Professor Lily Kong, President, Singapore Management University

Mr Gerald Singham, Global Vice-Chair and ASEAN CEO, Dentons Rodyk

Distinguished guests

Ladies and Gentlemen

1. It is a pleasure to join you at this year’s Dentons Rodyk Dialogue. I would like to thank Dentons Rodyk and the Singapore Management University (SMU) Centre for Commercial Law in Asia (CCLA) for the invitation, and for providing this platform for dialogue among legal practitioners, academics and industry leaders.

The Singapore Story

2. Singapore’s development as an international financial centre is, in many respects, an unlikely success story. Despite our small domestic market and limited natural resources, Singapore has become a major centre for international banking, asset and wealth management, and foreign exchange trading. Singapore’s GDP per capita has risen from around US$500 in 1965 to almost US$100,000 in 2025, in nominal US dollar terms. The financial sector accounts for around 14% of Singapore’s GDP, growing by an average of 4.6% annually in real terms from 2021 to 2025.

3. Singapore’s development as an international financial centre was the result of deliberate policy choices. An early example was the establishment of the Asian Dollar Market in 1968. Singapore’s strategic location in Asia and its time zone presented an opportunity to bridge the gap in trading hours between the American and European financial markets. Singapore seized this opportunity by creating a conducive environment for offshore banking, including arrangements that separated foreign-currency activities from domestic banking business. This facilitated international financial intermediation while safeguarding domestic financial stability.

4. Over the decades, Singapore continued to strengthen its financial infrastructure, professional capabilities, and legal and regulatory frameworks. Our experience illustrates an enduring lesson: geographical advantages create opportunities, but sound policies, strong institutions and sustained investment in capabilities turn them into lasting competitive strengths.

5. This brings me to the theme of my address today: attracting capital, enabling enterprise and sustaining trust. Together, they have shaped Singapore’s development as an international financial centre.

• Attracting capital is about creating an environment that draws international investors and financial institutions to Singapore.
• Enabling enterprise is about translating capital and capabilities into investment, innovation and economic growth.
• Sustaining trust is about preserving the institutional credibility and financial integrity on which these activities depend.

6. Singapore's success has depended not on openness alone, but also on strong institutions, well-functioning markets and sound and adaptable legal and regulatory frameworks. These provide the conditions for financial activities to flourish while managing the risks they present.

7. The objectives reinforce one another, but also involve trade-offs. Openness creates opportunities, but also heightens exposure to risks. Innovation brings benefits, but can create new vulnerabilities and amplify existing risks. The challenge is not to maximise openness or minimise regulation, but to strike the right balance between facilitating growth and managing risks.

Attracting Capital: Openness Supported by Strong Foundations

8. Over the decades, Singapore has developed a sophisticated financial ecosystem, bringing together financial institutions, investors, market infrastructure, professional services and specialised talent. These capabilities complement the strong institutions and credible regulatory environment that underpin investor confidence.

9. Today, Singapore is a major asset management centre, with approximately S$6.7 trillion in assets under management at the end of 2025. More than 75% of these assets originated outside Singapore, while close to 90% were invested internationally. Singapore is also Asia’s leading foreign exchange trading centre and the world’s third-largest, with average daily trading volumes reaching S$1.6 trillion in 2025.

10. But capital is mobile. Investors and financial institutions have choices about where to establish operations and deploy investments. They need confidence that their rights will be protected, contracts enforced and disputes resolved fairly. These institutional foundations are essential, but not sufficient. Singapore must also offer financial structures suited to commercial needs, and well-functioning markets that provide attractive investment opportunities. Two examples illustrate how Singapore has sought to strengthen these aspects of its financial ecosystem.

The VCC Framework: Deepening Singapore’s Fund Ecosystem

11. The first is the Variable Capital Company (VCC) framework introduced in 2020. Singapore already had a substantial fund management industry. But having fund managers here did not necessarily mean that the funds they managed would be domiciled here.

12. Investment funds have distinctive commercial and operational needs that conventional corporate structures may not adequately accommodate. These include flexibility in issuing and redeeming shares, making distributions from capital, and managing multiple investment strategies within an umbrella structure. The VCC framework addresses these needs, including by allowing multiple sub-funds whose assets and liabilities are legally segregated.

