AML Supervision by the Accounting and Corporate Regulatory Authority (ACRA)
In a Nutshell
ACRA is the statutory AML/CFT/CPF supervisor for: registered corporate service providers and registered qualified individuals under the Corporate Service Providers Act 2024. It also supervises public accountants and accounting entities for compliance with the Accountants (Prevention of Money Laundering and Financing of Terrorism) Rules 2023, where the activities covered by those Rules are undertaken
The rules changed on 9 June 2025. The Corporate Service Providers Act 2024 and the Corporate Service Providers Regulations 2025 replaced the old registered filing agent regime, tightened the fit and proper gate and strengthened nominee director controls.
ACRA supervises through the registration, fit and proper requirements, mandatory training and proficiency requirements, and compliance reviews. Registered CSPs must maintain an independent audit function for their AML/CFT/CPF controls as required by the applicable regulations. ACRA may impose regulatory sanctions, suspend or cancel registrations, and offer composition for specified offences where the law permits.
Mind the boundary. ACRA is the statutory regulator; ISCA supervises professional accountants through EP 200; and MAS supervises financial institutions. A single firm can sit under more than one.
AML Supervision by ACRA
The Accounting and Corporate Regulatory Authority is best known as Singapore’s company registrar, but for anti money laundering purposes it wears a different hat: it is the statutory supervisor of the gatekeepers who help set up and run companies, and of the accountants who audit and advise them. Because a shell company with a hidden owner is one of the oldest laundering tools, ACRA sits at a pressure point in the system. This guide explains how ACRA supervises for AML/CFT/CPF, who falls under it, how the 2025 corporate service provider regime works, and how ACRA registers, reviews and enforces.
For the full map of Singapore’s supervisors, see the guide to AML supervisory authorities. For the underlying statutes, see the AML laws and regulations in Singapore pillar. This page is about ACRA as a supervisor, not a how to for any single firm; where you need the compliance mechanics, follow the links to the detailed CSP and accountant guides.
Where ACRA Sits, and its Legal Basis
ACRA administers Singapore’s company and business registers and regulates the public accountancy profession. Its AML/CFT/CPF supervisory responsibilities include the corporate service provider regime under the Corporate Service Providers Act 2024 and the Corporate Service Providers Regulations 2025, which took effect on 9 June 2025. This regime provides for the registration and regulation of CSPs and registered qualified individuals. ACRA also oversees compliance with the Accountants (Prevention of Money Laundering and Financing of Terrorism) Rules 2023 by public accountants and accounting entities undertaking activities within the scope of those Rules.
These two legs cover different populations and should not be blurred. A corporate service provider helps form companies, provide registered offices, or supply directors and shareholders by way of business. A public accountant audits and signs off financial statements. Some firms do both, and some accountants also provide corporate services, which is why the boundary work later in this guide matters.
ACRA’s dual character, part registry and part regulator, is what makes it effective here. It holds the company register, so it knows which entities exist and who filed to create them, and it also supervises the gatekeepers who do that filing. That combination lets ACRA connect a pattern on the register, for example one individual sitting as director of hundreds of unrelated companies, back to the CSP that arranged those appointments. Few supervisors have that line of sight, and it shapes how ACRA targets its attention.
Who ACRA Supervises for AML/CFT/CPF
ACRA supervises registered CSPs and registered qualified individuals under the Corporate Service Providers Act 2024, as well as public accountants and accounting entities for activities covered by the Accountants Rules 2023. A business carrying on corporate services in and from Singapore must register with ACRA where the services fall within the scope of the Corporate Service Providers Act 2024 and no applicable exemption applies. These services include forming business entities, providing registered office or business addresses, and acting or arranging for persons to act as directors or nominee shareholders. Carrying on corporate services without the required registration may constitute an offence under the Act.
The Guidelines draw the perimeter carefully, because the point is to catch gatekeeping, not ordinary commerce. Simply renting premises to a tenant that happens to use the address as its registered office does not, by itself, make the landlord a CSP; the test turns on whether the address is being provided as a service. Likewise, a person whose directorship or shareholding was arranged through a registered CSP is generally not required to register separately, and pure intermediaries who only refer clients to registered CSPs sit outside the regime. Getting on the right side of these lines is the first supervisory question a firm faces, and the Guidelines exist precisely to answer it.
Scale of the sector ACRA Gatekeeps
Companies are the backbone of Singapore’s economy and a magnet for misuse. The Legal Persons risk assessment records 428,314 companies at the end of 2023, most of all legal persons. ACRA has conducted more than 2,900 CSP inspections since the corporate service AML regime began in 2015. The AML/CPF/CFT Proficiency Test costs S$45 per attempt, and CSP registration runs for a fixed period, currently two years.
We help corporate service providers and accounting entities build and test the AML programme, independent audit and records ACRA expects to see, before a review lands.
The Corporate Service Provider Regime
On 9 June 2025 the Corporate Service Providers Act 2024 and the Corporate Service Providers Regulations 2025 came into force, replacing the old registered filing agent framework under the revoked 2015 Regulations. The change was not cosmetic. It made corporate service provision a registered activity with a real fit and proper gate, brought nominee directors provided by way of business under tighter control, and set out AML duties, from customer due diligence to record keeping, in the Regulations themselves. Firms that were registered filing agents transitioned into the new regime, and should be reading the current CSP Act and Regulations action guide for the operational detail.
Registration is central to the regime. A CSP applicant must satisfy the applicable registration and fit and proper requirements. ACRA may refuse an application or impose conditions in accordance with the Act. At least one director, owner or partner must complete the prescribed AML/CPF/CFT course and proficiency test within the applicable period before the CSP application or renewal. Registered qualified individuals must separately satisfy the applicable eligibility and fit and proper requirements. CSP and registered qualified individual registrations are generally valid for two years under the new regime and must be renewed.
Where a corporate service provider arranges for a person to act as a nominee director during business, the Corporate Service Providers Act 2024 and the applicable regulations impose requirements relating to the nominee director’s eligibility and the CSP’s responsibilities. The Companies Act 1967 also contains requirements relevant to nominee directors and individuals holding multiple directorships. CSPs must comply with the applicable requirements when arranging nominee director appointments and must carry out the required customer due diligence to identify and verify the relevant customers and beneficial owners.
How ACRA Supervises CSPs
ACRA supervises CSPs across the same risk based cycle every Singapore supervisor uses, tuned to the corporate formation risk. The figure below sets out that cycle.
The process begins with registration and the applicable fit and proper and proficiency requirements. Registered CSPs must maintain appropriate AML/CPF/CFT policies, procedures and controls, including an independent audit function to assess their effectiveness and compliance. ACRA appoints private sector compliance firms to conduct CSP compliance reviews covering eight areas, including risk assessment, internal controls, customer due diligence, beneficial ownership, suspicious transaction reporting and staff training. Following a review, ACRA may request further information, conduct on site inspections or interviews, and take enforcement action where legally justified. Available measures include suspension or cancellation of registration, financial penalties and formal warnings. Composition may be offered for specified offences where permitted by law. Cancellation is the sharpest tool, because without registration the business cannot lawfully carry on corporate services at all.
The independent audit deserves emphasis because it is the control ACRA leans on to test the rest. A registered CSP must be able to describe how it implements and maintains an independent audit of its AML programme, and ACRA can ask to see both the arrangement and what it found. In a review, ACRA typically works from the firm’s own risk assessment and audit outward, sampling client files to check that the customer due diligence, beneficial ownership tracing and screening described in the policy actually happened on real engagements. Where the file does not match the manual, that gap is the finding, and remediation and follow up follow.
This is where ACRA supervision differs from a light touch registry. The register is not a list; it is a lever. ACRA has used it, cancelling registrations and taking action against nominee directors who lent their names to large numbers of companies without knowing who controlled them.
