MAS Issues New Governance Guidelines
The Monetary Authority of Singapore (MAS) has once again set the standard for the Variable Capital Company (VCC) ecosystem. With over 1,200 VCCs established and managed by more than 600 financial institutions since the framework's launch in 2020, growth has been impressive. However, with success comes responsibility, and MAS’s latest circular provides vital guidance for fund managers to maintain this momentum while remaining compliant.
Key Takeaways from the MAS Circular highlight:
Governance Standards Reinforced
- VCCs must serve as genuine collective investment schemes, not administrative shells.
- Management must remain MAS-regulated, with at least one qualified director on board.
Compliance Expectations Clarified
- Proper custody arrangements for listed securities are mandatory.
- Dormant VCCs that lack assets or investors should be liquidated.
- Robust AML/CFT frameworks, including accurate beneficial ownership records, are non-negotiable.
Call to Action for Fund Managers
- Reflect on current practices and close gaps highlighted by MAS.
- Ensure substantive management activities — avoid "window dressing" in the fund management.
This review strengthens Singapore’s reputation as a reliable international centre for complex investment structures while conveying a clear message to fund managers to improve compliance and governance.
For fund operators, now is the time to act, to assess, adapt, and align with MAS’s expectations to position your VCCs for sustainable growth in Asia's leading financial centre.

Get In Touch
For more information please contact Michael Velten.
michael@veltenadvisors.com
+6590687547
37 Ann Siang Rd, Singapore 069715
