Singapore VCC insights

MAS Enforcement Report 2025/2026: Lessons for Fund Managers and SFOs

By VCC Editorial Team · Published 14 October 2026 · Updated 16 October 2026

Short answer: The MAS Enforcement Report 2025/2026, covering 1 January 2025 to 30 June 2026, records 19 criminal convictions, S$29 million in financial penalties and compositions, 23 prohibition orders and three licence revocations. For fund managers and family offices the lessons are risk frameworks fitted to the actual book, conflicts, timely regulatory filings, capital, and corroborated source of wealth.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

The MAS enforcement report for 2025/2026 is the regulator’s own account of how it used its powers over eighteen months, and it is unusually direct about the failures that cost firms their licences or their senior managers their careers. This article reads the report, and the MAS releases it links to, from the position of a licensed fund management company (LFMC), a Singapore variable capital company (VCC) manager and a single family office (SFO). All figures below come from MAS publications and Singapore Statutes Online, checked on 14 October 2026.

What does the MAS Enforcement Report 2025/2026 cover?

It covers enforcement outcomes between 1 January 2025 and 30 June 2026 for breaches of MAS-administered Acts, Regulations and Notices, plus chapters on surveillance, the equities market and international cooperation.

The opening message describes rising activity, “driven by higher case openings and a growing pipeline of ongoing investigations”, and singles out three themes relevant to asset managers: licence revocations for serious or recurring non-compliance, accountability of principal officers for oversight failures, and composition penalties against fund management companies that did not adequately manage risks from their underlying investments.

What are the headline figures in the MAS enforcement report?

The headline figures are 19 criminal convictions, S$307,000 in civil penalties, S$29 million in financial penalties and compositions, 23 prohibition orders, 3 licence revocations and 583 other regulatory actions. The table below sets out the figures as MAS published them in the Enforcement Achievements chapter.

Measure (1 January 2025 to 30 June 2026)	Figure	Breakdown given by MAS
Criminal convictions	19	False trading 7, insider trading 1, disclosure breaches 1, offer document breaches 4, unlicensed regulated activity 5, business conduct rules 1
Civil penalties	S$307,000	Imposed on 3 individuals for insider trading
Financial penalties and compositions	S$29 million	7 banks, 6 insurers, 5 major payment institutions, 6 capital markets services licensees, 1 financial advisory firm, 1 individual
Prohibition orders	23	1 to 5 years: 14 individuals; 6 to 10 years: 7; over 10 years: 2
Licence revocations	3	2 capital markets services licences, 1 major payment institution licence
Other actions	583	43 reprimands, 150 warnings, 38 letters of advice, 352 supervisory reminders
Cases opened	233	Insider trading 75, matters concerning conduct of individuals 32, breaches of AML controls 31, disclosure breaches 22, deception or fraud under the Securities and Futures Act 2001 20, unlicensed regulated activity 20, false trading 18, business conduct rules 9, others 6

Source: MAS Enforcement Report 2025/2026, Enforcement Achievements. Cases are categorised by the primary offence that triggered the review.

Most regulatory contact, such as the 352 supervisory reminders, never reaches a press release. MAS also reports an average of 7 months to complete regulatory investigations, against 44 months for criminal investigations. A regulatory finding, including a prohibition order or a composition, can therefore arrive quickly once a file is opened.

Why did MAS revoke capital markets services licences?

MAS revoked two capital markets services licences because the holders persistently failed basic regulatory obligations despite repeated reminders. The report lists three triggers for revocation: breaches of key obligations, repeated failure to remediate deficiencies in time, and giving false or misleading information to MAS.

The two cases MAS names in the report are instructive because neither involved fraud on investors. In the first, announced on 3 July 2025, Xen Capital Asia failed to lodge audited financial statements for 2022 and 2023 and quarterly returns, failed to notify MAS of a change of address and a director’s resignation, fell below two full-time appointed representatives, lacked a commensurate compliance function and did not pay its annual fees. Its sole remaining director was reprimanded. In the second, announced on 29 October 2025, One Heritage Capital Management failed to submit quarterly returns within 14 days of each quarter end from the quarter ended 30 September 2024 and failed to meet capital requirements.

