MAS revokes One Heritage Capital’s CMS licence – what it means for FMCs

On 29 October 2025, the Monetary Authority of Singapore (MAS) revoked the Capital Markets Services (CMS) licence of One Heritage Capital Management (SG) Pte Ltd (OHCM) for regulatory breaches relating to reporting and financial requirements. MAS said OHCM repeatedly failed to submit quarterly regulatory returns since Q3 2024, failed to meet capital requirements, and satisfy MAS of its financial standing, despite multiple reminders. MAS underscored that licensees must adhere to ongoing obligations “at all times”.

The breaches at a glance

Late or missing MAS returns. CMS licensees must lodge quarterly returns promptly (within 14 calendar days of each quarter end). This is a basic housekeeping requirement MAS uses to monitor prudential soundness. Persistent non-compliance is a red flag and can lead to escalation.

Capital adequacy failings. OHCM also failed to meet required capital levels and to satisfy MAS of its financial standing – an essential condition for holding a CMS licence.

Immediate implications of a revocation

When a CMS licence is revoked, the firm must cease all regulated activities covered by the licence and commence an orderly wind-down. This includes client notifications, transfer/termination of mandates, and safeguarding of client assets. The MAS licensing framework makes clear that a licence is contingent on continuing compliance with fit-and-proper, financial resources, and reporting and conduct obligations. Where those are not met, revocation is on the table.

Not an isolated case: Xen Capital Asia (July 2025)

MAS has shown a willingness this year to take strong action against non-compliant CMS licensees. In July, MAS revoked the CMS licence of Xen Capital Asia Pte Ltd (XCAPL) and reprimanded its Executive Director and former CEO. Publicly available summaries show breaches included, repeated failures to submit financial returns, failure to notify MAS of changes in key personnel, and not meeting the minimum requirement of at least two full-time appointed representatives, among others.

A wider enforcement backdrop

The One Heritage and Xen Capital actions sit against a broader backdrop of stepped-up supervision. In July 2025, MAS announced S$27.45 million in composition penalties against nine financial institutions over control gaps linked to Singapore’s 2023 money-laundering case – highlighting deficiencies in customer risk assessment, source-of-wealth corroboration, and monitoring. The clear signal: supervisory tolerance for basic control failures is low.

What CMS licensees should do now

1. Tighten regulatory “hygiene” and evidencing

• Submit MAS returns on time: File quarterly/other returns within the prescribed deadline; diarise statutory deadlines and embed maker-checker sign-offs. Late lodgements compound supervisory concern.

• Capital monitoring: Run a forward-looking capital buffer (policy thresholds above the regulatory minimum), with breach triggers that escalate to senior management and the board.

2. Continuously satisfy your licence conditions

• People & notifications: Ensure you maintain minimum staffing/ representative requirements and promptly notify MAS of key changes (place of business, directors, and control persons). XCAPL’s case shows these are active enforcement touchpoints.

3. Treat MAS reminders as escalation events

• If MAS sends reminders, treat them like an internal audit issue with the owner, due date, and board visibility. Repeated non-response is itself a supervisory concern, as highlighted in the OHCM revocation note.

4. Pre-emptive governance

• Regulatory calendar: Maintain a central compliance calendar (returns, attestations, and audits) with key risk indicators (e.g., return timeliness % and capital headroom days). 

• Board oversight: Table a quarterly “Regulatory Compliance Dashboard” to the board/senior management – showing filings status, capital metrics, staffing/ representative counts, and pending MAS correspondence.

Bottom line

For Singapore fund managers and other CMS licensees, basic supervisory expectations are rising. Timely returns, robust capital buffers, and disciplined notifications are not box-ticking – they are licence-preserving controls. The One Heritage and Xen Capital cases are a reminder that administrative lapses, left unremediated, can become existential.

How Ocorian can help

We regularly support firms in the following areas:

• Reviewing client communications for regulatory alignment.
• Assessing marketing materials for compliance with applicable requirements.
• Advising on the interpretation and application of marketing regulations.
• Reviewing and enhancing relevant policies and procedures.

If you’re looking to be licensed, need to change your license, or seek permission for a new controlling shareholder, we can help.