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A Comparative Look at Singapore's Proposed Accountability Regime for Senior Managers and Employees in Material Risk Functions

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12 June 2018

​The MAS is proposing to require financial institutions to clearly identify and delineate the responsibilities of senior management and of employees in material risk functions. The proposed "Guidelines on Individual Accountability and Conduct" identifies five outcomes that should be met in order to ensure that senior management and employees are held accountable for their responsibilities and incentivised to ensure that they and their staff meet these expectations.

These proposed Guidelines are similar to regulatory requirements that have been implemented (or that are being implemented) in Hong Kong, the UK and Australia that are intended to increase the accountability of senior management and employees in various key posts. The regimes are not identical and the challenge for financial institutions with offices in these jurisdictions will be understanding how their management and operational structures will need to be mapped onto the different reporting regimes in these jurisdictions.

To help financial institutions navigate the different regimes, the attached update:

  • Looks at the proposed Guidelines;
  • Compares it to equivalent regimes in the UK, Hong Kong and Australia (a comparative table of the Singapore, UK, Hong Kong and Australia regimes is also included); and
  • Considers the steps that can be taken to meet the new regime (if implemented as proposed).