MAS issues AML/CFT Notice VCC-N01 for variable capital companies

What changed?

MAS issued Notice VCC-N01 under section 84 of the VCC Act, effective 14 January 2020. It imposes anti-money laundering and countering-the-financing-of-terrorism obligations directly on VCCs: risk assessments, customer due diligence including beneficial ownership checks, ongoing monitoring, and suspicious transaction reporting.

Why it matters for fund managers

Every VCC must appoint an eligible financial institution (EFI) to perform these checks on its behalf — a recurring compliance cost that belongs in any realistic VCC operating budget from day one. The notice has been amended several times since; the consolidated current version is maintained on the MAS notice page.