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Company registration in Singapore amid sanctions

Below is up-to-date information about company registration and opening a bank account in Singapore for Russian citizens. You can also read this information in our video.

Currently there are no bans on registration and operation of Russian business in Singapore, except for financing and financial operations of companies/activities subject to Singapore sanctions against Russia;

Given the difficult international situation around the Russian-Ukrainian conflict and the harsh international sanctions imposed on Russia by most countries of the world and Singapore, opening bank accounts in Singapore for companies whose shareholders/directors are Russian citizens is currently difficult and requires a significant package of supporting documents and sub-standards in Singapore.

Possible Options
Depending on your goals and capabilities, in the current situation, we would recommend you to consider 4 main scenarios for starting a business in Singapore:

If you don't care about having a bank account in Singapore:
  • Registering a company with a payment system account (no bank account)
  • Registering a Company with a bank account outside Singapore

If you need a bank account in Singapore:
  • Registering a company with a bank account in Singapore (with providing the most complete set of documents and ensuring the company's physical and economic presence requirements in Singapore)
  • Registration of fully nominal company

Comparative table of options

Company registration with an account in the payment system (without a bank account)

You can register a company with Russian directors/shareholders and apply for an account in the Singapore payment system after registration.

Advantages of
Registration of the company in Singapore with the account in the payment system provides the following advantages:
  • Fast company registration procedure
  • Fastest time of account opening
  • Fastest way to open an account without a personal flight to Singapore
  • Minimum initial deposit and monthly average balance requirements for company accounts
  • Minimum set-up and administration costs in Singapore

Disadvantages
  • Payment system account is not a 100% substitute for company bank account
  • Not ideal if you plan to relocate and grow your business in Singapore

Timeline

Company Registration: 
Company registration procedure in Singapore will take 1-3 business days from receipt of all signed documents from your side.

Account opening in the payment system:
The entire payment system account opening procedure can take 2-4 weeks. The decision to open a payment system account is at the discretion of the payment system.

IMPORTANT:
  • At the moment, the best option is the Singapore payment system Aspire, the functionality of which can replace the bank account by 80-90% and which currently has no restrictions on opening accounts for Russian citizens).
  • At the moment, the Singapore payment systems open accounts for companies with Russian participation, but in the case of deterioration of the international system and the adoption of additional sanctions, the situation may change for the worse.
  • Most Singapore payment systems have temporarily suspended the acceptance/sending of funds to/from Russia.

2. Registering a company with a bank account outside of Singapore
You can register a company with Russian directors/shareholders and after registration to apply for a bank account in the country where you plan to do business.

Advantages of
  • Fastest company registration procedure
  • Lowest company formation costs
  • Choice of the country and bank best suited for your operations

Disadvantages
  • No current account in Singapore
  • No substandards in Singapore
  • Impossibility to relocate to Singapore / relocate employees
  • Additional costs for legalization/apostille and notarization of documents

Timeline

Company Registration:
Company registration procedure in Singapore will take 1-3 business days from receipt of all signed documents on your part.

Account opening in the payment system:
The entire bank account opening procedure depends on your choice of country and bank. 

IMPORTANT:
  • Currently, banks in many countries of the world can open a bank account for a Singapore company if you provide the required set of documents. 
  • The possibility of opening an account in a particular country, the procedure, the cost, as well as the list of documents depend on the country and the bank of opening an account;
  • Costs of legalization/apostille and notarization of incorporation documents will be required.

3. Company registration with a bank account in Singapore (with the provision of a full set of documents and requirements to the company presence in Singapore)
You can register a company with Russian directors/shareholders, open a bank account, obtain a work visa and meet other requirements for physical and economic sabstance and then to apply for account opening in a Singapore bank.

Most banks in Singapore may consider opening a bank account with Russian directors/shareholders if the following conditions are met:
  • The company is not subject to the sanctions list adopted by the Singapore Ministry of Foreign Affairs
  • The company can provide the most complete list of documents on the company, confirming the seriousness of its activities
  • The company has a presence in Singapore

In order to prove the presence of the company in Singapore, two criteria must be met - physical and economic sub-standards:
  • physical sabstance is the company's actual presence in the country (having a real office, employees, director, etc.).
  • Economic substance is the actual operation of the company on the territory of the country (local expenses, contractors, generation of income, payment of taxes, etc.).