How ACRA Supervises Public Accountants and Accounting Entities
On the accountancy side, ACRA regulates public accountants and accounting entities under the Accountants Act and oversees compliance with the Accountants (Prevention of Money Laundering and Financing of Terrorism) Rules 2023. The Rules apply to accounting entities that prepare to carry out or carry out specified transactions for clients, and to public accountants who prepare to carry out or carry out those transactions on behalf of an accounting entity. The specified activities include buying or selling real estate, managing client money or assets, managing bank or securities accounts, organising contributions for the creation or operation of companies, creating or managing legal persons or arrangements, and buying or selling business entities.
The scoped activities are the key to who is caught. The Accountants Rules apply when a public accountant or accounting entity, by way of business, does things such as buying or selling real estate for a client, managing client money, securities or other assets, managing bank or securities accounts, organising contributions to form or run a company, or creating, operating or managing legal persons or arrangements and buying or selling business entities. An accountant who only audits financial statements and does none of these is largely outside the Rules, while one who helps structure or run client entities is squarely within them. This scoping is why two accounting firms of similar size can face very different AML supervision.
Supervision here runs through ACRA’s practice monitoring architecture and the Public Accountants Oversight Committee, which oversees the quality and conduct of public accountants. ACRA reviews AML/CFT requirements as part of its inspection of public accountants and accounting entities, on a risk based cycle. Singapore has more than 4,200 professional accountants in public practice, including roughly 1,210 public accountants across about 720 accounting entities, so ACRA risk rates and samples rather than inspecting every firm each year. The public ACRA review and inspection process for public accountants sets out how that review works in practice, and firms preparing for it should read that alongside this supervisory overview.
ACRA, Beneficial Ownership and Corporate Transparency
ACRA’s AML role cannot be separated from corporate transparency. A company is only as transparent as the record of who really owns and controls it, and criminals exploit nominee arrangements and layered structures to obscure that. ACRA sits at the point where those structures are created, which is why its supervision connects to the register of registrable controllers and to beneficial ownership more broadly. The obligation to identify and keep accurate controller information, and ACRA’s supervision of the CSPs who help set companies up, are two sides of the same anti laundering coin. Firms should be clear about their register of registrable controllers obligations as part of this.
This is not a company law digression: it is why ACRA supervision matters to the national effort. The 2023 money laundering case turned in part on companies and structures, and the reforms that followed put more weight on corporate transparency and on the gatekeepers ACRA supervises.
The ACRA Compliance Calendar
ACRA supervision mixes a few fixed dates with mostly event driven duties, and it is important not to confuse ordinary business filings with AML obligations. The table below sets out the shape; confirm the exact periods against the current Regulations and ACRA guidance.
Duty type | Examples | Cadence |
Fixed date | CSP and qualified individual registration and renewal; the AML/CPF/CFT course and Proficiency Test before applying | Registration runs for a specified period, currently two years, then renews |
Periodic controls | Independent audit of the AML programme; enterprise risk assessment; training; controller information reviews | On a risk based cycle set by the Regulations and the firm’s policy |
Event driven | Customer due diligence and screening for each engagement; enhanced due diligence for higher risk; suspicious transaction reports; change notifications to ACRA | Triggered by the client, the risk or the change, not by a calendar date |
CSP training and proficiency requirements must be completed within the applicable period before registration or renewal. Under ACRA’s current guidance, CSP registration is renewed every two years, and at least one director, owner or partner must complete the prescribed training and proficiency test within six months before renewal. Independent audit, risk assessment, training and other AML/CFT/CPF controls must be maintained in accordance with the applicable legislation and the CSP’s risk profile. Customer due diligence, screening and suspicious transaction reporting are triggered by the applicable legal requirements and circumstances rather than by a single annual deadline.
ACRA and the National Strategy
Singapore’s national risk assessments treat corporate service provision as a higher risk designated non financial sector, precisely because company formation and nominee arrangements are attractive to launderers. The Legal Persons risk assessment sets out how companies and structures are misused, and the Inter Ministerial Committee that reported in 2024 recommended reforms to corporate transparency and gatekeeper supervision. ACRA’s tightened CSP regime and its enforcement against nominee directors are the supervisory response to those findings. For a CSP or accountant, the practical implication is simple: expect ACRA to treat your sector as higher risk, and to inspect accordingly.
