Start with a compliance calendar
Your compliance team should maintain a calendar covering regulatory submissions, control reviews, declarations and other recurring obligations.
For each item, record the deadline, the person preparing the work, the person reviewing it and any approval needed before submission. Set an internal preparation date too. A deadline reminder is considerably more useful when it arrives before everyone is scrambling.
The calendar should reflect your firm’s activities, licence conditions and any specific requirements communicated by MAS.
Annual financial returns
The annual financial reporting package includes the following:
| Form | What it covers |
|---|---|
| Form 1 | Statement of Assets and Liabilities |
| Form 2 | Statement of Financial Resources, Total Risk Requirement and Aggregate Indebtedness |
| Form 3 | Statement related to the Accounts of a Holder of a CMS Licence |
| Form 4 | Statement relating to the Accounts of a Holder of a CMS Licence - Supplementary Information |
| Form 5 | Auditor’s Report |
| Form 6 | Auditor’s Certification |
The package also includes the audited financial statements, auditor’s report and management letter, if any. It is due within five months after the financial year ends. For a 31 December year end, that means 31 May.[1]
Finance, compliance and the external auditor will usually need to coordinate this work. Agree the timetable early enough to allow for questions, corrections and management review.
Quarterly financial returns
Forms 1 and 2 are also submitted quarterly, within 14 days after each reporting quarter ends.[2][3]
For reporting periods ending in March, June, September and December, the corresponding dates are:
| Quarter ending | Forms 1 and 2 deadline |
|---|---|
| 31 March | 14 April |
| 30 June | 14 July |
| 30 September | 14 October |
| 31 December | 14 January of the following year |
Confirm your firm’s assigned reporting periods and deadlines in MAS-Tx.
The Quarterly Income and Expenditure return should be tracked separately, using the deadline specified for that return. Do not assume that it shares the 14-day deadline for Forms 1 and 2.
Cross-border arrangements, where applicable
An LFMC with qualifying arrangements notified under the foreign related corporation or foreign office exemption frameworks must submit Form FR, including the relevant independent assurance certification and information, within five months after its financial year ends.
This is a conditional requirement, rather than an optional submission once the arrangements fall within the framework. It does not apply simply because you invest overseas or have overseas investors.
Form FN serves a different purpose: notifying MAS of the commencement of qualifying cross-border business.[4]
Keep misconduct reporting current
Representative misconduct needs its own assessment, escalation and reporting process when an issue arises.
Under the existing reporting notice, reportable misconduct must be reported upon discovery, no later than 14 days afterwards. From 1 January 2027, the revised notice introduces a deadline of 21 calendar days after the firm first has reasonable grounds to believe reportable misconduct has occurred. The reportable categories and associated procedures also change.[5][6]
If your old calendar includes an annual nil misconduct declaration, update it. MAS has waived the declaration for the calendar year ending 31 December 2026, and the revised regime does not require an annual nil return.[7]
Use the prescribed submission channel
Routine financial returns are submitted through MAS-Tx. Keep the submission acknowledgements and supporting documents with your records.
Follow the channel specified for each requirement. Certain reportable incidents require prompt contact with MAS as well as subsequent reporting through the portal.[2][8]
The ongoing work between reporting deadlines
Once the calendar is in place, the next question is whether your firm’s controls are working in practice.
A practical programme should cover the relevant policies, procedures and assessments, including:
- Compliance manual.
- Employee code of conduct.
- Anti-money laundering and countering the financing of terrorism, or AML/CFT, policies and procedures.
- Enterprise-wide financial crime risk assessment.
- Business continuity management.
- Risk management framework.
- Technology risk management.
- Outsourcing and third-party risk management.
These are areas of coverage, rather than a compulsory set of document titles. Some firms combine related procedures in one manual; others keep separate documents.
The enterprise-wide risk assessment is also an assessment of the business’s risks and controls, rather than simply another policy to file away. The current AML/CFT framework incorporates proliferation financing risks too.[9]
Investment, valuation, operational and financial controls will also need appropriate owners. Compliance can help coordinate the programme, while finance, operations and risk remain responsible for the work assigned to them.
How often should policies be reviewed?
For a smaller LFMC, we generally recommend an annual review of the overall policy suite, with earlier updates when regulations, activities, systems or risks change materially.
