Singapore Entities to Observe Nominee Shareholders & Enhanced Registrable Controllers Requirements by 5 Dec 2022

On 4 October 2022, the Companies Act 1967 and the Limited Liability Partnerships Act 2005 were amended to introduce the following new requirements:

• Mandatory Requirement to Keep Register of Nominee Shareholders (“RONS”): Singapore companies and foreign companies registered in Singapore (“foreign companies”) are now required to maintain a non-public RONS containing the prescribed particulars of the nominee shareholders and their nominators; and
• Enhanced Measures Where There is No Registrable Controller or the Entity is Unable to Identify Registrable Controller: Singapore companies, foreign companies or Singapore limited liability partnerships (“LLPs“), which have no registrable controller or are unable to identify the registrable controller, are required to identify individuals with executive control as their registrable controllers.

Singapore companies, foreign companies or LLPs (as the case may be) must comply with the above requirements by 5 December 2022.

This Update sets out the key features of these new requirements.