Advantages of
  • Gives high chances of opening a bank account
  • Gives high chances to get work and long-term visas in Singapore
  • Creates all the conditions and infrastructure for doing business in Singapore
  • Minimal risk of having your bank accounts closed
  • Opportunity to apply for grants and government support
  • Tax benefits

Disadvantages
  • High cost of setting up and maintaining a company
  • High cost of setting up substands in Singapore
  • Does not guarantee a bank account


How to set up a substandard foreign company:

Physical Substance:
  • A real physical office in Singapore
  • Resident Visa with company shareholder (Employment/ Entre Pass)
  • Company director with appropriate education and experience;
  • Local employees with salary and contributions to mandatory funds
  • Local website, phone line, etc.
  • Economic Substance:
  • Local counterparties (customers and suppliers)
  • Financial transactions within Singapore
  • Tax resident status in the country
  • Payment of taxes in the country
  • Procedure:
  • Company registration
  • Account opening in the payment system
  • At the present moment the best option is Singapore payment system Aspire, which can replace the bank account on 90% and where at this moment there are no restrictions on opening accounts for citizens of the Russian Federation).
  • Crediting of the authorized capital/working capital in the amount of not less than 100 000 SGD to the company account in the payment system*.
  • Employment pass for director/shareholder
  • Prepare website in English with hosting in Singapore
  • Rent/sub-rent an office/workplace
  • Prepare company business plan and business documents**
  • Find partners/clients in Singapore
  • Hire at least one employee in Singapore
  • After approval of Employment pass, apply to the bank to open bank account

** - The amount of equity/working capital required depends on the number of work visas you want to issue.
** - If there are no documents for the Singapore company, you can provide documents for the related/parent company in another country.

Timeline

Company Registration:
Company registration procedure in Singapore will take 1-3 business days from receipt of all signed documents on your part.

Bank Account Opening:
The whole procedure to set up a Substance Company in Singapore, obtain a work visa and open a bank account can take 4-6 months from the date of approval of the work visa (Employment pass). The decision to open a bank account is at the bank's discretion.

IMPORTANT:
  • We can help you with all the necessary steps and issues of setting up a sub-account in Singapore
  • At the moment Singapore banks open accounts for companies with Russian participation, but in the case of deterioration of the international system and the adoption of additional sanctions, the situation could change for the worse.
  • Many banks in Singapore have temporarily suspended the receipt/sending of funds to/from Russia.

4. Registration of a Fully Nominee Company

You can register a fully nominee company, i.e. a company where local director and shareholder are nominees and the real beneficiary of the company does not appear in the official sources and open a bank account in it.

Fully nominal company is used in cases where it is necessary to hide the data on the actual beneficiary of the company and is in great demand to solve problems with opening bank accounts for Russian citizens. Fully nominee companies have become especially popular since the beginning of the military conflict in Ukraine and the imposition of harsh sanctions against Russia in many countries of the world.

Advantages of
Registering a fully nominee company in Singapore offers the following advantages:
  • The details of the ultimate owner will be hidden in public registries
  • Full confidentiality. Information about the beneficiaries can be found only on request of the Singapore Supreme Court.
  • Highest chances of opening a bank account
  • Ability to open an account without flying to Singapore in person
  • Fastest timeframe for opening a bank account
  • Minimum initial deposit and monthly average balance requirements for company bank accounts
  • Virtually the only current option for Russian citizens to open bank accounts with top banks in Singapore
  • All legal responsibility for the company lies with the nominee director and shareholder

Disadvantages
  • Higher cost of opening and maintenance (as compared to nonnominal company)
  • Potentially higher risks for both the nominee and the beneficiary of the Company.

Timeline

Company Registration:
The Company registration procedure in Singapore will take 1-3 business days from receipt of all signed documents on your part.

Bank Account Opening:
Opening a bank account will take 2-4 weeks from receipt of all required documents on your part. Examination time depends on the chosen bank and completeness of the documents provided.

Approximate cost: ~ USD 20 000 - 30 000 per year.

IMPORTANT TO KEEP IN MIND
  • At the moment this is probably the most guaranteed way to open a bank account and to do it in the shortest possible time
  • You can replace the shareholder at any time, but we recommend to do it only after getting a work visa and creating at least a basic company presence in Singapore and starting operations
  • If you want to personally manage the company, you will need to obtain a working visa for the director/shareholder to personally manage the business after opening the company and bank account.

*-The amount of registered/working capital required depends on the number of working visas you wish to issue, but not less than SGD 100,000 per working visa.