Singapore appreciates the PRMG's assessment.
Singapore views that the recommendation has been fully addressed. The legislative amendments in 2022 and 2024 demonstrate Singapore’s continued commitment to maintaining high standards in our beneficial ownership framework, rather than a response to systemic deficiencies. These enhancements build on an existing framework that has already fully addressed the concerns raised in the original 2018 (Second Round) recommendation.
Singapore’s implementation and monitoring of beneficial ownership requirements are evidenced by the high 91% filing compliance rate to maintain and update the central BO register as of December 2024 and the expansion of inspections. The verification mechanisms to ensure the accuracy of information in the central BO register are comprehensive, covering both point-of-filing verification and post-filing measures such as risk-based inspections, investigations and enforcement actions. Singapore has been able to access and provide BO information when required.
Given the demonstrated robustness of our framework, comprehensive verification mechanisms and high compliance rate, Singapore’s view is that the 2018 recommendation has been fully addressed and the existing framework is effective to ensure the availability of beneficial ownership information. However, we note the position maintained by the PRMG on the need to continue monitoring new legislative amendments, which is consistently applied to all monitored jurisdictions.
Considering the PRMG's interest to continue monitoring implementation of the legislation that was passed in 2024, we will focus our subsequent updates on the implementation of the most recent July 2024 legislative enhancements. With further demonstration of our continued efforts, Singapore hopes that the recommendation will be considered fully addressed by the PRMG in the next Enhanced Monitoring Round.