Enforcement Powers and Outcomes
ACRA’s enforcement tools should be read in two columns: the statutory ceilings, and what ACRA does. On the CSP side, the Corporate Service Providers Act creates offences with substantial maximum fines and, in some cases, imprisonment, including for carrying on corporate services without registration and for breaches of the nominee director controls. On the accountancy side, the Public Accountants Oversight Committee can take disciplinary action against public accountants. ACRA can also impose specified offences, and can suspend or cancel a registration.
In practice, ACRA has been active. It has conducted thousands of CSP inspections, cancelled tens of CSP and qualified individual registrations in recent years, and acted against several nominee directors, including individuals found sitting as director of well over a hundred companies each without any real knowledge of who controlled them. Company law reinforces this: holding nominee directorships by way of business is channelled through registered CSPs, and holding many directorships can trigger a capacity assessment. The lesson from ACRA’s enforcement is that the register is conditional. It can be withdrawn, and the individuals behind a firm can be held to account. The precise statutory maximums and enforcement counts should be cited from the Act and ACRA’s published figures at publication and kept separate from one another.
Route | What it targets | Consequence |
Statutory offences | Acting as a CSP without registration; nominee director control breaches; CDD failures | Fines and, for some offences, imprisonment, per the CSP Act |
Registration action | Fit and proper or compliance failings | Conditions, suspension or cancellation of CSP or QI registration |
Composition | Specified offences | Composition sums in lieu of prosecution |
Accountancy discipline | Public accountants and accounting entities | Action by the Public Accountants Oversight Committee |
ACRA, ISCA and MAS: Who Supervises Whom
Accountants and corporate service firms are sectors where supervisory responsibilities can overlap. ACRA regulates CSPs and registered qualified individuals under the Corporate Service Providers Act 2024 and oversees AML/CFT compliance by public accountants and accounting entities under the applicable Accountants Rules. ISCA issues Ethics Pronouncement EP 200, which sets AML/CFT requirements and guidance for professional accountants, and its members are required to comply with it. MAS supervises financial institutions under the legislation and regulatory requirements applicable to those institutions. A public accountant who is also an ISCA member may therefore be subject to both ACRA’s statutory requirements and ISCA’s professional requirements. A firm providing corporate services must also assess whether it falls within the CSP regime.
Body | Whom it supervises | Instrument |
ACRA | Registered CSPs and QIs; public accountants and accounting entities | CSP Regulations 2025; Accountants (PMLFT) Rules 2023 |
ISCA | Professional accountants who are ISCA members, for scoped activities | Ethics Pronouncement EP 200 |
MAS | Financial institutions | Sector AML/CFT Notices and Guidelines |
Getting this right matters before an inspection, because each supervisor inspects against its own instrument. A firm that maps its activities to the correct supervisor, and reads that supervisor’s guidance, is already ahead. Suspicions, in every case, are reported to the Suspicious Transaction Reporting Office.
Putting Supervision into Practice
What an ACRA Reviewer Looks At
Registration and fit and proper: whether the CSP and its registered qualified individuals are properly registered and remain fit and proper.
Beneficial ownership due diligence: whether the CSP identifies and verifies the beneficial owners behind the entities it forms or administers.
Nominee director controls: whether nominee arrangements are justified, documented and monitored.
Register of registrable controllers: whether RORC obligations are met for client entities.
Records and filings: whether due diligence records are complete and filings are accurate.
Worked example (illustrative)
A corporate service provider incorporates a company for an overseas client who wants a local nominee director and supplies only a passport copy. If the CSP files the incorporation without verifying the beneficial owner or documenting why a nominee is used, an ACRA review would flag the missing beneficial ownership due diligence and the unmonitored nominee arrangement.
Recent enforcement and what it signals
ACRA has cancelled registrations and taken enforcement against errant nominee directors. The signal is that beneficial ownership due diligence and nominee director controls are the sector’s watched failure points.