13. These features make Singapore more attractive for fund domiciliation. VCCs must appoint fund managers that are licensed, registered or otherwise permitted under Singapore’s regulatory framework. By complementing existing fund management capabilities, the VCC framework can help anchor fund domiciliation and related activities here, supporting associated services such as administration, custody, accounting and legal advisory. This illustrates how legal structures designed around commercial needs can strengthen a financial ecosystem and support its continued development.

The Equities Market Review: Connecting Capital with Enterprise

14. A second example is Singapore’s Equities Market Review. Despite our development as an international financial centre, the depth and vibrancy of our domestic equities market have not always kept pace. Managing substantial international capital does not automatically translate into capital formation and financing for enterprises through Singapore’s public markets.

15. Companies considering a listing need sufficient investor demand and market liquidity. Investors, in turn, need an attractive pipeline of quality companies and investment opportunities. Each depends on the other. Strengthening the market therefore requires measures that address both investor participation and the attractiveness of Singapore as a listing venue.

16. The Equities Market Review has adopted this broader approach. On the investor side, the S$6.5 billion Equity Market Development Programme seeks to deepen investment capabilities and attract greater participation in Singapore equities. MAS has allocated S$5.4 billion across 14 asset managers. Encouragingly, the programme has achieved a crowd-in ratio of more than 1:1 to date, with more than one dollar of private capital invested alongside every dollar of public funds deployed.

17. On the issuer side, MAS has pursued reforms to make its listing regime more efficient and attractive, while preserving investor confidence. Changes implemented in October 2025 moved towards a more disclosure-based approach, placing greater emphasis on adequate disclosure of material issues. MAS and Singapore Exchange Regulation Pte. Ltd. (SGX RegCo) have also consulted on consolidating listing suitability and prospectus disclosure reviews under SGX RegCo. This would provide issuers with a clearer and more streamlined listing process.

18. There are encouraging signs, but it is still early days. The longer-term test is whether deeper liquidity, sustained investor participation and an attractive listing environment can draw quality companies and support capital raising. Regulatory reform is an important part of this effort, but so are the capabilities and participation of investors, intermediaries and issuers. A well-regulated market is not necessarily a vibrant market. Our ambition must be to achieve both.

19. The VCC framework and Equities Market Review illustrate complementary aspects of Singapore’s financial centre development. The first provides suitable structures to attract and anchor fund activities. The second seeks to strengthen the markets through which capital can be raised and deployed. Attracting capital, however, is only the beginning. The greater challenge is creating the conditions for capital to be deployed productively, supporting investment, innovation and enterprise. 

Enabling Enterprise: Clear, Proportionate and Adaptable Regulation

20. This brings me to the second theme: enabling enterprise. Businesses need an environment in which they can invest, innovate and operate efficiently. Sound and adaptable legal and regulatory frameworks help provide the certainty businesses need, reduce unnecessary friction and maintain appropriate safeguards.

21. Three qualities of effective regulation are particularly important:

• First, certainty: Clear and predictable requirements enable businesses to plan and invest with confidence.
• Second, proportionality: Requirements should be calibrated to the nature, scale and complexity of activities and the risks they present.
• Third, adaptability: Regulatory approaches must evolve with changing markets, technologies and risks, while preserving their underlying objectives.

22. Let me illustrate how these qualities can support enterprise through two examples. 

Project Guardian: Bridging Innovation and Adoption

23. The first is Project Guardian, MAS’ collaboration with the financial industry on asset tokenisation. Tokenisation offers potential improvements in the issuance, trading, servicing and settlement of financial assets. But demonstrating technological feasibility is not the same as achieving commercial adoption at scale.

24. Financial institutions need confidence in the operational arrangements, risk management and applicable regulatory treatment of tokenised assets. Through Project Guardian, MAS has worked with industry participants to develop common standards and best practices relating to asset servicing, disclosure, interoperability and risk management. These help address coordination challenges that individual institutions cannot readily resolve on their own.

