Penalties Under the Corporate Service Providers Act 2024 (Singapore)
A standalone reference to the enforcement landscape under the CSP Act 2024 — operating unregistered, AML/CFT breaches, and personal accountability for senior management and RQIs.
What is the penalty landscape under the CSP Act 2024?
The Corporate Service Providers Act 2024 (the “CSP Act”) came into force on 9 June 2025 and is enforced by the Accounting and Corporate Regulatory Authority (ACRA). It replaces the older filing-agent regime with a registration-and-supervision framework, and it backs that framework with real penalties.
The enforcement landscape has three broad fault lines: operating without registering as a CSP; breaching the AML/CFT/PF duties once registered; and failures around nominee directors and personal accountability of the people who run and supervise the CSP. This page consolidates each into one reference. For the full obligations, see the pillar guide on what corporate service providers must do.
What is the penalty for operating as an unregistered CSP?
From commencement, you must not provide corporate services by way of business in or from Singapore unless you are registered with ACRA as a CSP. Providing those services without registering is an offence.
Law-firm briefings on the Act widely report the penalty for providing corporate services without registration as a fine of up to S$50,000, imprisonment of up to 2 years, or both, with further daily fines for a continuing offence. Treat these as indicative and confirm the exact figures against the CSP Act as enacted and current ACRA guidance before relying on them.
What are the penalties for AML/CFT breaches?
The core of the CSP Act is the AML/CFT/PF regime: customer due diligence, enhanced due diligence for higher-risk clients, sanctions and watchlist screening, a documented risk assessment, record-keeping for at least five years, and suspicious transaction reports. Failing these duties is where the heaviest exposure sits.
Breaching the AML/CFT/PF obligations can attract a fine of up to S$100,000 per breach. Because these are counted per breach, exposure across many client files can compound quickly. Confirm the applicable figure and how breaches are counted against the Act and ACRA guidance.
| Breach | Reported exposure | Note |
|---|---|---|
| Providing corporate services without registering as a CSP | Fine up to S$50,000, imprisonment up to 2 years, or both (plus daily fines for continuing offences) | Widely reported by law-firm briefings — confirm against the Act as enacted. |
| Breaching AML/CFT/PF obligations (CDD, screening, records, STRs) | Fine up to S$100,000 per breach | Senior management may be personally liable. |
| Failing to ensure a nominee director is fit and proper | Fine up to S$100,000 | Applies to the CSP arranging the nominee. |
| Acting as a nominee director by way of business outside a registered CSP | Fine commonly cited up to S$10,000 | Confirm against the Act as enacted. |
How are senior management and RQIs held accountable?
A defining feature of the CSP Act is personal accountability. The obligations do not stop at the corporate entity: where the CSP breaches its AML/CFT/PF duties, senior management can be held personally liable. This is deliberate — it pushes compliance ownership up to the people who actually run the business, rather than letting it be absorbed by the company alone.
Every registered CSP must also have at least one Registered Qualified Individual (RQI) — a person who holds the relevant qualifications, has completed mandatory AML/CFT/PF training, and provides or supervises the CSP’s corporate services. The RQI is the accountable human behind the CSP’s compliance, so RQI-level failures feed directly into the CSP’s exposure. See the explainer on what a Registered Qualified Individual is.
What about nominee-director failures?
The Act tightens the rules around nominee directors on two sides. A CSP must not arrange for anyone to act as a nominee director unless it is satisfied the person is fit and proper; failing that duty can attract a fine of up to S$100,000. Separately, a person who acts as a nominee director by way of business without being arranged by a registered CSP commits an offence, with a fine commonly cited up to S$10,000 — confirm against the Act as enacted.
For the detailed duties around arranging and disclosing nominee directors, see nominee director requirements under the CSP Act 2024.
How should a CSP reduce its penalty exposure?
The penalties are per-breach and reach the people in charge, so the sensible posture is systematic compliance rather than best-efforts. Confirm your ACRA registration, designate an RQI, put a written AML/CFT programme in place, and run CDD/EDD and screening on every client with records kept for at least five years.
Because several headline figures above are drawn from professional commentary rather than quoted verbatim here, verify the specific fines, imprisonment terms and daily-penalty provisions against the CSP Act 2024 as enacted and current ACRA guidance — and take your own legal advice on any live enforcement question. CorpSec AI operationalises each duty so the AI does the work and you confirm.
Frequently asked questions
What is the maximum penalty under the CSP Act 2024?
Breaching the AML/CFT/PF obligations, or failing to ensure a nominee director is fit and proper, can each attract a fine of up to S$100,000 — and for AML/CFT breaches, senior management may be personally liable.
What happens if I provide corporate services without registering?
It is an offence. Law-firm briefings widely report a fine of up to S$50,000, imprisonment of up to 2 years, or both, with daily fines for continuing offences. Confirm the exact figures against the Act as enacted.
Can senior management be personally liable?
Yes. Where a CSP breaches its AML/CFT/PF duties, senior management can be held personally liable — the Act pushes accountability up to the people running the business.
Is acting as a nominee director now an offence?
Acting as a nominee director by way of business without being arranged by a registered CSP is an offence, with a fine commonly cited up to S$10,000. Confirm against the Act as enacted.
Sources
This article is general information for Singapore corporate service providers, not legal or professional advice. Verify against the primary sources above and your own professional judgement.