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Role of Company Secretaries in Singapore

The Evolving Role of Company Secretaries in Singapore’s Fight Against Financial Crime

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Corporate secretaries in Singapore now have a critical role, particularly in governance and regulatory compliance, as part of Singapore’s tightening AML/CFT framework. With the Monetary Authority of Singapore’s (MAS) 2024 National Risk Assessment identifying corporate service providers (CSPs) as one of the highest-risk sectors for money laundering, the days of seeing company secretaries as merely administrative support are gone. The role of company secretary in Singapore now includes strategic gatekeeping, too. Interestingly, the country continues to grow as a global financial hub, with an AUM of $4.9 trillion. Naturally, financial organisations in the country are susceptible to cross-border threats.

Company secretaries in the country must comply with the high standards of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) norms. Besides ensuring corporate compliance, it’s time that company secretaries mitigate illicit finance risks from the ground up.

The Expanding Role of Company Secretaries in AML and CFT Oversight

Traditionally, company secretaries in Singapore have been considered as governance administrators. However, the responsibilities of these professionals have evolved significantly. Under current compliance expectations, they are expected to serve four essential AML functions.

  • Board reporting: Providing regular updates on AML/CFT compliance to directors and maintaining minutes for internal accountability.
  • Regulatory filings: Ensuring timely and accurate submissions related to beneficial ownership registers, suspicious transaction reporting, and ultimate beneficial owner (UBO) disclosures.
  • Internal training: Coordinating AML awareness programs for directors and senior executives, ensuring all key personnel are equipped to identify and act on compliance risks.
  • Policy oversight: Providing assistance in drafting and implementing anti-money laundering policies that align with the latest guidelines of MAS.

Strengthening the AML Framework: Core Compliance Pillars

Here are the core compliance pillars that strengthen Singapore’s AML framework:
1. Risk Assessment

An effective AML program begins with a clear view of risk. Company secretaries must take the initiative in establishing a dynamic risk assessment framework. This structure must evaluate clients, business partners, and structures based on:

  • Jurisdictional exposure
  • Transparency of beneficial ownership
  • Historical conduct
This structure establishes how the rest of the AML strategy is executed and monitored.
2. Customer Due Diligence (CDD)

In recent years, the responsibility for CDD has expanded significantly, particularly in sectors flagged as high risk. Now, the duty of company secretaries includes ensuring that onboarding processes for clients go beyond basic KYC. They need to:

  • Verify Ultimate Beneficial Owners (UBOs)
  • Identify politically exposed persons (PEPs)
  • Document complex shareholding structures
Company secretaries also need to maintain updated registers and make them easily accessible for regulatory inspections.
3. Transaction Monitoring

While transaction monitoring was traditionally handled by finance teams, the current situation demands cross-functional cooperation. Therefore, company secretaries must review and interpret transactional red flags in real-time. These include:

  • Unusually large transfers
  • Inconsistent sources of payment
  • Transactions with countries (https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html)
  • Frequent structural changes

Once detected, they must escalate these within governance channels. In the context of banking compliances in Singapore, early identification of anomalies is essential to preserve institutional integrity.

Why the Regulatory Pressure is Rising

Singapore is tightening its regulatory framework due to rising money laundering (ML) and terrorism financing (TF) risks, driven by:

  • A large share of foreign assets (76% of AUM)
  • Growth of family offices (1,400+)
  • High-profile cases like the recent $2.24B money laundering syndicate

In response, Singapore has:

  • Formed an inter-ministerial task force
  • Strengthened AML/CFT regulations
  • Increased inspections in high-risk sectors
Impact on Corporate Service Providers
Company secretaries are now the first line of defence, responsible for enhanced due diligence, onboarding checks, transaction monitoring, and ensuring compliance.

Proactive Governance Starts with the Right Partner

As the compliance environment in Singapore grows complex, organisations cannot afford to treat the company secretary as a symbolic role. Today, company secretaries serve as gatekeepers of compliance, guiding board decisions, upholding regulatory ethics, and protecting reputational integrity. Companies in Singapore are working closely with established professionals like the IMC Group, which specialises in helping global businesses remain compliant in the evolving regulatory environment in Singapore.

Whether it comes to evaluating governance protocols, onboarding clients, or simply looking for scalable corporate compliance solutions, businesses must consult these experts to fortify their defences. With personalised compliance advice from professionals, global businesses operating in Singapore can adhere to the demanding regulatory environment.

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