25. MAS has complemented these efforts through its Guide on Tokenisation of Capital Markets Products, which clarifies how existing securities laws apply to tokenised products and related activities. The underlying principle is that the same economic activity and risks should be subject to the same regulatory outcomes, regardless of the technology used. This provides greater regulatory certainty without unnecessarily creating a separate regime for tokenised products.

26. Regulatory clarity, however, does not resolve every legal question arising from tokenisation. MAS continues to examine areas where further clarification may be needed. Project Guardian illustrates how established principles, supported by industry standards and adaptable approaches, can provide a foundation for responsible financial innovation.

Private Banking Onboarding: Proportionality in Practice

27. Private banking onboarding offers another example. Financial institutions must understand their customers' sources of wealth and assess financial crime risks. But due diligence should be proportionate to those risks. MAS's May 2026 guidance therefore emphasised materiality and relevance in source-of-wealth assessments. Financial institutions should focus on corroborating material or higher-risk sources of wealth, rather than attempting to verify every historical detail. Unnecessary documentation requests should be avoided, while material discrepancies must continue to receive appropriate scrutiny.

28. MAS has also worked with the Private Banking Industry Group to improve onboarding processes through clearer practices, better use of technology and stronger professional capabilities. The objective is not to weaken due diligence standards, but to achieve more effective risk assessment while reducing unnecessary delays and costs. Proportionality is not about lowering standards. It is about focusing attention and resources on the risks that matter.

29. These examples illustrate two complementary ways in which regulation can enable enterprise. Project Guardian shows how regulatory clarity and common standards can support emerging financial activities. Private banking onboarding demonstrates how risk-proportionate approaches can improve the efficiency of established activities without compromising safeguards. Effective regulation provides certainty, calibrates requirements to risks, and adapts to evolving markets – while preserving the safeguards that underpin trust.

Sustaining Trust: Safeguarding an Open Financial Centre

30. Singapore’s openness to international capital has been central to our success. But the same connectivity that facilitates legitimate investment and commerce also exposes our financial system to illicit financial flows. Sophisticated financial services and corporate structures serve legitimate purposes but may also be misused to conceal criminal proceeds or obscure ownership.

31. Sustaining trust requires strong institutions, sound governance, market integrity and effective supervision and enforcement. An important dimension is protecting the financial system against financial crime, without unnecessarily impeding legitimate activity.

COSMIC: Sharing Information with Safeguards

32. Financial crime networks may operate across multiple institutions, entities and jurisdictions. Individual financial institutions may see only part of the picture, making suspicious activity difficult to detect. Yet unrestricted sharing of customer information could undermine confidentiality and data protection. The challenge is to enable information-sharing that strengthens the detection of financial crime, while safeguarding customer confidentiality and data protection.

33. COSMIC, launched in April 2024, addresses this challenge through a statutory framework under the Financial Services and Markets Act 2022. It allows participating financial institutions to share specified customer information when specified conditions and risk thresholds are met. The framework also establishes safeguards governing access to, use and disclosure of shared information. This illustrates how a targeted legal framework can facilitate collaboration against financial crime while preserving customer confidentiality.

Beyond Rules: Effective Implementation Matters

34. Information-sharing is only part of an effective defence against financial crime. Singapore’s experience has underscored the complexity of financial crime risks and the need to continually assess whether our safeguards remain effective against evolving criminal methods. Following a major money laundering case uncovered in 2023, the Inter-Ministerial Committee on Anti-Money Laundering examined improvements across prevention, detection and enforcement. MAS' supervisory examinations of financial institutions with links to the case found that most of these institutions had established AML policies and controls in place, but failed to implement them effectively. The lesson is clear: sound regulatory requirements are necessary, but their effectiveness ultimately depends on implementation, supervision and enforcement.

Shared Responsibility for Financial Integrity

35. Safeguarding trust is therefore a shared responsibility. Regulators cannot observe every transaction or identify every risk. Financial institutions must maintain effective controls, while boards and senior management must ensure sound governance, risk management and organisational culture.

