealment of true ownership and control, strengthening corporate governance (Section 20 CSP Regulations 2025).

2.4. Increased Penalties for Non-Compliance

The CSP Act introduces significantly higher penalties for breaches of its obligations, underscoring the seriousness of compliance.

• Failure to Register as a CSP: A person who carries on a business of providing corporate services in Singapore without being registered as a CSP is liable for an offense. Upon conviction, this can result in a fine not exceeding S$50,000, imprisonment for a term not exceeding two years, or both. In the case of a continuing offense, an additional fine of up to S$2,500 per day or part of a day may be imposed after conviction.
• Breaches of AML/CFT/PF Obligations: The sanctions for non-compliance with AML/CFT/PF obligations have been dramatically increased. A registered CSP breaching these obligations is liable to a fine not exceeding S$100,000 for each breach. Furthermore, senior management of a registered CSP who fails to ensure compliance with AML/CFT/PF obligations can also face a fine not exceeding S$100,000 for each breach. In more egregious situations, ACRA may also impose regulatory sanctions such as suspension or cancellation of the CSP's registration.
• Nominee Director Violations:
  
  • A person acting as a nominee director by way of business without their appointment being arranged by a registered CSP is guilty of an offense and liable to a fine not exceeding S$10,000.
  • A registered CSP that arranges for a person to act as a nominee director without ensuring they are "fit and proper" is guilty of an offense and liable to a fine not exceeding S$100,000.
• Offences Pertaining to Registers: Companies will face higher penalties for non-compliance with maintaining accurate registers of registrable controllers, nominee directors, and nominee shareholders. The maximum fines for these offenses have been increased from S$5,000 to S$25,000.
• Providing False Information: Providing any false or misleading information to the Registrar is an offense, punishable by fines of up to S$25,000.

3. What the CSP Act Means for Your Business (Engaging CSPs)

Even if your business isn't a CSP, the new Act has direct implications for you. As an entity engaging corporate secretarial services or other corporate services, you may experience enhanced due diligence from your CSP.

3.1. Enhanced Customer Due Diligence from Your CSP

Your existing or new CSP will now be required to collect more detailed information about your business, its beneficial owners, and your nominee arrangements.

• Additional Documentation: You may need to provide more extensive documentation regarding beneficial ownership and nominator details to meet ACRA's enhanced disclosure requirements.
• Increased Scrutiny: Expect more thorough vetting and ongoing monitoring from your CSP to ensure they meet their expanded AML/CFT/PF obligations. This may involve more questions or requests for updated information.

3.2. Ensuring Your CSP is Registered and Compliant

It is crucial to ensure that any corporate service provider you engage or continue to engage is ACRA-registered and fully compliant with the new CSP Act 2024 and CSP Regulations 2025.

• Legal Obligation: While the primary compliance burden falls on the CSP, ensuring your service provider is legitimate and adhering to regulations safeguards your own company's standing.
• Risk Mitigation: Working with a non-compliant CSP could indirectly expose your business to risks, including potential reputational damage or complications with regulatory filings.

4. How Triangle Legal LLC Can Guide You Through the New CSP Regime

Navigating the complexities of the CSP Act 2024 and CSP Regulations 2025 requires not just an understanding of the law, but practical steps for implementation. As a capable law firm in Singapore with expertise in regulatory & compliance advisory and corporate matters, Triangle Legal LLC is uniquely positioned to assist both CSPs and businesses.

Our experienced lawyer in Singapore team provides:

• Compliance Gap Analysis: For existing CSPs, we can conduct a thorough review of your current processes to identify any gaps against the new CSP Act and Regulations.
• Policy and Procedure Drafting: We assist in developing and implementing robust internal policies, procedures, and controls (IPPC) for AML/CFT/PF obligations, tailored to your operations.
• Nominee Arrangement Review: We advise on compliance with the stricter nominee director and shareholder rules, including "fit and proper" assessments and disclosure requirements.
• Guidance for Businesses: If you engage CSPs, we can advise you on what to expect from your providers and how to effectively respond to their enhanced due diligence requests.
• Training and Advisory: We provide training for your team on the new regulatory landscape and offer ongoing advisory to ensure continuous compliance.
• Legal Representation: In the unlikely event of non-compliance issues or investigations by ACRA, our lawyer in Singapore team can provide robust legal representation.

Whether you are a CSP needing to overhaul your compliance framework or a business engaging corporate services, ensuring full adherence to these new regulations is paramount. Contact Triangle Legal LLC, a corporate and commercial law firm in Singapore today for a confidential consultation. Let our expertise in corporate and regulatory compliance be your guide in navigating Singapore's evolving legal landscape.

FAQ

Q1: What is the Corporate Service Providers Act 2024 (CSP Act)

The Corporate Service Providers Act 2024 (CSP Act), together with the Corporate Service Providers Regulations 2025 (CSP Regulations), is Singapore's latest legislative update for CSPs, corporate governance and corporate services. Its primary purpose is to bolster the nation's financial integrity and enhance the fight against illicit activities such as money laundering and terrorism financing.

