On 30 December 2025, the Monetary Authority of Singapore (“MAS“) issued revised Notices on market misconduct reporting requirements. The Notices will come into effect on 1 January 2027. Financial institutions (“FIs“) are required under the Financial Advisers Act 2001 (“FAA“), the Insurance Act 1966 (“IA“), and the Securities and Futures Act 2001 (“SFA“) to lodge a report with MAS when they become aware of misconduct committed by their representatives (including former representatives) or broking staff[1] (collectively, “representatives“).
On 19 April 2022, MAS issued a Consultation Paper to seek feedback on the proposed legislative amendments to the revised misconduct reporting requirements for representatives under the FAA, the IA and the SFA. MAS issued its Response to the Consultation Paper on 30 December 2025, which is available here. For more information, please refer to our May 2022 Legal Update titled “MAS Consults on Revised Notices on Misconduct Reporting Requirements under Financial Advisers Act, Insurance Act, Securities and Futures Act“.
Key Features of the Misconduct Reporting Requirements
- Revision of categories of reportable misconduct in the FAA Notice, IA Notice and SFA Notice
- The updated category of conduct falling within misconduct that is reportable includes offences involving illegal monetary gains, bribery, money laundering, and tax evasion.
- For cases involving illegal monetary gain from a representative’s misconduct, the FI must determine whether the act is reportable misconduct, regardless of who ultimately receives the funds.
- MAS has provided guiding principles, factors, and examples to help FIs interpret the Notices, guiding FIs in assessing whether an act is a reportable misconduct in the 2021 Response to Feedback Received on Revisions to Misconduct Reporting Requirements and Proposals to Mandate Reference Check. MAS will incorporate this guidance in a FAQs document to be issued to provide clarity on these topics.
- Revision of reporting timelines of the misconduct report and subsequent updates to the misconduct report (“Update Report”)
- An FI must submit the misconduct report no later than 21 calendar days (or such longer period as MAS may allow) after the date on which the FI first has reasonable grounds to believe that its representative had committed any misconduct or its former representative had committed any misconduct during the period when he or she was a representative of the FI.
- If any significant development occurs after the misconduct report is submitted, the FI must submit an Update Report to MAS no later than 21 calendar days after the development (or such longer period as MAS may allow).
- Other submissions accompanying the misconduct report
- The FI must also provide related documents, including any internal investigation report and a police report if available, as required by the Revised MAS Notices. For each alleged misconduct, the FI must determine if a police report is necessary and, if not filed, explain the reasons for not lodging a police report.
- Provision of misconduct report (and Update Report) by FIs to representatives
- These reports must be provided to the representatives within 21 calendar days (or longer if allowed by MAS), although this is subject to certain exceptions including if providing the report would prejudice an investigation or proposed investigation against the representative.
- Scope of application of MAS 508 Notice will be extended to include accident and health (“A&H”) insurance intermediaries
- An A&H insurance intermediary means direct insurers, licensed or exempt financial advisers, in the business of long-term A&H insurance intermediary activities. These activities mainly involve arranging such policies. All FIs must report misconduct by representatives advising on long-term A&H products, regardless of the type of FI the representative is appointed with.
Click on the following links for more information (available on the MAS website at www.mas.gov.sg):
- FAA-N27 Notice on Reporting of Misconduct of Representatives by Financial Advisers
- MAS 508 Notice on Reporting of Misconduct of Broking Staff by Insurance Brokers and of Representatives by Accident and Health Insurance Intermediaries
- SFA 04-N24 Notice on Reporting of Misconduct of Representatives by Holders of Capital Markets Services Licence and Exempt Persons
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[1] “broking staff”, in relation to an IB, means a person who acts for, or by arrangement with, the IB in the performance of all or any of the insurance broking activities carried out by the IB. “IB” means a registered insurance broker or a person who is carrying on business as an insurance broker and exempted from registration under the IA.
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