Compliance
Building The “3L” Infrastructure For Asia’s New Family Offices
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The surge in the number of single-family offices in Singapore counts as a major success story, but all growth brings certain tasks, and compliance rules are significant. Singapore's central bank and regulator has, alongside other bodies, changed the climate for SFOs. This article examines the picture.
The following article, which considers issues generated by the rapid growth in Singapore-based single-family offices, is most timely. This is a large and varied sector. There are also compliance and other challenges for an area that is still young and learning how to operate. The author of this article, Shahnaz Khan (pictured below), is the founder of Elyff Group headquartered in Singapore including Elyff Concierge and Elyff Events. (More on the author below.) The editors are pleased to share this content; the usual editorial disclaimers apply to views of outside contributors. To comment, email tom.burroughes@wealthbriefing.com and amanda.cheesley@clearviewpublishing.com
Shahnaz Khan
Singapore’s family office boom is more than a headline. It is a
structural shift in Asia’s wealth landscape. The Monetary
Authority of Singapore has signalled continued momentum, and
by 2024 the number of single-family offices reached roughly
2,000, up from about 1,650 the previous year. That growth,
paired with Singapore’s ascent to the world’s fourth wealthiest
city with about 242,400 millionaires, underscores why the
ecosystem now needs to build beyond tax and regulatory incentives
towards a robust “3L” infrastructure for lifestyle, legacy and
leadership.
Policy foundations: why capital Is choosing
Singapore
Singapore’s policy stack for family offices is unusually
comprehensive. The Section 13O/13U fund tax incentives provide
tax exemption for qualifying funds managed by Singapore-based
managers. These schemes were extended to 31 December 2029, adding
predictability for planners. Complementing this is the Variable
Capital Company (VCC) structure, which gives managers dividend
and capital flexibility and a scalable umbrella/sub-fund
framework. For significant principals, the Global Investor
Programme (GIP) includes an Option C track to set up a Singapore
SFO with S$200 million ($154 million) AuM, of which S$50 million
must be deployed in specified local investments. Together, these
tools anchor capital and talent onshore. (Sources: Monetary
Authority of Singapore, DLA Piper, Default, Economic Development
Board.)
Policy fine-tuning is ongoing. MAS introduced a three-month
approval regime for family office tax-incentive confirmations,
materially shortening set-up timelines. And to channel wealth
into purposeful giving, Singapore launched the Philanthropy Tax
Incentive Scheme (PTIS) which is a 100 per cent deduction
(subject to caps/conditions) for qualifying donors, now running
until 31 December 2028. This is key in formalising
Singapore’s role as a regional hub for strategic philanthropy.
(Sources: Monetary Authority of Singapore, KPMG Assets, EY.)
At the same time, the regulatory perimeter is tightening. MAS has
issued additional guidance on AML/CFT good practices and
continues to raise standards for intermediaries which is critical
for safeguarding the hub amid rapid inflows. (Sources: Allen &
Gledhill, Monetary Authority of Singapore.) A robust environment
lowering barriers of financial entries with tightening security
sounds like a heaven for the inflow of the UHNW into
Singapore.
A strengthening compliance regulatory
environment
Alongside tax and structuring incentives, Singapore has
reinforced its compliance framework across multiple areas. In
July 2025, MAS introduced revised AML/CFT Notices and Guidelines
for financial institutions and variable capital companies (VCCs),
effective 1 July this year. These updates broaden requirements to
include proliferation financing risk assessments, stronger
identification of beneficiaries and “trust relevant parties,” and
more rigorous screening of sources of funds.
MAS also issued Circular AMLD 12/2024, directing CEOs to ensure
that audit functions are properly resourced, that regular AML/CFT
risk assessments are maintained, and that audit scopes reflect
inherent money-laundering and terrorism-financing risks.
Beyond MAS, the compliance ecosystem is being strengthened across
the industry. Trustees and trust companies are now expected to
meet higher standards in verifying effective controllers,
understanding legal arrangements, and maintaining clear
documentation.
