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Individual Accountability and Conduct

Two (2) public consultation papers on proposed Guidelines on Individual Accountability & Conduct (“IAC”) were issued on 26 April 2018 and 6 June 2019 by the Monetary Authority of Singapore (“MAS”). Feedback was sought on the application scope of IAC Guidelines and the affected Financial Institutions (“FIs”).


Rules and regulations are often insufficient to influence behaviors, MAS is of the view that FIs need to promulgate standards of proper conduct to influence the day-to-day operations and strategic decisions of the FIs.

MAS’ 3-Pronged-Approach

MAS’ proposed Guidelines on IAC, reinforced the responsibilities of FIs in 3 areas:

  • Promote individual accountability on senior managers (SM)
  • Strengthen the oversight of employees in material risk functions (MRFs)
  • Embedding standards of proper conduct among all employees

5 Accountability and Conduct IAC aims to achieve



  • MAS has proposed for IAC guidelines to apply to all FIs except entities whose scope of activities conducted is limited, are subject to minimal business conduct and financial requirements or, have minimal presence in Singapore, or are primarily regulated by a foreign regulator.
  • MAS has also proposed that the IAC Guidelines should not apply to firms with a headcount of less than 20, rationale being management oversight and control is more concentrated in the directors and the chief executive in such firms, leading to simpler decision-making structures, making accountability clearer.

What you need to do

  • FIs need to start working with Core Management Functions to identify and articulate key roles and responsibility.
  • Communicate with Senior Managers their responsibility and reporting lines.
  • Senior Management should identify and have clear oversight over Material Outsourced Vendors.

RHT Compliance Solutions

RHT Compliance Solutions is able to assist and provide an independent review of FIs’ organisational structure.
RHT Compliance Solutions is a premier Compliance Service Advisory firm based in Singapore.
Our team comprises experienced and certified professionals with extensive regulatory, compliance and risk management experience from Singapore, Indonesia, Hong Kong and the broader region. The team is well equipped to provide clients with intelligent, risk-focused and cost-effective solutions.

For further information, contact:

Jarvis Lee
Compliance Analyst

RHT Compliance Solutions Pte Ltd
1 Paya Lebar Link #06-08
PLQ 2 Paya Lebar Quarter
Singapore 408533

Reach out to us for more information.

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