Singapore and Central Register of Controllers

As of July 30, 2020, Singapore applies a more extensive reporting requirement in relation to so-called controllers.

Controllers are or can be individual shareholders, holding directly, indirectly or beneficially at least 25% of a shares with voting power, issued by the Singaporean entity. A controller in this sense equates the definition of “UBO” or ultimate beneficial owner.

Next to the registering of controllers in the Register of Registrable Controllers (RoRC), that information is now also to be supplied to, and processed in, the Central Register of Controllers (CRC) which is maintained by the Singaporean Accounting and Corporate Regulatory Authority (ACRA). Maintaining an RoRC has been mandatory for all companies operating in Singapore, as of March 2017; the RoRC is to be kept in Singapore e.g. at its local headquarters; upon request, certain government officials will have to be given access to the register. The change now applied sees to a proactive supply of controller related information in a centrally kept and maintained register, the CRC. This CRC information is not publicly available. Late filing of controller information to the CRC will result in a substantial financial penalty.