For a fund manager the message is plain: the filing calendar, the base capital buffer and the representative count are licence conditions, not administrative chores. Our guide to building a fund management licence application sets out the staffing and capital standards these firms are measured against from the day the licence is granted.

What did MAS find against fund management companies?

MAS imposed composition penalties on two fund management companies whose risk management frameworks did not identify, address and monitor the risks of the assets they managed, and acted against their senior management. The report observes that some firms “operated with generic risk management frameworks that were insufficiently tailored” to their specific risks.

In the Eurofin Investments case (MAS release of 5 January 2026), the composition fine was S$70,000. MAS found failures in managing credit risk on restructured loans and guarantees, failure to mitigate or disclose conflicts of interest in three managed funds (including directors participating in decisions to finance entities in which they had indirect interests), and nine individuals conducting fund management on the firm’s behalf without being appointed representatives. The chief executive received a one-year prohibition order, MAS finding him not fit and proper under the Guidelines on Fit and Proper Criteria issued under section 7 of the Financial Services and Markets Act 2022, and the chief risk officer was reprimanded.

In the Havenport Investments case (MAS release of 18 May 2026), the composition fine was S$40,000. The weaknesses lay in the risk framework for a loan fund, with inadequate credit assessment of debtors. The firm also breached its base capital requirement without reporting it, and breached licence conditions requiring MAS approval before launching a new product and requiring retail investors to receive personalised advice from independent financial advisers before onboarding. The chief executive and an executive director were reprimanded.

Both cases involve lending exposures, where credit monitoring and related-party dealings are hardest to evidence. A manager running a private credit sub-fund inside a VCC should read these releases as a description of what an inspection will test.

What do the AML/CFT actions mean for family offices and their banks?

The anti-money laundering and countering the financing of terrorism (AML/CFT) actions show that MAS penalises poor implementation of policies, not only their absence, and that source of wealth corroboration is the recurring failure. That standard flows directly to family offices through the banks and trust companies that onboard them.

The report links to MAS’s 4 July 2025 actions against nine financial institutions with a nexus to the August 2023 money laundering case, which fall within the reporting period. MAS imposed composition penalties totalling S$27.45 million and found that all nine institutions “did not detect or adequately follow up on significant discrepancies or red flags” bearing on customers’ purported source of wealth. At one capital markets services licensee, MAS issued prohibition orders of three to six years to four individuals, finding that senior managers had let AML/CFT controls fall behind rapid business growth and had not subjected them to audit review. Senior managers at a licensed trust company were reprimanded for policies that gave insufficient practical guidance on establishing source of wealth.

A separate release on 25 May 2026 records a S$300,000 composition on Padang Trust Singapore, a licensed trust company, for failing to inquire into unusual transactions and to file suspicious transaction reports promptly. Each breach of the relevant MAS notice is an offence under section 27B(2) of the Monetary Authority of Singapore Act 1970, with a maximum fine of S$1,000,000 per offence.

For an SFO, the practical consequence is a deeper source of wealth file at account opening and on periodic review, and a trustee or bank that will ask harder questions about unusual flows. Our article on opening a family office bank account and evidencing source of wealth covers how to prepare that file, and our note on the private trust company exemption and its AML duties covers the trustee side.

How do these lessons apply to a VCC manager and a single family office?

A VCC must at all times have a qualifying manager, so the enforcement standards applied to fund management companies apply in full to whoever manages the VCC. An SFO sits outside licensing only while it stays within the class exemption, and the report shows that unlicensed activity is actively prosecuted.

Under section 46 of the Variable Capital Companies Act 2018, a VCC must have a manager that is the holder of a capital markets services licence for fund management under the Securities and Futures Act 2001, a person mentioned in section 99(1)(a) to (d) of that Act, or a prescribed person. Paragraph (b) of section 46(2) was deleted by Act 24 of 2025 with effect from 6 May 2026, a VCC cannot be its own manager, and a holder of a suspended licence does not qualify. A revocation of the manager’s licence, of the kind described above, therefore leaves the VCC without a qualifying manager and its board facing an urgent replacement. VCC directors should monitor the manager’s regulatory health, not only its performance.

