Our regulatory and compliance framework is designed to align with the expectations of the Monetary Authority of Singapore (MAS) and applicable regulations governing Registered Fund Management Companies (RFMCs).
Compliance is embedded into our governance structure, investment operations, and internal controls to ensure responsible management of capital and sustained regulatory readiness.
1. Regulatory Status & Scope of Activities
Million Leaf conducts its investment activities in accordance with applicable regulatory requirements under Singapore law.
- Investment activities are limited to permitted scopes consistent with RFMC regulatory frameworks
- The firm does not engage in activities outside its approved investment mandate
- Capital is managed within defined strategy boundaries and risk parameters
All business activities are conducted with due regard to regulatory obligations and investor protection principles.
2. Compliance Philosophy
Million Leaf adopts a proactive and principles-based compliance approach, recognising that regulatory compliance is a foundational element of trust and long-term sustainability.
Key compliance principles include:
- Compliance is a firm-wide responsibility
- Policies and procedures take precedence over individual discretion
- Documentation, auditability, and traceability are maintained at all times
- Regulatory obligations are treated as minimum standards, not aspirational targets
Compliance considerations are incorporated into decision-making at every operational level.
3. Governance & Oversight
Regulatory oversight is embedded within the firm’s governance framework.
- Senior management bears ultimate responsibility for regulatory compliance
- Investment and risk activities are conducted within approved governance structures
- Policies are reviewed periodically to reflect regulatory developments and best practices
Clear accountability lines are maintained to ensure effective supervision and escalation.
4. Policies & Internal Controls
Million Leaf maintains documented policies and procedures covering, but not limited to:
- Investment governance and mandate controls
- Risk management and exposure limits
- Conflict of interest identification and management
- Trade execution, allocation, and monitoring
- Record-keeping and data integrity
Internal controls are designed to be proportionate, enforceable, and consistent with the firm’s operating scale.
5. Conflict of Interest Management
The firm maintains a structured approach to identifying, mitigating, and disclosing conflicts of interest.
- Personal and proprietary interests are managed through defined policies
- Investment decisions are made in the best interests of the managed capital
- Potential conflicts are reviewed, documented, and addressed through governance procedures
Conflicts are not eliminated by assumption, but managed through transparency and control.
6. Record Keeping & Transparency
In line with regulatory expectations, Million Leaf maintains:
- Accurate and complete records of investment decisions and transactions
- Documented rationale for material investment actions
- Audit-ready documentation supporting compliance and risk oversight
Records are retained securely and made available for regulatory review when required.
7. Regulatory Engagement & Readiness
Million Leaf maintains an ongoing state of regulatory readiness.
- Regulatory requirements are monitored for updates and changes
- Internal policies are adjusted to remain aligned with evolving standards
- The firm is prepared to engage constructively with regulators and professional advisors
Regulatory engagement is approached with transparency, cooperation, and professionalism.
8. Ethical Standards & Fiduciary Duty
All activities are conducted in accordance with high ethical standards.
- Fiduciary duty to managed capital is paramount
- Market conduct principles are strictly observed
- The firm avoids practices that could compromise integrity or trust
Ethical conduct is enforced through governance, culture, and accountability.
9. Continuous Improvement
Regulatory and compliance practices are reviewed on an ongoing basis.
- Periodic internal assessments are conducted
- Control effectiveness is evaluated and enhanced where necessary
- Lessons learned from market developments and regulatory guidance are incorporated
Compliance is treated as a dynamic discipline that evolves with the firm and regulatory environment.
Million Leaf 