Singapore’s CSP Act: The End of the ‘Silent’ Nominee Director

The S$3 billion money laundering scandal of 2023-2024 was the catalyst for the biggest shake-up in Singapore's corporate secretarial sector in decades. In response, Parliament passed the Singapore CSP Act (Corporate Service Providers Act 2024) and the Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024 on July 2, 2024. These rules went live on June 9, 2025, fundamentally changing the rules of engagement for foreign businesses and their local representatives.

In the past, the entry barrier for corporate service providers (CSPs) was relatively low. That’s over. The new framework brings Singapore in line with Financial Action Task Force (FATF) standards on beneficial ownership. Now, any firm providing corporate services in or from Singapore—even those only serving overseas clients without touching ACRA’s internal systems—must be registered with the Accounting and Corporate Regulatory Authority (ACRA). This includes anyone forming corporations, providing registered addresses, or acting as a company secretary or director as a business.

To stay legal, a CSP must now appoint at least one Registered Qualified Individual (RQI). The stakes for ignoring this are high. Operating without registration can land individuals a S$50,000 fine, two years in jail, or both. If a provider keeps operating after a conviction, they face a continuing offence fine of up to S$2,500 every single day.

For any international company setting up shop here, appointing a local resident director is a standard statutory requirement. However, the new law makes this a high-risk move by shifting the burden of vetting onto the CSPs. A registered CSP cannot just put a name on a piece of paper; they are strictly prohibited from arranging a nominee director unless they are certain the person is 'fit and proper.' This means the CSP has to actually check the person's competency, compliance track record, and existing workload to ensure they can handle their fiduciary duties.

We’re already seeing this squeeze the market. Professional nominee director fees in Singapore, which usually sit between S$1,500 and S$4,000 annually, are climbing as the pool of qualified candidates shrinks. On top of that, providing nominee directorships 'by way of business' outside of a registered CSP setup is now a crime. ACRA has also raised the stakes for the providers themselves—CSPs and their senior management now face fines of up to S$100,000 per breach of their AML/CFT duties. If you're a foreign owner, expect your provider to ask for a lot more documentation during onboarding than they used to.

Nominee Directorship: Old vs. New Regime

By 2026, the regulatory environment has moved firmly into a phase of strict enforcement. For foreign business owners, the biggest red flag is the personal liability now hanging over nominee directors. The Singapore High Court has made it clear that 'silent' directors are a thing of the past. In the landmark PP v Low Beng Huat [2024] case, the court ruled that directors cannot simply delegate their statutory duties and look the other way.

The courts have backed this up with a much tougher sentencing framework for negligent nominees who let their companies become conduits for dirty money. The baseline sentence for this kind of negligence is now four months in prison. It’s a dual-pressure system: the CSP faces a S$100,000 fine for bad vetting, and the nominee faces jail for bad oversight. ACRA’s track record shows they aren't bluffing; between 2021 and mid-2024, the authority handed out 41 sanctions to CSPs and RQIs, resulting in 31 registrations being cancelled or suspended.

If you haven't reviewed your corporate service arrangements recently, you need to do it now. The Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024 introduced strict disclosure rules, specifically the mandatory Register of Nominee Directors (ROND) and the Register of Nominee Shareholders (RONS). Companies incorporated after June 16, 2025, had to comply immediately, but all existing entities were required to have these filed with ACRA by December 31, 2025.

Under this regime, the fact that a director or shareholder is a nominee is now visible on ACRA business profiles. While the identity of the person who 'nominated' them stays private from the public, CSPs have to hand that info over to the Registrar for law enforcement access. You have a 14-day window to file any updates to these nominee registers with ACRA. If you provide false or misleading information, the fine hits S$25,000. For companies that repeatedly fail to keep accurate records, ACRA has the power to strike them off the register entirely.