Dear Members,

Various issues concerning the trust industry have surfaced recently. STEP members may wish to provide their feedback and views to the STEP Singapore Branch on the matters itemized below:

A. Designation of Tax Crimes as Money Laundering Predicate Offences in Singapore

MAS has issued a Consultation Paper in Oct 2012 titled "Designation of Tax Crimes as Money Laundering Predicate Offences in Singapore" . MAS has also invited interested parties to provide views and comments on the implementation framework outlined in Section D of the Paper. Members may wish to submit their feedback through STEP Singapore Branch. As all comments should be submitted to MAS by 9 Dec 2012, we would appreciate if you could write to us by 23rd Nov 2012 for the committee's perusal and consolidation. Please note that all submissions received may be made public by MAS unless confidentiality is specifically requested for the whole or part of the submission.


We invite feedback on inter alia the following:

a. What are the challenges faced by the trust industry, particularly if the FFI-IRS route is adopted?

b. Assuming that the FFI-IRS option is pursued, what are the specific problems faced by the trust industry in Singapore's operating environment given that our Banking Act and the Personal Data Protection Bill already allow for client consent? 

c. How difficult will it be to obtain client consent? Are these issues Singapore-specific or do they apply to other jurisdictions as well? Where possible and relevant, please provide quantitative estimates to better gauge the materiality of the industry's concerns. 

d. How the G-G can help in addressing these specific problems, and how they are not resolved under the normal FFI-IRS route. 

e. What is the preferred option for the trust industry - FFI-IRS, Model 1 G-G or Model 2 G-G? What are the differences and corresponding benefits? 

f. Any other concerns.

C. Rules on "accredited investor"

We invite feedback on your views on the following:

a. The present definition and regulations of "accredited investor" under section 4A of the Securities and Futures Act (Cap 289). 

b. Whether it provides sufficient clarity in relation to corporate trustees on the requirement for net assets exceeding $10 million in value in relation to an underlying PIC (personal investment company) of the trust, the Settlor and/or Beneficial Owner of the trust, particularly for bank accounts opening and other transactions. 

Please revert with your feedback via email to This email address is being protected from spambots. You need JavaScript enabled to view it. by 30th Nov 2012.


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