Focused comparison
Australia custody/client assets vs Singapore custody/client assets
A focused comparison for custody/client assets businesses choosing between Australia and Singapore.
| Question | Australia | Singapore |
|---|---|---|
| Likely route | AFSL custody, depository, client money, and responsible entity analysis | CMS custodial services and client asset safeguarding analysis |
| Key people | Responsible managers with appropriate competence and organisational capacity Authorised representatives where services are provided under another licensee | Appointed representatives for regulated activities conducted on behalf of CMS licensees or exempt financial institutions Fit and proper assessment for directors, representatives, substantial shareholders, and key persons |
| Corporate evidence | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers |
| Capital/resources | Financial resource expectations depend on authorisations, financial products, client money/custody, and licensee obligations. | Capital and financial resource expectations depend on activity, client type, custody, and the specific licence or exemption path. |
| Timeline | Often 4 to 8+ months depending on authorisations and proof quality. | Typically 4 to 9+ months depending on route and readiness. |
| Common bottlenecks | Requested authorisations are broader than the actual operating plan can support Responsible manager evidence is thin or not matched to all authorisations | Assuming accredited or institutional clients remove all licensing questions Weak explanation of investment strategy, risk management, or outsourced functions |