Your corporate secretary or incorporation provider asks for passports, proof of address, ownership charts and source-of-funds evidence because the law requires it. Under section 17 of the Corporate Service Providers Act 2024, a registered corporate service provider (CSP) must perform customer due diligence before providing any corporate service, including incorporating a company or acting as company secretary. That means identifying and verifying you, the proposed directors and every beneficial owner, screening them, and understanding what the company will do. A CSP that cannot complete these checks generally cannot act for you.
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
Why can’t my provider just take my word for it?
Since the Corporate Service Providers Act 2024 took effect on 9 June 2025, every business that provides corporate services in or from Singapore must register with ACRA and comply with anti-money laundering, counter-terrorism financing and counter-proliferation financing duties. Corporate services include forming companies, acting as or arranging company secretaries, providing registered office addresses and arranging nominee directors or shareholders. Our overview of what the CSP Act means for clients explains the regime itself.
ACRA’s Guidelines for Registered Corporate Service Providers set out what CSPs must do. The key point for founders is that verification must use “reliable and independent sources”. A declaration from you is a starting point, not the end of the check. ACRA reviews CSPs’ files, and a CSP that skips due diligence risks fines and enforcement action, so a careful provider is protecting both of you.
What information must the CSP collect about me?
For every individual customer and agent, the CSP must obtain and record at least:
- full name, including any alias;
- identity card, birth certificate or passport number;
- residential address and contact number;
- date of birth; and
- nationality, including any dual nationality.
Where the CSP is forming a company, it must also establish the identities of the proposed directors. It must verify the identities using reliable, independent sources, verify the authority of anyone acting for you, and keep copies of the documents used. It must also inquire whether anyone else is a beneficial owner and take reasonable measures to verify that person’s identity.
Every customer, agent, connected party and beneficial owner must be screened against sanctions and terrorism lists provided by the authorities, and ACRA expects CSPs to check for adverse news as well. That is why a provider may come back with questions about a news article you had forgotten about.
Why does the CSP want a structure chart and details of the beneficial owner?
If a company, trust or other entity will be a shareholder, the CSP must understand its ownership and control structure and identify the natural persons behind it. The guidelines describe a cascade: first the individuals who ultimately own the entity; if that is unclear or there are none, those with ultimate effective control; and failing both, the individuals with executive authority, such as senior managers. For a trust, the settlor, trustees, any protector, the beneficiaries or class of beneficiaries, and anyone with ultimate control must be identified.
The CSP will therefore ask for a chart tracing every layer up to individuals, with percentage holdings. Holding chains through several jurisdictions are not unlawful, but each layer needs documents. Your company will also need this information for its own register of registrable controllers, explained in our guide on who counts as a registrable controller.
Why am I being asked about source of funds and source of wealth?
ACRA’s guidelines distinguish two ideas. Source of funds is the origin of the money involved in the relationship, for example the cash used to pay up share capital or to buy shares from an existing shareholder. Source of wealth is how the customer came to have their overall wealth, such as business profits, employment, an inheritance or a sale of assets.
CSPs must establish source of wealth and source of funds by appropriate and reasonable means when enhanced due diligence applies, and corroborate what you say against documents or public information appropriate to the risk. The guidelines say checks should be risk-proportionate and should not unduly hinder legitimate businesses. In practice, a founder putting in modest capital from salary savings will face lighter questions than a first-time founder injecting several million dollars from an overseas holding company.
When will I face enhanced due diligence?
The guidelines require enhanced checks in situations including:
- a customer or beneficial owner who is a foreign politically exposed person (PEP), or a family member or close associate of one, which ACRA treats as always high risk;
- domestic or international organisation PEPs, assessed on a risk-sensitive basis;
- customers from or in a country subject to a Financial Action Task Force call for countermeasures or enhanced due diligence;
- complex or unusually large transactions, or unusual patterns with no apparent economic or lawful purpose;
- structures where the CSP cannot establish any real business activity or commercial purpose; and
- any other customer the CSP assesses as high risk.
Enhanced measures can include more information on your business and intentions, source of wealth and source of funds evidence, senior management approval at the CSP and closer ongoing monitoring. A customer who is not met face to face also requires additional documents, data or information to compensate for the higher risk. If you or a family member holds or held a senior public role anywhere, say so at the start. Our article on politically exposed persons explains who is caught.
