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Trusts and estates
A trust file can contain the right documents and still leave important questions unanswered. Who exercises control? Has a change in the parties been assessed? Does the wealth evidence support the explanation? Who owns the next review or regulatory submission?
Advisors Assemble helps Singapore trust companies organise their compliance arrangements around the Trust Companies Act, applicable regulations, licence conditions and MAS AML/CFT requirements. You work directly with Jackie on an agreed review, remediation or ongoing-support scope, with clear responsibilities for management and the firm's appointed personnel.
Discuss your trust company's compliance needs.Who it is for
Support can be discussed with licensed trust companies, private trust companies and professional firms working with trusts and estates. Their regulatory positions differ. The Trust Companies Regulations cover matters including appointments, financial resources, insurance, business conduct, records and reporting for licensed trust companies. [1]
MAS Notice TCA-N03 applies to licensed trust companies and exempt private trust companies. A PTC's exemption does not remove its requirement to engage a licensed trust company for the relevant trust-administration work, including the required AML/CFT checks. AA's advisory engagement would support that arrangement, rather than fulfil the licensed trust company's role. [2][3]
Other trustees and professional firms may operate under different requirements, including the Trustees Act or their profession's framework. We establish the applicable position before proposing a scope. An estate-planning label does not, by itself, make a business subject to the TCA. [3]
How we can help
Review the business activities, licence or exemption position and current procedures. Organise the relevant approvals, notifications and submissions, with owners and evidence requirements. For licensed firms, this can include preparation support around appointments, financial-resource information, insurance records and trust-business reporting. Filing responsibility and management approval remain clear. [1]
Review the firm's risk assessment and prepare or maintain procedures tailored to its trust business, structures, counterparties and delivery arrangements. Connect the written procedures to the work staff perform and the matters they escalate. [2]
Review selected files and the identification of relevant trust parties and effective controllers. Assess risk ratings, source-of-wealth or source-of-funds evidence, higher-risk issues and the reasoning behind acceptance or continuation decisions. Record gaps and the actions needed from the responsible team. [2]
Help organise periodic and event-driven reviews, screening exceptions, relevant transaction concerns and unresolved actions. Review whether the record explains what was checked, who made the decision and what must happen next. Findings and escalation should be usable by management. [2]
Prepare or review agreed controls for responsibilities, conflicts, client information, outsourcing and AI use. Assess consequential workflows and human review, including where staff use AI to analyse client material or prepare communications. AI governance is assessed against its applicable framework and actual use, rather than presented as a universal requirement of the TCA itself.
Provide focused staff education, selected control checks and concise management reporting. Support agreed responses to regulatory or audit queries, with a record of the evidence, decisions and outstanding work. [2]
We would not reuse an SFA04-N02 customer file checklist or an LFMC submission calendar unchanged. The work needs to reflect the trust-company framework, trust relevant parties, effective controllers and the firm's actual services. Resident-manager and other appointments, reporting and financial-resource matters need their own assessment. The responsible trustee and management retain their respective decisions and duties. [1][2]
Where independent audit or assurance is needed, scope and independence must be assessed separately. A review of controls AA has helped implement must not be presented as an independent assessment of AA's own work.
Lawyers, accountants and other professional firms may need help organising selected due-diligence records, policies or governance work around family structures. We can discuss support within the relevant professional framework and agreed responsibilities. Legal drafting, probate, tax work, investment decisions and trustee appointments remain with the relevant appointed professionals.
Working together
The first discussion covers your entity, activities, current arrangements and immediate concerns. We review the relevant scope and agree the workstreams, records, deliverables and escalation arrangements in writing. Support may begin with an initial gap review and move into remediation or recurring work where appropriate.
For a prospective trust company, application-readiness and supporting policy preparation can be discussed as a separate project. The proposal would identify the materials AA prepares, the information and appointments the applicant must provide, and support for agreed regulatory queries. MAS determines the licensing outcome.
About Jackie and Advisors AssembleStart with a conversation
Bring the business scope, existing compliance setup and the issue that needs attention. We agree a suitable secure process before asking for confidential trust or client records.
Discuss your trust company's compliance needs.