For SFOs, MAS’s revised framework took effect on 15 June 2026. Qualifying SFOs need only notify MAS, maintain an account with a MAS-licensed bank and file an annual return with total assets under management and the name of the bank; existing SFOs have until 15 June 2027 to comply. The report records 20 cases opened for carrying on regulated activities without a licence and 5 convictions for unlicensed conduct. An SFO that begins managing money for persons outside the family, or for co-investors, risks section 82 of the Securities and Futures Act 2001. Our guide to the 15 June 2027 SFO transition explains where the boundary sits.

The market integrity chapter adds a point specific to family wealth. MAS reports that market abuse commonly uses accounts of “family members, friends, employees, associates or their nominees” to conceal beneficial ownership, and describes one manipulator who used 13 trading accounts of friends and associates. A family office operating accounts for several relatives needs clear mandates and records of who decided each trade.

How should a fund manager or family office run a compliance review after the report?

Work through the failure points MAS actually penalised, in order of how quickly each can end a licence or an exemption. This is our suggested order, mapped to the cases above.

1. Confirm regulatory status: the LFMC’s licence category and conditions; the VCC manager’s eligibility under section 46 of the Variable Capital Companies Act 2018; the SFO’s notification, filed or diarised before 15 June 2027.
2. Audit the filing calendar. List every return, audited financial statement, change notification and annual fee with owner and deadline, and reconcile it against what was lodged in the last two years.
3. Test capital daily or at least monthly. Check base capital and financial resources against requirements, hold a buffer, and set an escalation rule for reporting any shortfall to MAS immediately.
4. Reconcile the representative register against everyone who actually manages, deals or advises for the firm.
5. Re-tailor the risk management framework. Map each strategy (private credit, real assets, listed securities) to specific credit, valuation, liquidity and concentration controls, and document how each control is monitored.
6. Re-run conflicts of interest. Identify every director or employee interest in an underlying investment or counterparty, and record the mitigation and the disclosure to investors.
7. Rebuild the source of wealth file. For each higher-risk investor or family member, corroborate significant elements of source of wealth with independent evidence and record how red flags were resolved.
8. Review transaction monitoring and suspicious transaction reporting. Confirm that system alerts are reviewed and closed with reasons, and that risk ratings and monitoring are revisited after any report is filed.
9. Check trading account governance. For family offices, document who has authority over each relative’s or entity’s account and prohibit the use of others’ accounts for any person’s own trading.
10. Minute board oversight of compliance, AML/CFT and risk reports, and commission an independent audit of AML/CFT controls where the business has grown.

Our compliance function effectiveness test for VCC managers is a useful companion to this list.

Frequently asked questions

Are licensed fund management companies named in the report?

Yes, where MAS has already published the action: the two capital markets services licensees whose licences were revoked and the two fund management companies penalised for risk management failures.

Can a director or chief executive be prohibited even if the firm pays the composition?

Yes. In the Eurofin Investments case the firm paid a composition fine and its chief executive separately received a one-year prohibition order for failing to take reasonable steps to ensure compliance. In the AML/CFT actions, prohibition orders of three to six years were issued to senior managers and relationship managers.

Does the report cover financial advisers?

Yes. One financial advisory firm was among those penalised, and MAS issued a three-year prohibition order to a financial adviser who sold unsuitable insurance policies to a vulnerable client. Acting as a financial adviser without a licence or exemption is an offence under section 6 of the Financial Advisers Act 2001.

Is a single family office supervised by MAS?

A qualifying SFO is exempt from licensing under MAS’s class exemption from 15 June 2026, but it must notify MAS, bank with a MAS-licensed bank and file an annual return. If it carries on regulated activity outside the exemption, it is exposed to the unlicensed activity offence in the Securities and Futures Act 2001.

Sources

• MAS, Enforcement Report 2025/2026 (7 October 2026)
• MAS, Enforcement Report 2025/2026: Upholding Standards of Conduct, Competence and Accountability
• MAS, Regulatory Actions against 9 Financial Institutions for AML-Related Breaches (4 July 2025)
• Variable Capital Companies Act 2018, section 46 (Singapore Statutes Online)
• MAS, Revised Framework for Single Family Offices to take effect on 15 June 2026

Raffles Corporate Services helps fund managers, VCC boards and family offices put the compliance basics MAS enforces into working order, from filing calendars to source of wealth files. We support VCC incorporation, family office set-up and ongoing compliance. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 14 October 2026. The Editorial Team, Variable Capital Companies Act.

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