What documents should founders prepare?
| Document | Why it is asked for | Practical tip |
|---|---|---|
| Passport or NRIC | Identity and nationality verification | Send a clear colour copy with the signature page; check it has not expired |
| Proof of residential address | Required identification particular | Use a recent utility bill, bank statement or official letter in your own name |
| CV or professional profile | Understanding your background and plausibility of the business plan | A short summary or professional profile is usually enough |
| Business description | Purpose and intended nature of the relationship | Explain products, customers, countries and expected funding in plain terms |
| Structure chart | Identifying beneficial owners | Trace every layer to individuals, with percentages |
| Source of funds evidence | Where enhanced checks apply, origin of capital or purchase money | Bank statements, sale agreements, dividend records or payslips |
| Corporate shareholder documents | Identity, constitution and powers of the entity | Certificate of incorporation, constitution, registers of directors and members, authorising resolution |
For a fuller list of incorporation documents, see our incorporation documents checklist.
Do foreign documents need to be certified or apostilled?
Often, yes. ACRA’s guidelines say that in higher-risk situations, such as foreign customers not residing in Singapore, CSPs should take reasonable measures such as accepting statutory declarations or copies certified as true copies by notaries public, commissioners for oaths or registered lawyers. Corporate shareholder documents from overseas are usually requested in certified form.
Singapore joined the Apostille Convention with effect from 16 September 2021, according to the Ministry of Law. Public documents from another member country that carry an apostille can generally be used in Singapore without further legalisation. Ask your CSP early whether it needs notarisation only, an apostille or a certified translation, because getting these overseas can take weeks.
What must I disclose to the company itself?
Separately from the CSP’s checks, the company has its own beneficial ownership duties. ACRA’s announcement on the requirements that commenced on 16 June 2025 states that new companies must submit controller and nominee information on incorporation, that controllers must give a signed and dated annual confirmation that their information is accurate, and that particulars in the register of controllers must be updated within seven calendar days of a change. If you hold shares or a directorship as a nominee for someone else, you must tell the company and give the nominator’s details.
What happens if my documents do not match?
Inconsistencies are common: a different address on the passport and the utility bill, a name spelt differently in two languages, or a structure chart that does not match the foreign registry extract. Expect the CSP to ask for an explanation and supporting documents. Answer fully and early.
A CSP may only start work before verification is complete in limited circumstances, where deferral is essential to normal business and the risks can be managed. If a CSP forms a suspicion of money laundering or terrorism financing, it must consider filing a suspicious transaction report, and it may stop asking questions if continuing would tip you off. That means a provider may decline to act without giving detailed reasons. Changing provider does not remove the issue, because the next CSP must perform the same checks.
Due diligence also continues after onboarding. CSPs must monitor every business relationship, re-screen customers periodically and refresh information when something changes, such as a new shareholder or a change in business activity. CSPs must keep due diligence records for five years after the relationship ends.
Example: a foreign holding company founder
Example: A founder living overseas wants to incorporate a Singapore subsidiary owned by her family’s holding company, which is in turn owned through a trust. She sends a passport scan and asks the CSP to proceed within two days.
The CSP explains that it must identify the holding company’s ownership and control, the trust’s settlor, trustees and beneficiaries, and the proposed directors, and that a non-resident customer met remotely requires additional verification. It asks for certified copies of her passport and proof of address, the holding company’s certificate of incorporation, constitution and register of members, a structure chart, a summary of the trust’s parties and a board resolution approving the investment. Because the paid-up capital will come from the holding company’s dividends, it asks for the relevant financial statements. With a complete pack, the CSP completes its checks and the incorporation proceeds. The founder also signs the controller information the new company needs for its registers.
Frequently asked questions
My bank already did KYC. Why repeat it?
A CSP can rely on certain third parties, such as Singapore financial institutions, lawyers and public accountants, only if strict conditions are met, including getting the due diligence information from them immediately. The CSP remains responsible, so in practice it will still ask you for documents. Our guide to opening a corporate bank account explains the bank’s own checks.
Can I use Myinfo instead of sending copies?
ACRA’s guidelines note that Myinfo business can be used to establish and verify identities, with the customer’s consent. Ask your CSP whether its onboarding process supports it.
Will the CSP send my documents to ACRA?
The CSP keeps its due diligence records and must make them available to ACRA on request. The company’s own controller and nominee information is filed with ACRA separately as part of its statutory obligations.
How often will I be asked to update my documents?
It depends on the CSP’s risk assessment of you. Expect requests when documents expire, when ownership or business activities change, and periodically for higher-risk relationships.
Need help preparing your onboarding documents?
Raffles Corporate Services can tell you exactly which documents we need for your structure, review your ownership chart before you submit it, prepare your registers of controllers and nominee directors and shareholders, and handle the incorporation and ACRA filings once due diligence is complete. Contact us at [email protected] or on WhatsApp at +65 8501 7133.
Willie Tan, Raffles Corporate Services