For Corporate Service Providers (CSPs) in Singapore, an ACRA compliance review is not merely a regulatory formality. It is a structured supervisory process that evaluates whether a firm can demonstrate effective implementation of its Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Customer Due Diligence (CDD) obligations.
In practice, many regulatory findings arise not from the absence of policies, but from gaps between written procedures and actual operational practice. Understanding how ACRA conducts compliance reviews — and what it prioritises — is therefore essential for CSPs seeking to remain audit-ready and reduce regulatory risk.
How ACRA Conducts Compliance Reviews
ACRA may conduct compliance reviews using different supervisory approaches, depending on regulatory objectives, sectoral focus, and the CSP’s risk profile. In practice, reviews are commonly carried out through one of the following methods.
Review Method 1: Third-Party Audit Firm Commissioned by ACRA
Under this approach, ACRA appoints an independent audit firm to conduct the compliance review on its behalf.
Typical characteristics include:
- Advance notice is usually provided to the CSP
- On-site or hybrid reviews involving document sampling and record checks
- Interviews with directors, compliance officers, and relevant staff
- A formal review report prepared by the appointed audit firm
- Final assessment, feedback, and follow-up actions determined by ACRA
This method places strong emphasis on documentation quality, consistency of implementation, and staff awareness. CSPs are often assessed on whether they can clearly explain and evidence how compliance policies are applied in real operational scenarios.
Review Method 2: Direct ACRA Supervisory Inspection
In some cases, ACRA may conduct compliance reviews directly through its supervisory teams.
This approach may involve:
- On-site or remote inspections conducted by ACRA officers
- Requests for specific documents, case files, and records
- Interviews with key personnel responsible for compliance oversight
- Follow-up clarification requests and remediation expectations
Direct supervisory inspections often focus on the practical effectiveness of compliance controls and may involve targeted deep dives into specific risk areas or client cases.
ACRA Compliance Review Assessment Dimensions
While the scope of each review may vary, ACRA compliance reviews are generally structured around a set of core assessment dimensions. These dimensions are typically evaluated together to form an overall view of the CSP’s compliance effectiveness.
Common Review Dimensions and Relative Weighting
| Assessment Dimension | Typical Focus | Relative Weight |
|---|---|---|
| General information about CSP | Business profile, governance structure | Low |
| Risk-based approach & risk assessment | Client risk profiling, risk classification | Medium |
| Internal Policies, Procedures and Controls (IPPC) | Policy coverage, implementation, updates | High |
| Customer Due Diligence & Beneficial Ownership | CDD execution, BO identification, consistency | High |
| Suspicious Transaction Reporting | Escalation procedures, STR handling | Medium |
| Internal communication & staff training | Awareness, training records | Low |
Key observation:
IPPC and CDD-related dimensions consistently carry the highest weight and are the most common sources of regulatory findings during compliance reviews.
What ACRA Typically Examines During a Compliance Review
Beyond formal scoring dimensions, ACRA reviews place significant emphasis on how compliance frameworks operate in practice.
Typical areas of examination include:
- Whether IPPC documents reflect actual business activities and risks
- How risk-based decisions are applied during client onboarding
- Consistency of CDD and ongoing monitoring processes
- Accuracy, completeness, and retrievability of records
- Independence and effectiveness of internal compliance reviews
- Staff understanding of AML/CFT obligations
- Escalation processes and suspicious transaction handling
- Ongoing compliance monitoring and periodic updates
ACRA does not assess policies in isolation. Reviews are designed to evaluate whether CSPs can demonstrate real-world application supported by evidence.
IPPC: The Most Critical Component in Compliance Reviews
Internal Policies, Procedures and Controls (IPPC) form the backbone of a CSP’s compliance framework and represent the highest-weighted assessment area in ACRA compliance reviews.
From a supervisory perspective, IPPC is expected to:
- Reflect the CSP’s actual business model and risk exposure
- Clearly define AML/CFT, CDD, escalation, and record-keeping procedures
- Be communicated internally and understood by relevant staff
- Be applied consistently in day-to-day operations
- Be reviewed and updated on an ongoing basis
A common weakness observed during reviews is the inability to demonstrate how IPPC policies are operationalised in actual client cases.
From Compliance Obligations to Repeatable Operational Workflows
CSPs that perform well in compliance reviews typically treat compliance as a repeatable operational process, rather than a one-time documentation exercise.
Key characteristics include:
- Defined workflows from onboarding to ongoing monitoring
- Standardised documentation and record-keeping practices
- Centralised records with documented decision rationales
- Reduced reliance on ad-hoc or manual handling
Such an approach not only improves audit outcomes but also reduces long-term compliance risk.
Practical Resources for Compliance Readiness
To support CSPs at different stages of compliance maturity, AlgoCandy provides dedicated resources designed to address specific compliance needs. Each resource is explained in detail on its respective page.
AlgoCandy AML & CDD Software
A digital platform designed to help CSPs:
- Execute CDD processes in a compliant and consistent manner
- Maintain clear audit trails and evidence-linked records
- Improve operational efficiency without compromising regulatory expectations
👉 Explore AlgoCandy AML & CDD Software
IPPC Template for Singapore CSPs
A structured IPPC template designed to help CSPs:
- Establish policies aligned with ACRA compliance expectations
- Address the highest-weighted review area in compliance assessments
- Translate regulatory requirements into practical operational guidance
CSP AML & CDD Compliance Self-Assessment Tool
A self-assessment tool designed to help CSPs:
- Review current compliance posture
- Identify weaknesses before a formal review
- Improve internal alignment and awareness
👉 Start the Compliance Self-Assessment
Learn More About ACRA Compliance Reviews
Early preparation plays a critical role in reducing regulatory risk and avoiding last-minute remediation. Understanding ACRA’s review methods, assessment dimensions, and evidence expectations is a key step toward compliance readiness.
For a more detailed and structured explanation, including review workflows, scoring logic, and preparation guidance, please visit our ACRA Compliance Review Topic Page: