The Monetary Authority of Singapore (MAS) issued the Guidelines on Individual Accountability and Conduct which come into effect on 10 September 2021. It is aimed at strengthening the accountability of senior mangers in key functions in financial institutions and promote ethical behaviour in the financial sector. The Individual Accountability and Conduct regime in Singapore has parallels with other accountability regimes such as the UK’s Senior Managers and Certification Regime and Hong Kong’s Manager in Charge Regime.

Let’s look at some key elements of Singapore’s Individual Accountability and Conduct regime:

Financial Institutions need to achieve 5 outcomes to promote clear accountability and proper conduct.


Some steps to be taken by Financial Institutions

  1. Conduct an assessment and identify senior managers performing core management functions and identify material risk personnel
  2. Assess fitness and propriety prior to appointment and on ongoing basis of senior managers and material risk personnel
  3. Specify and document each senior manager’s responsibilities and roles
  4. Document reporting line of senior managers within the organisation
  5. Obtain acknowledgement of each senior manager of his or her understanding of responsibilities and reporting lines
  6.  Obtain approval from board or head office of senior managers’ responsibilities and financial institutions management structure
  7. Maintain succession planning to facilitate smooth transitions
  8. Conduct training and standards of conduct for material risk personnel
  9. Institute appropriate incentive structure that is aligned with risk and motivates desired conduct.

How can Argus help?

Argus provides outsourced compliance support to asset managers as an outsourced compliance
service provider.

We can help you with the following:

  • Conduct gap analysis on your current policies and procedures against the MAS Guidelines on Individual Accountability and Conduct
  • Assist to implement processes to adopt MAS Guidelines on Individual Accountability and Conduct such as identifying senior managers and material risk personnel.
  • Assist to conduct due diligence checks to establish fitness and propriety on senior managers and material risk personnel.
  • Conduct ethics and conduct training to ensure all relevant parties are aware of their responsibilities

Please reach out to us for an initial discussion at


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