The Anti-Money Laundering/Counter-Financing of Terrorism Industry
Partnership (ACIP) and Regulated Dealers have published a
best-practice paper on Counter-Proliferation Financing, providing
guidance to financial and non-financial institutions on managing
CPF risks, though it is not legally binding. Meanwhile,
capability-building initiatives led by the Wealth Management
Institute, the Law Society of Singapore, and government bodies
are preparing lawyers, trustees, and wealth managers with
specialised programmes in governance, cross-border compliance,
AML/CFT, ESG, and succession planning. Together, these measures
enhance accountability, transparency, and alignment with
international standards, reinforcing Singapore’s position as a
trusted hub for wealth management, funds, and family offices.
The demographic imperative: The great Asian wealth
transfer
Between now and 2030, Asia Pacific families are projected to
transfer about $5.8 trillion in a wave that will amplify demand
for governance, next-gen preparation, impact investing, and
cross-border structuring. For wealth managers and service
providers, the message is clear: the competitive differentiator
will shift from set-up to stewardship. (Source: Elyff
Concierge.)
From policy to practice: Building the “3L”
infrastructure
Lifestyle: UHNW families expect frictionless living that respects
privacy and purpose. Beyond private banking, Singapore should
scale curated healthcare access, education pathways, global
mobility planning, and concierge-quality relocation services that
is well integrated with banks and SFO administrators.
The Julius Baer Lifestyle Index has repeatedly placed Singapore
at or near the top for premium service costs, a signal that
curated value (not discounts) is the opportunity. Providers that
bundle residency, schooling, wellness, and hospitality into
service-level agreements for SFOs will win share.
Legacy: With incentives like PTIS and widely-used 13O/13U
frameworks, families can institutionalise their giving and
investing under robust governance. The next step is turnkey
philanthropy platforms. These include vehicle selection
(VCC/CLG/Trust), mission design, grant-making ops, and impact
measurement which are seamlessly connected to the SFO’s
investment policy statement. Onshore structures and local
deployment requirements under GIP Option C will further encourage
meaningful participation in Singapore’s innovation economy and
community. (Source: Monetary Authority of Singapore, Economic
Development Board)
Leadership: As wealth professionalises, the bottleneck is people.
The market needs next-gen leadership academies that blend
governance, investment literacy (public, private, and venture),
stewardship, and family dynamics coaching. Pair this with
director-readiness tracks for independent board roles and
chief-of-staff pipelines for SFOs. Embedding risk culture and AML
awareness into these programmes aligns with MAS’s emphasis on
controls – futureproofing both reputation and returns.
(Source: Allen & Gledhill.)
Why this matters
For private banks, trustees, law firms, and multi-family offices,
Singapore’s acceleration is not just about AuM capture. It’s
about orchestrating full-stack solutions that combine policy
fluency with human capital development:
-- Structure with purpose: lead with 13O/13U and VCC, where
suitable, but connect them to long-horizon family charters and
investment theses (private markets, venture, sustainable real
assets);
-- Operationalise philanthropy: use PTIS to catalyse high
impact giving; offer outsourced grant ops and outcome
tracking;
-- Compress time-to-live: leverage the three-month MAS
regime to launch faster and then immediately transition clients
into governance, education, and risk programmes; and
-- Elevate assurance: align onboarding and monitoring to
evolving AML/CFT guidance to protect the franchise and client
reputations.
In the global wave of automation and rapid technological
development, these services, rare and personalised, are now
elevated in value – almost creating a cyclical model calling
for the revival of human intervention as a distant nostalgia.
The call to action
Singapore has the policy chassis; the next edge is client
experience. With 2,000 single-family offices and counting
– and an historic $5.8 trillion transfer underway, providers
now need to build a cohesive client experience which
encompass: lifestyle, legacy, leadership stack which will move
from service vendors to generational partners. For wealth
leaders, the playbook is clear: translate statutory advantages
into programmatic value that develops people, not just
portfolios.
About the author
Shahnaz Khan completed her bachelors at the National
University of Singapore and her postgrad in King's College
London. She is the founder of Elyff Group headquartered in
Singapore including Elyff Concierge and Elyff Events. Elyff
Concierge provides bespoke lifestyle management, legacy and
leadership planning services as well as personal assistance
services to UHNW clients and family offices, while Elyff Events
designs and delivers tailored bespoke events experiences.