BACKGROUND
On 16 April 2025, the Monetary Authority of Singapore (MAS) released its 5th Enforcement Report, covering enforcement activities from 1 July 2023 to 31 December 2024. The report underscores MAS’s commitment to maintaining the integrity of Singapore’s financial sector through robust enforcement actions, and also indicates an evolution in intended enforcement outcomes.
1. Main Enforcement Themes
- AML/CFT Failures Remain a Core Concern
MAS imposed penalties on FIs with lapses in suspicious transaction reporting, inadequate KYC, and poor AML/CFT governance. These cases reinforce the expectation that AML compliance is a board-level responsibility. - Individual Accountability Takes Centre Stage
MAS issued prohibition orders against individuals involved in fraud, misrepresentation, and insider trading. The message is clear: misconduct will follow the person, not just the firm. - Misconduct in the Capital Markets
MAS ramped up enforcement against insider trading and disclosure breaches. Joint actions with CAD led to criminal convictions, reinforcing MAS’s zero-tolerance stance on market abuse. - Holding Senior Management to Account
MAS held board members and key executives responsible for control failures in several cases, signalling a shift toward upstream accountability. - Enhanced Transparency and Public Disclosure
MAS increased the visibility of enforcement outcomes, including naming sanctioned individuals and publishing anonymised case studies for public learning.
2. Overview vs last year
There was an overall decrease in enforcement statistics, indicating the effectiveness of on-going regulatory oversight.
Category | 2023/2024 | 2022/22023 |
Prohibition Orders | 24 | 18 |
Criminal Convictions | 20 | 39 |
Total Civil Penalties | S$3.8 million | S$12.96 million |
Financial Penalties and Compositions | S$3.2 million | S$7.88 million |
Other Actions | 156 | 455 |
3. Evolving from Reactive to Strategic
- Increasing use of Prohibition Orders and financial penalties to deter future breaches
- Adoption of cross-border enforcement collaboration, enhancing speed and scope of investigations
- Enhanced public disclosures to promote industry-wide learning and reputational consequences
- MAS focuses not only on actual harm but also on potential risk and deterrence value
WHAT’S NEXT?
Financial Institutions should:
- Review MAS enforcement case studies and map against internal gaps
- Strengthen compliance monitoring and board-level oversight
- Enhance AML/CFT detection systems and STR escalation procedures
- Monitor high-risk staff and enforce clear consequence management policies
- Embed conduct and ethical awareness in performance evaluation frameworks
MAS has made its stance clear yet again: maintaining trust in Singapore’s financial system requires that rules, action, and institutions step up, and the regulator will continue to surveil, inspect and enforce regulatory compliance across all financial institutions big or small.
HOW CAN WE HELP?
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