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MAS Circular IID 04/2025 sets supervisory expectations for VCC managers
By VCCGuide Editorial
Reviewed by the fund management team at JCube Capital Partners (JCP), a Monetary Authority of Singapore capital markets services licence holder (Licence No. CMS100895).
What changed?
Following its 2024 thematic review, MAS issued Circular IID 04/2025 on 26 June 2025, setting out supervisory expectations for VCC managers: independent custody of assets (with an exception for private equity and venture capital strategies offered to accredited or institutional investors), licensing of VCC directors who conduct regulated activities, winding down dormant VCCs holding no assets or investors, demonstrating substantive fund management rather than conduit structures, and robust AML/CFT oversight of appointed eligible financial institutions. The circular noted approximately 1,200 VCCs as of 31 March 2025, managed by about 600 financial institutions.
Why it matters for fund managers
This is the current supervisory baseline for running a VCC. MAS states the expectations apply to other fund structures where relevant, and it has since acted on them — in 2025, managers of 25 asset-less VCCs were directed to de-register them. Any VCC governance review should start from this circular.