Non U.S. Citizen

We have come across our first prospect that is a resident of the US (work visa for 20+ years), but a Singapore citizen. This prospect does own property and have bank accounts in Singapore.

The question I have is:

- Can this individual become an RIA client?

- If yes, what needs to be done?

Thank you,

Stephanie Kelm, IACCP (r)
Senior Client Services Associate
[NorthLanding logo color]
Direct - (585) 497-5006
Main - (585) 497-5000
Fax - (585) 497-5001

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Investment advisory services offered through NorthLanding Financial Partners, LLC, an SEC Registered Investment Adviser. Clearing, custody and brokerage services provided to clients of NorthLanding Financial Partners, LLC are offered by Fidelity Brokerage Services, LLC, Member NYSE/SIPC. Securities may also be offered through Mutual Securities, Inc., Member FINRA/SIPC. Supervisory office located at 807-A Camarillo Springs Road, Camarillo, CA 93012. NorthLanding Financial Partners, LLC is not affiliated with Mutual Securities, Inc.


  • Yes, there is no prohibition allowing them to become a SEC RIA client. (This is done all the time with onshore/offshore private funds). You would need to do more extensive AML due diligence including ensuring that they are not a Politically Exposed Person (PEP) or has any negative information from their home jurisdiction of Singapore. Additionally, be aware of the tax implications of their investments, in certain cases Non Resident Alien type products may be considered. Please call me with any questions.

    Myles Edwards, Esq.
    General Counsel & Chief Compliance Officer
    Shufro, Rose & Co., LLC
    745 Fifth Avenue, 26th Floor
    New York, NY 10151-2600
    Direct (646) 517-1184
    Mobile (973) 650-4385
    Facsimile: (212) 754-5111
  • edited May 2017
    Your custodian may be able to provide additional guidance.
    Here's an OFAC link that may be helpful, too.

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