Country-specific guidance Current

Requesting beneficial ownership information from a corporate client

Ask for the same controllers the company's own register is required to hold.

A Singapore-incorporated company is required to keep its own register of the people who actually own or control it, so requesting that same information from the client is a natural starting point. This guide sets out a practical approach to that request. It is general information, not legal or compliance advice.

Action plan

1 Ask for the individuals or entities who meet the registrable controller test The test is about ownership and control, not who signs correspondence.

Under the Companies Act's register of registrable controllers (RORC) requirement, a registrable controller is an individual or legal entity with a significant interest in the company, such as more than 25 per cent of its shares, the right to appoint or remove a majority of its directors, or the right to exercise or the actual exercise of significant influence or control. Ask the client to identify controllers against this same test.

  • Ask about interests of more than 25 per cent of shares
  • Ask about the right to appoint or remove a majority of directors
  • Ask about significant influence or control that falls outside those two tests

Done when: Controllers were identified against the Companies Act's registrable controller test, not a general assumption of who owns the company

ACRA: setting up and maintaining a register of registrable controllers
2 Ask when the company's own register was last updated A company's RORC has its own update clock; a stale register is a signal worth following up on.

A Singapore company's private RORC must be updated within seven days of a controller notifying a change, and the corresponding lodgment with ACRA made within two business days of that update. If the client can't say when their register was last reviewed, treat that as a prompt to ask more questions rather than assume the information you're given is current.

  • Ask when the company's RORC was last reviewed or updated
  • Treat a register the client can't date as a reason for closer follow-up
  • Don't assume information from an old register reflects the company's current ownership

Done when: Whether the company's own register is current was confirmed before relying on the information it holds

See the ACRA beneficial ownership register requirements
3 Request different evidence depending on whether the controller is a person or an entity An individual controller needs identity evidence; a legal-entity controller needs registration evidence.

Where a registrable controller is an individual, request identity documents as you would for any individual client. Where the controller is itself a legal entity, request that entity's own registration details so its identity and standing can be checked separately, rather than treating the corporate client's say-so as sufficient on its own.

  • Request identity documents for an individual controller
  • Request registration details for a legal-entity controller
  • Don't accept the client's description of a controller as a substitute for evidence

Done when: Evidence appropriate to whether each controller is an individual or a legal entity was requested

See requesting identity documents from an individual client