Disclosure Requirements – Investment Funds – Singapore


Disclosure Category 2

Clearstream Banking S.A ("CBL") may be required under the laws and regulations of Singapore to disclose, upon request, information and holdings on CBL customers and ultimate beneficial owners for holding investment funds in Singapore.


In order to comply with the local legislation, customers holding Singapore investment funds or entering into transactions in the Singapore market must consent and are hereby deemed to consent to the required legal disclosure. Such consent includes the appointment of the requestor (for example, the Fund Manager, Transfer Agent, Regulator) as their attorney-in-fact, under power of attorney, to collect from CBL the required information to be disclosed. Customers who do not grant such authority cannot hold such investment funds or financial instruments in their accounts with CBL.

Disclosure requirements

Customers are advised that under local laws and regulations, investment funds and its agents may require CBL, on request, to disclose information on CBL customers and ultimate beneficial owners. This is particularly the situation where the fund is managed and/or distributed by a financial institution regulated by the MAS in Singapore and is required to comply with local regulatory requirements. 

Background and legal basis

Disclosure of information on CBL customers and ultimate beneficial owners may arise from the following Singapore laws and regulations:

  • Notices on the Prevention of Money Laundering and Countering the Financing of Terrorism (AML/CFT Notices);
    • MAS Notice on the Prevention of Money Laundering and Countering the Financing of Terrorism – Capital Markets Intermediaries (MAS Notice SFA04-N02);
    • MAS Guidelines to MAS Notice SFA04-N02 on Prevention of Money Laundering and Countering the Financing of Terrorism;
  • Register of Registrable Controllers.


Non-compliance with the disclosure requirements may result in the fund manager or its agent refusing acceptance of the proposed investment, and/or mandatory redemption of the existing holdings.

The customer undertakes to hold CBL harmless and to indemnify CBL from any loss, claim, liability or expense asserted against or imposed upon CBL as a result of the customer failure, whatever the failure, to comply with these disclosure requests.


The information contained in the Disclosure Requirements is based on the legal opinion obtained by CBL that was issued on 2 June 2020. CBL believes the information to be correct as of that date but disclaims any responsibility as to the accuracy and completeness of the information after that date. In the case of discrepancy between the information provided by CBL and the local laws and regulations, the latter shall prevail. The Disclosure Requirements do not constitute legal advice and customers should seek advice from independent professional counsel.

Customers are responsible for ensuring compliance with the disclosure requirements and agree to indemnify and hold harmless CBL, for any loss, expense, liability, damage or claims, whether direct or indirect, against or incurred by CBL arising out of or resulting from such non-compliance.