Your Reporting Line: STRO
Whoever supervises you, you report suspicion to the same place.Where the statutory conditions for suspicious transaction reporting are met, the relevant person must report the suspicious transaction to the Suspicious Transaction Reporting Office in accordance with the applicable legal requirements. Reports may be submitted through the SONAR platform. ACRA, ISCA or another sector supervisor does not replace the statutory reporting channel.
Conclusion
ACRA has moved from registrar to supervisor with teeth. The corporate service provider regime that took effect in 2025 made registration a fit and proper decision, put nominee directors under real control, and gave ACRA a register it is willing to prune.
On the accountancy side, the Accountants Rules and the oversight committee do similar work. For any CSP or accounting entity, the task is clear: register properly, run and independently test a real AML programme, keep accurate records of who controls the companies you touch, and be ready to show ACRA the file. Do that, and you are supervising yourself the way ACRA would.
Read the detailed CSP and accountant guides for the mechanics, keep an eye on the registered filing agent to CSP transition if you came through the old regime, and use the AML policy documentation service if you need the programme built or refreshed.
Be prepared with documented policies, effective client verification procedures and risk based safeguards that support compliance with supervisory expectations.
Frequently Asked Questions
ACRA supervises registered corporate service providers and their registered qualified individuals, and public accountants and accounting entities. It does not supervise financial institutions, which fall to MAS.
Yes. ACRA supervises public accountants and accounting entities under the Accountants Act and the Accountants (PMLFT) Rules 2023, and corporate service providers under the Corporate Service Providers Act 2024 and Regulations 2025. Professional accountants who are ISCA members are also subject to EP 200.
From 9 June 2025 the Corporate Service Providers Act 2024 and Regulations 2025 replaced the old registered filing agent regime. They made corporate service provision a registered, fit and proper activity, tightened nominee director controls, and set out AML duties directly in the Regulations.
CSP and registered qualified individual registrations are generally valid for two years under the current regime and must be renewed. CSP applicants and renewing CSPs must meet the applicable fit and proper requirements. At least one director, owner or partner must complete the prescribed AML/CPF/CFT course and proficiency test within six months before the CSP application or renewal. Registered qualified individuals must separately meet the applicable registration and eligibility requirements.
A qualified individual is a person registered with the Registrar in connection with a CSP, subject to fit and proper and competency requirements. The QI framework ensures accountable, tested individuals stand behind a registered CSP.
ACRA conducts risk based compliance reviews of CSPs and inspections of public accountants and accounting entities within its regulatory remit. For CSPs, the review may examine AML/CFT/CPF controls, supporting records and the required independent audit function. For public accountants and accounting entities, ACRA examines compliance with the applicable statutory and professional requirements. Where non compliance is identified, ACRA may take the corrective or enforcement action available under the relevant legislation, including suspension or cancellation of a CSP registration where legally justified, and may offer composition for specified offences.
The Public Accountants Oversight Committee exercises its functions under the Accountants Act in relation to public accountants. ACRA also conducts AML/CFT inspections of public accountants and accounting entities subject to the Accountants (Prevention of Money Laundering and Financing of Terrorism) Rules 2023. Any disciplinary action or statutory penalty must be based on the applicable legal powers and the nature of the breach.
ACRA is the statutory supervisor of registered CSPs and of public accountants and accounting entities. ISCA is the professional body that supervises its members through EP 200. A public accountant who is an ISCA member can answer to both.
Yes. ACRA can attach conditions to a registration, suspend it, or cancel it, and it has cancelled registrations and acted against nominee directors. Without registration, a business cannot lawfully carry on corporate services.
About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is a Chartered Accountant with more than 26 years of experience in governance, risk, and compliance. He helps companies with end-to-end AML compliance services, from conducting Enterprise- Wide Risk Assessments to implementing the robust AML Compliance framework. He has played a pivotal role as a functional expert in developing and implementing RegTech solutions for streamlined compliance.
