Focused comparison
Singapore custody/client assets vs United Kingdom custody/client assets
A focused comparison for custody/client assets businesses choosing between Singapore and United Kingdom.
| Question | Singapore | United Kingdom |
|---|---|---|
| Likely route | CMS custodial services and client asset safeguarding analysis | FCA safeguarding, custody, CASS, arranging custody, and prudential analysis |
| Key people | 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 | Senior Manager Function approval where a controlled function applies Certification for relevant staff under SM&CR where applicable |
| 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 | Capital and financial resource expectations depend on activity, client type, custody, and the specific licence or exemption path. | Capital and prudential requirements depend on the permissions, MiFID/MIFIDPRU status, client asset position, and business model. |
| Timeline | Typically 4 to 9+ months depending on route and readiness. | FCA service standards distinguish complete and incomplete applications; practical timelines often run 4 to 10+ months. |
| Common bottlenecks | Assuming accredited or institutional clients remove all licensing questions Weak explanation of investment strategy, risk management, or outsourced functions | Permissions requested do not match the actual operating model Financial forecasts are inconsistent with the applicant legal entity or prudential category |