Who this page is for
- - Custodians
- - Managers with custody risk
- - Platforms handling client money
- - Brokers and fund operators
- - Fund managers serving accredited or institutional investors
- - Broker-dealers and product distributors
Likely route questions
- - CMS custodial services and client asset safeguarding analysis
Activity trigger map
- - Can the firm move, instruct, deduct from, or otherwise control client assets?
- - Are client assets held directly, by a custodian, by a fund vehicle, or through a platform?
- - What audit, segregation, disclosure, capital, and reporting controls are needed?
- - Which entity will hold, safeguard, control, or arrange custody of client assets?
- - How will professional, accredited, institutional, or wholesale client status be evidenced and monitored?
- - Which domestic permissions, representative approvals, and ongoing obligations apply before launch?
Individual requirements
- - 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
- - Activity-specific entry and examination requirements where applicable
- - Clear senior ownership for compliance, AML/CFT, risk, and operations
Corporate requirements
- - Singapore entity with clear proposed activities and product scope
- - Business plan, financial resources, compliance arrangements, AML/CFT program, and risk management framework
- - Representative framework and supervision model
- - Client classification and marketing controls for retail, accredited, and institutional clients
People and key-person expectations
- - 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
- - Activity-specific entry and examination requirements where applicable
- - Named owners should be able to explain the activity workflow, client type, controls, and evidence pack.
Documents and evidence checklist
- - 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, timeline and bottlenecks
Capital and financial resource expectations depend on activity, client type, custody, and the specific licence or exemption path.
Timeline estimate: Typically 4 to 9+ months depending on route and readiness.
- - Assuming accredited or institutional clients remove all licensing questions
- - Weak explanation of investment strategy, risk management, or outsourced functions
- - Unclear representative arrangements and supervision
- - Marketing plans that drift into retail or public solicitation without controls
Common mistakes
- - Saying the firm does not hold assets while retaining practical control over movements.
- - Not documenting qualified custodian, CASS, client money, or safeguarding assumptions.
- - Do not rely on an exemption without mapping the exact entity, activity, client, and marketing facts.
- - Representative status and individual conduct controls are not afterthoughts.
Disclaimer
Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.