A firm with fewer than ten employees and a settled business may have relatively little to change. The review might be straightforward and require no Herculean effort from its compliance officer.
That is still a review worth recording. Document what was considered, whether changes were needed and who approved the outcome.
MAS’s risk management observations for fund managers support having defined review frequencies and clear triggers for earlier reviews.[10]
Specific controls also have their own expectations. For example:
- Enterprise-wide AML/CFT risk assessment: review at least once every two years, or earlier when material trigger events occur. Document the review and obtain senior management approval, including where no significant changes result.[11]
- Material outsourcing arrangements: review at least annually. The outsourcing register should be updated promptly and submitted to MAS at least annually or upon request.[12]
- Business continuity: review critical services and functions, recovery objectives and dependencies at least annually and after material changes. The framework also includes an annual senior management attestation to the Board.[13]
A blanket decision to review everything only once every two years could therefore miss more frequent requirements.
Keep registers current as events happen
Registers help the firm track declarations, approvals, risks and outstanding actions. Depending on your business, useful records may include:
- Outsourcing register.
- Conflicts of interest register.
- Personal account dealing register.
- Risk register.
- Marketing and advertising records.
- Record-keeping and data-management records.
- Training register.
- Employee screening, reference-check and fit and proper records.
- Incident, breach, complaint and audit action logs.
The exact format can vary. What matters is that the records capture the relevant information and are maintained by someone who knows what belongs in them.
Take personal account dealing. If your policy requires approval before an employee buys shares, the employee should obtain that approval before trading. The declaration, decision and any conditions should then be recorded promptly.
Likewise, a new outsourcing arrangement should trigger the relevant assessment and register update. Waiting until the annual review would leave management working from an incomplete picture.[12]
Compliance can prepare reviews and proposed changes. The appropriate approving authority should review and approve them, with clear oversight from the Board and senior management. The firm’s CEO and directors retain ultimate responsibility for compliance, including where support is outsourced.[14]
What should the monitoring actually check?
A quiet month can still involve reviewing existing relationships, following up alerts and checking that controls are being followed.
Depending on the business and agreed responsibilities, regular work could include:
- Reviewing investor onboarding, beneficial ownership and customer due diligence.
- Tracking periodic customer reviews, screening alerts and unusual transactions.
- Checking selected files against the firm’s procedures, including supporting evidence and approvals.
- Following up personal dealing declarations, conflicts, marketing issues and complaints.
- Coordinating with finance and risk on capital requirements, licence restrictions and investment limits.
- Tracking training, control breaches and audit findings through to resolution.
The AML/CFT framework requires ongoing monitoring and appropriate controls. Independent investment and risk monitoring should also reflect the funds’ activities and risks.[9][10]
A signed onboarding form tells you who approved an investor. A monitoring review should also check what information they relied on and whether the red flags were properly addressed.
Agree the scope and frequency of these checks. Investor risk, transaction activity, systems and changes in the business all affect the workload.
Compliance monitoring and independent internal audit also need distinct responsibilities. Your programme should track audit findings and remediation while preserving the independence of the audit function.[9]
For the distinction in practice, see our guide to internal audit for fund managers in Singapore, including audit scope, evidence testing and independence.
Changes that trigger MAS approval or notification
Some obligations arise when the business changes, rather than on a recurring date.
Appointing a CEO or director, or changing a director’s appointment from non-executive to executive, requires prior MAS approval. Representative appointments must be notified before they take effect.[15][16]
Representative cessations must be reported by the next business day, while changes to the principal business address must be notified within 14 days. Changes to the CEO’s or directors’ declared business interests and shareholdings should be notified as soon as practicable.[17][18][1]
Ownership changes need an early check too. Obtaining effective control requires prior approval, and control can arise through arrangements beyond a person’s percentage shareholding.[19]
Tell compliance while the change is being planned. An approval requirement is awkward to discover after the paperwork has already been signed.
The MAS Compliance Toolkit for Fund Management Companies is a useful starting point for approvals and submissions. Your calendar should also capture obligations under relevant notices, guidelines, licence conditions and specific MAS requests.
Give management a report they can use
A good compliance adviser should know these obligations like the back of their hand and send timely reminders, without spamming management.