Q2: How does the new CSP Act broaden the definition of a "Corporate Service Provider" (CSP)?

Previously, regulatory oversight was primarily limited to "Registered Filing Agents" (RFAs). The new CSP Act significantly expands this scope, now mandating registration with ACRA for any person or entity providing "corporate services" by way of business. This includes a wide array of activities such as:

• Forming companies or other legal entities.
• Acting as or arranging for directors or secretaries.
• Providing registered offices, business, or correspondence addresses.
• Acting as or arranging for nominee shareholders.
• Carrying out specific "designated activities" related to accounting services (e.g., managing client money, organizing contributions for entity creation). This expanded definition aims to eliminate regulatory blind spots and strengthen corporate governance by bringing more service providers under ACRA's direct supervision.

Q3: What are "Registered Qualified Individuals" (RQIs) and why are they important under the new CSP Act?

Registered Qualified Individuals (RQIs) are key personnel who either directly provide or supervise corporate services for a CSP. A fundamental requirement under the new CSP Act is that every registered CSP must have at least one RQI. This requirement, coupled with stricter qualification criteria (e.g., specific experience for ISCA or CSIS members), is designed to elevate professional standards and ensure accountability within the corporate services sector. For any law firm in Singapore, understanding the RQI requirements is crucial when advising CSP clients on compliance and best practices.

Q4: What are the key enhanced AML/CFT/PF obligations for CSPs under the new Act?

The CSP Act introduces significantly tougher Anti-Money Laundering (AML), Countering Proliferation Financing (CPF), and Countering Terrorism Financing (CFT) duties for all registered CSPs. Key obligations include:

• Stricter Customer Due Diligence (CDD): Requiring detailed documentation of both source of wealth and source of funds, especially for high-risk clients.
• New remote verification rules: Mandating live video calls and retaining screenshots for non-face-to-face client onboarding.
• Shortened Suspicious Transaction Report (STR) deadlines: Reduced to 5 business days for standard cases and just 1 business day for higher-risk scenarios.
• Mandatory AML/CFT/PF training: Required for key appointment holders and RQIs to ensure up-to-date knowledge. These changes underscore Singapore's commitment to robust financial oversight and will require careful consideration from commercial lawyers and business lawyers guiding their clients.

Q5: How do the new regulations impact nominee directors and shareholders?

The Act introduces stricter rules for nominee directors and shareholders, aiming to boost transparency and prevent misuse. Key changes include:

• A prohibition on acting as a nominee director by way of business unless arranged by a registered CSP.
• CSPs must conduct thorough "fit and proper" assessments for all nominee directors they arrange.
• Mandatory disclosure of nominee status and the identities of nominators to ACRA. While nominee status will be public, nominator details remain confidential to public authorities. These measures are crucial for enhancing corporate governance and ensuring that nominee arrangements are not exploited for illicit activities, a common area of concern for corporate lawyers.

Q6: What are the penalties for non-compliance with the new CSP Act and Regulations?

The penalties for non-compliance have been substantially increased to act as a stronger deterrent against financial crime. For instance:

• Failure to register as a CSP can lead to fines up to S$50,000 and/or imprisonment for up to two years.
• Breaches of AML/CFT/PF obligations can result in fines up to S$100,000 per breach for both the CSP and its senior management.
• Fines for offences related to maintaining accurate registers (e.g., beneficial owners, nominee directors) have significantly increased from S$5,000 to S$25,000.
• Criminal liability can also be imposed for serious breaches, including providing false or misleading information. These severe consequences highlight why corporate lawyers and commercial lawyers are stressing the importance of timely and thorough compliance.

Q7: What should existing Registered Filing Agents (RFAs) do to comply with the new CSP Act?

Existing RFAs will experience a streamlined transition: they will automatically convert to Registered Corporate Service Provider (CSP) status on June 9, 2025, retaining their current registration validity. However, they will need to meet the new, more stringent requirements (such as updated Internal Policies, Procedures, and Controls (IPPC) and RQI qualifications) when their registration is due for renewal. They should also proactively inform ACRA about all the types of corporate services they provide, ensuring full transparency under the expanded definition.

Q8: What essential steps should businesses engaging CSPs take to ensure compliance?

While the new legislation directly targets CSPs, businesses are indirectly affected and should take proactive steps to ensure compliance and robust corporate governance:

• Verify your CSP's registration: From June 9, 2025, it's critical to confirm that your corporate service provider is officially registered with ACRA under the new Act.
• Prepare for enhanced due diligence: Your CSP will be required to ask for more detailed information. Be prepared to provide comprehensive documentation regarding beneficial ownership, source of wealth/funds, and nominator identities.
• Review your corporate structure: If you utilize nominee director or shareholder services, engage in discussions with your CSP and legal advisor to ensure full compliance with the new disclosure requirements. Engaging a fully compliant CSP and maintaining high transparency are vital for managing regulatory risks and protecting your business's reputation. A leading law firm in Singapore can provide invaluable assistance with these critical aspects of commercial lawyers' advice.