36. Professional intermediaries also play important roles. Lawyers, accountants, trustees and corporate service providers facilitate legitimate commercial and wealth management activities, but the structures and transactions they support can sometimes be misused. Singapore’s AML framework therefore imposes obligations on different categories of professional intermediaries, according to their activities and applicable sectoral requirements. These include, where relevant, identifying clients and beneficial owners, understanding the purpose of transactions, and conducting enhanced checks where risks are higher.

37. The integrity of a financial centre depends not only on the strength of its institutions, but also on the conduct of those who operate within them. Financial integrity is not separate from competitiveness. It is fundamental to sustaining it.

Family Offices: Bringing the Three Themes Together

38. The family office sector brings these themes together. Family offices can bring capital, investment expertise, business networks and long-term investment. Singapore has attracted family offices through its strengths in wealth management, international connectivity and professional services. The number of single family offices (SFOs) awarded tax incentives grew from 400 at the end of 2020 to more than 2,000 by end-2025.

39. Their distinctive characteristics call for a calibrated regulatory approach. An SFO typically manages the wealth of one family rather than funds entrusted by third-party investors. Many licensing and business conduct requirements applicable to fund managers are designed to protect third-party investors. Applying the same requirements to a SFO may therefore be neither necessary nor proportionate.

40. In June this year, MAS introduced a revised, structure-agnostic licensing exemption framework for SFOs. It provides a common class exemption for qualifying SFOs, accommodates different ownership structures and offers greater regulatory clarity and operational flexibility.

41. But SFOs are not immune to financial crime risks. The exemption therefore remains subject to safeguards, including notification to MAS, prescribed banking relationships and annual reporting. These requirements improve MAS' regulatory visibility. Banks maintaining the prescribed accounts remain responsible for conducting AML/CFT checks under MAS requirements.

42. Separately, the family office tax incentive framework seeks to encourage substantive economic contributions through requirements relating to investment professionals, local spending and capital deployment.

43. The two frameworks serve different but complementary objectives. The licensing exemption provides regulatory clarity and flexibility, subject to safeguards appropriate to the risks of family office activities. The tax incentive framework seeks to develop local capabilities and encourage economic contributions.

44. Together, they illustrate Singapore's approach to attracting international wealth, enabling legitimate financial activities and sustaining financial integrity. We should compete for capital on the strength of our institutions, not by compromising the standards that make those institutions credible.

The Next Chapter: Remaining Competitive and Trusted

45. Looking ahead, Singapore cannot assume that the conditions supporting our past success will remain unchanged. Geopolitical tensions are reshaping trade, investment and financial flows. Technological advances, particularly in artificial intelligence and digital assets, are transforming financial services. And the growing complexity of cross-border financial activities presents new challenges for risk management and supervision. These developments will test not only our competitiveness, but also the resilience of our financial system and institutions.

46. Meeting these challenges will require Singapore to strengthen its financial capabilities and maintain a sound and adaptable legal and regulatory environment. Regulatory certainty should not mean rigidity, just as adaptability should not mean unpredictability. MAS' recently issued Guidelines on Artificial Intelligence Risk Management for Financial Institutions illustrate this approach — setting clear supervisory expectations while allowing institutions to tailor controls to their AI risk profiles. We must be prepared to clarify requirements, recalibrate obligations and develop new frameworks as markets and risks evolve, while preserving the safeguards that underpin market confidence.

47. Constructive engagement with industry and the professional community will remain important. Financial institutions bring insights into evolving markets; legal practitioners and in-house counsel understand how regulatory requirements operate in practice; and academics contribute research and critical perspectives. These insights can inform sound policy judgments and help ensure that our regulatory approaches remain both principled and practical.

The Singapore Story Is Still Being Written

48. Let me conclude.

49. Singapore's success as an international financial centre was not inevitable. It was built through deliberate choices — to remain open to international capital, create an environment conducive to enterprise, and develop strong institutions that inspire trust. These choices have shaped Singapore’s development and will continue to guide us as the financial landscape evolves.

50. The Singapore Story is still being written. Our challenge is to remain open to opportunity, adaptable to change, and steadfast in the standards that sustain trust.

51. Thank you.

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