For many smaller firms, we recommend a concise monthly checklist or update covering:
- Checks completed and work still outstanding.
- Upcoming deadlines.
- Material issues and decisions needed.
- Policy and register reviews.
- Relevant regulatory developments.
- Audit actions, with owners and target dates.
A quarterly compliance report can give the Board and senior management a fuller view of recurring issues, changes in risk and progress on outstanding actions. These are practical reporting arrangements to agree with your firm; urgent matters should be escalated when they arise.
Keep the reporting readable. Management should be able to find the issue, understand its significance and see who needs to do what next.
A quieter firm may have a short report. That is perfectly reasonable when the agreed checks have been performed and the records support the conclusion.
If you are comparing external support, our guide to choosing an outsourced compliance provider in Singapore explains the questions to ask about scope, responsibilities and deliverables.
For help setting up or reviewing your programme, explore Advisors Assemble’s fund manager compliance support or contact [email protected].
Regulatory references reviewed on 4 October 2026.
Sources
- [1]
MAS Compliance Toolkit for Licensed Fund Management Companies. Monetary Authority of Singapore. Revised 29 May 2026; annual financial returns, changes in declared interests and other approval and reporting requirements.
- [2]
Form 1 - Statement of Assets and Liabilities. Monetary Authority of Singapore. Quarterly and annual deadlines and MAS-Tx submission instructions.
- [3]
Form 2 - Statement of Financial Resources, Total Risk Requirement and Aggregate Indebtedness. Monetary Authority of Singapore. Quarterly and annual reporting requirements.
- [4]
Notice SFA04-N17 - Cross-Border Arrangements with Foreign Related Corporations and Notice SFA04-N18 - Cross-Border Arrangements with Foreign Offices. Monetary Authority of Singapore. Conditional notification and annual declaration requirements, including Form FN and Form FR.
- [5]
Notice SFA04-N11 - Reporting of Misconduct of Representatives. Monetary Authority of Singapore. Existing reporting requirements.
- [6]
Notice SFA04-N24 - Reporting of Misconduct of Representatives. Monetary Authority of Singapore. Revised requirements effective 1 January 2027.
- [7]
FAQs on Misconduct Reporting Requirements under the FAA, IA and SFA. Monetary Authority of Singapore. Questions 10 and 13; reporting deadline and waiver of the 2026 nil return.
- [8]
Circular on Financial Institution Incident Reporting. Monetary Authority of Singapore. Initial incident notification and subsequent MAS-Tx reporting.
- [9]
Notice SFA04-N02 - AML/CFT for Capital Markets Intermediaries. Monetary Authority of Singapore. Revised 30 June 2025; risk assessment, policies, customer due diligence, ongoing monitoring and paragraph 14.12 on independent audit.
- [10]
Risk Management Practices for Fund Management Companies. Monetary Authority of Singapore. May 2026; policy reviews, independent risk monitoring and investment controls.
- [11]
Guidelines to Notice SFA04-N02. Monetary Authority of Singapore. Revised 30 June 2025; paragraph 4-18 on enterprise-wide risk assessment reviews.
- [12]
Guidelines on Outsourcing for Financial Institutions Other than Banks. Monetary Authority of Singapore. Paragraphs 4.1.1 and 5.8.2; register submission, prompt updates and reviews of material arrangements.
- [13]
Business Continuity Management Guidelines. Monetary Authority of Singapore. Paragraphs 6.7 and 10.6; annual reviews and senior management attestation.
- [14]
Guidelines on Licensing and Conduct of Business for Fund Management Companies. Monetary Authority of Singapore. Paragraph 3.15; compliance arrangements and CEO and director responsibility.
- [15]
Securities and Futures Act 2001, section 96. Singapore Statutes Online. Approval for CEO and director appointments and changes from non-executive to executive appointments.
- [16]
Appointing a Representative for CMS Licensees or Exempt Financial Institutions. Monetary Authority of Singapore. Representative appointment requirements.
- [17]
Securities and Futures Act 2001, section 99D. Singapore Statutes Online. Representative cessation notifications.
- [18]
Securities and Futures Act 2001, section 93. Singapore Statutes Online. Notification of changes in name or principal place of business.
- [19]
Securities and Futures Act 2001, section 97A. Singapore Statutes Online. Prior approval for obtaining effective control.