Published Date: 13 September 2022

Circular on Enhancing Anti-Money Laundering and Countering the Financing of Terrorism Controls in the VCC Sector

MAS conducted an industry-wide survey of Variable Capital Companies (VCCs) and a series of thematic engagements of eligible financial institutions (EFIs) to assess the effectiveness of their AML/CFT risk management and controls. This Circular sets out MAS’ key observations and supervisory expectations for effective AML/CFT frameworks and controls that VCCs and their appointed EFIs should note. VCCs should read this Circular in conjunction with the MAS Notice VCC-N01 [1] and Guidelines to Notice VCC-N01 [2]. 


While this Circular is premised on MAS’ observations in the VCC sector, the takeaways are applicable and relevant to other types of financial institutions (FIs), with the appropriate calibrations. FIs should note the learning points, and continue to implement appropriate AML/CFT controls that are commensurate with the nature and complexity of business.

[1] Please refer to MAS’ website at .

[2] Please refer to MAS’ website at .