AIMA Singapore Seminar: Are You Ready for the Culture Revolution?
On 6 June 2019, the Monetary Authority of Singapore (MAS) issued its response to feedback received on its proposed Guidelines on Individual Accountability and Conduct (IAC Guidelines). MAS also issued a consultation paper on extending the application of the IAC Guidelines, including to registered fund management companies exempt from holding a CMSL, and allowing smaller financial institutions (e.g. those with a headcount of less than 20) to take a flexible approach in applying the specific guidance.
We are pleased to invite you to a lunch seminar where speakers from Herbert Smith Freehills and Millennium Capital will share their experience of implementing similar regimes in other jurisdictions and provide insights on what will be required to comply with the MAS IAC Guidelines.
Natalie Curtis, Partner, Herbert Smith Freehills
Peter Tillman, Chief Compliance Officer - Asia, Millennium Capital Management
In line with MAS' increasing focus on culture and conduct, the IAC Guidelines will require most MAS-regulated financial institutions (FIs) to achieve five conduct-related outcomes, which MAS expects will reinforce FIs responsibilities in three key areas, i.e. (i) promote individual accountability of senior managers, (ii) strengthen oversight of material risk personnel (MRP), and (iii) embed standards of proper conduct among all employees.
The generous 12 month implementation period is indicative of the amount of work that is expected to be required to achieve the five outcomes. Among other specific guidance in the IAC Guidelines, FIs will need to identify senior managers and conduct internal reviews of their roles and responsibilities, review their management structure and reporting relationships to ensure that they are clear and transparent, identify MRP, expand their fit and proper assessment framework to cover senior managers and MRP who aren't already caught (e.g. head of human resources and certain middle and back office functions etc), enhance governance policies and procedures, review incentive structures, implement a whistleblowing programme, and review training and on-boarding programmes.