Banking Sector Offences - Test V1

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Offences, Misconduct, Regulatory Breaches & Punishments

Banks, Merchant Banks, Digital Banks, Branches, Banking Groups, Officers, Representatives, Vendors and Banking Operations

Publication notes: This master table is prepared as a training, compliance and investigation reference. The final legislation, section numbers and punishments must be verified against the current Singapore Statutes Online, MAS legislation, MAS notices, directions, guidelines, licensing conditions, regulatory enforcement materials and relevant agency guidance before publication or operational use.

Source basis used: User-supplied BCA master table format; MAS and Singapore Statutes Online materials relating to Banking Act 1970, Monetary Authority of Singapore Act 1970, Financial Services and Markets Act 2022, Payment Services Act 2019, Securities and Futures Act 2001, Financial Advisers Act 2001, Trust Companies Act 2005, MAS Notice 626 AML/CFT framework, CDSA 1992, Terrorism (Suppression of Financing) Act 2002, United Nations Act 2001 sanctions framework, Penal Code 1871, Prevention of Corruption Act 1960, Computer Misuse Act 1993, Personal Data Protection Act 2012, Companies Act 1967, Workplace Safety and Health Act 2006 and Fire Safety Act 1993.

Offence Classification Legend

Part A: Theft, Criminal Breach of Trust, Cheating, Fraud and Deception Offences — Number of Offences: 40

Part B: Forgery, False Records, Documentation and Evidence Offences — Number of Offences: 30

Part C: Banking Act, MAS Licensing, Prudential and Regulatory Compliance Breaches — Number of Offences: 40

Part D: AML/CFT, Sanctions and Financial Crime Compliance Breaches — Number of Offences: 40

Part E: Cyber, Technology, Digital Banking, Payment Systems and Data Protection Offences — Number of Offences: 40

Part F: Securities, Financial Advisory, Investment, Market Conduct and Customer Mis-Selling Offences — Number of Offences: 40

Part G: Corruption, Ethics, Governance, Audit, Operational Risk, WSH and Public Protection Breaches — Number of Offences: 30

Offences / Misconducts / Breach

Part A: THEFT, CRIMINAL BREACH OF TRUST, CHEATING, FRAUD AND DECEPTION OFFENCES — Number of Offences: 40

Offence / Misconduct / Breach	Legislation / Section	What the Section Is For	When It Applies in the Organisation	Punishment in Law
Theft of bank cash or teller float	Penal Code 1871, ss378-379	Defines theft as dishonestly taking movable property without consent.	Applies where bank cash, devices, documents, valuables or customer/bank property are dishonestly taken.	Imprisonment up to 3 years, fine, or both.
Theft of customer cash or valuables	Penal Code 1871, ss378-379	Defines theft as dishonestly taking movable property without consent.	Applies where bank cash, devices, documents, valuables or customer/bank property are dishonestly taken.	Imprisonment up to 3 years, fine, or both.
Theft of bank cards, tokens or cheque books	Penal Code 1871, ss378-379	Defines theft as dishonestly taking movable property without consent.	Applies where bank cash, devices, documents, valuables or customer/bank property are dishonestly taken.	Imprisonment up to 3 years, fine, or both.
Theft of bank devices, laptops or security equipment	Penal Code 1871, ss378-379	Defines theft as dishonestly taking movable property without consent.	Applies where bank cash, devices, documents, valuables or customer/bank property are dishonestly taken.	Imprisonment up to 3 years, fine, or both.
Theft of negotiable instruments or securities certificates	Penal Code 1871, ss378-379	Defines theft as dishonestly taking movable property without consent.	Applies where bank cash, devices, documents, valuables or customer/bank property are dishonestly taken.	Imprisonment up to 3 years, fine, or both.
Theft by bank employee, clerk or servant	Penal Code 1871, s381	Aggravates theft committed by an employee of property in employer possession.	Applies where bank staff, branch staff, operations staff, contractors or secondees steal property held through banking work.	Imprisonment up to 7 years and liable to fine.
Dishonest misappropriation of branch collections or cash deposits	Penal Code 1871, s403	Covers dishonest conversion of property to personal use.	Applies where funds, cards, documents, recovered property or customer assets are dishonestly retained or diverted.	Imprisonment up to 2 years, fine, or both.
Dishonest misappropriation of unclaimed or recovered customer property	Penal Code 1871, s403	Covers dishonest conversion of property to personal use.	Applies where funds, cards, documents, recovered property or customer assets are dishonestly retained or diverted.	Imprisonment up to 2 years, fine, or both.
Criminal breach of trust by bank staff	Penal Code 1871, ss405-406	Covers dishonest misappropriation or conversion of property entrusted to a person.	Applies where staff, agents or service providers misuse funds, securities, devices, access tokens, documents or customer property entrusted to them.	Imprisonment up to 7 years, fine, or both.
Criminal breach of trust by employee in banking operations	Penal Code 1871, s408	Enhance punishment for criminal breach of trust by a clerk, servant or employee.	Applies where a bank employee misappropriates entrusted funds, securities, payment instruments, records or customer property.	Imprisonment up to 15 years and liable to fine.
Criminal breach of trust by banker or relationship manager	Penal Code 1871, s409	Aggravates criminal breach of trust by banker, agent or person in a high-trust capacity.	Applies where banker, relationship manager, operations officer or entrusted agent dishonestly misuses customer or bank assets.	Imprisonment up to 20 years and liable to fine.
Misuse of customer deposits or entrusted funds	Penal Code 1871, s409	Aggravates criminal breach of trust by banker, agent or person in a high-trust capacity.	Applies where banker, relationship manager, operations officer or entrusted agent dishonestly misuses customer or bank assets.	Imprisonment up to 20 years and liable to fine.
Misuse of client securities or custody assets	Penal Code 1871, s409	Aggravates criminal breach of trust by banker, agent or person in a high-trust capacity.	Applies where banker, relationship manager, operations officer or entrusted agent dishonestly misuses customer or bank assets.	Imprisonment up to 20 years and liable to fine.
Misuse of safe deposit box contents	Penal Code 1871, s409	Aggravates criminal breach of trust by banker, agent or person in a high-trust capacity.	Applies where banker, relationship manager, operations officer or entrusted agent dishonestly misuses customer or bank assets.	Imprisonment up to 20 years and liable to fine.
Misuse of escrow, trust or settlement monies	Penal Code 1871, s409	Aggravates criminal breach of trust by banker, agent or person in a high-trust capacity.	Applies where banker, relationship manager, operations officer or entrusted agent dishonestly misuses customer or bank assets.	Imprisonment up to 20 years and liable to fine.
Receiving stolen bank or customer property	Penal Code 1871, ss410-411	Covers receiving or retaining property known or believed to be stolen.	Applies where stolen cards, devices, documents, cash, cheques, tokens or securities are knowingly received or retained.	Imprisonment up to 5 years, fine, or both.
Assisting disposal of stolen cards, cheques or bank property	Penal Code 1871, s414	Covers assisting concealment or disposal of stolen or dishonestly obtained property.	Applies where a person helps conceal stolen bank assets, customer property, fraud proceeds or compromised payment instruments.	Imprisonment up to 5 years, fine, or both.
Cheating a customer or bank counterparty	Penal Code 1871, ss415, 417	Covers deception inducing a person to deliver property, consent, act or omit to act causing harm.	Apply to deception of customers, bank officers, counterparties, guarantors, regulators, vendors or the public.	Imprisonment up to 3 years, fine, or both.
Cheating to obtain loan, credit card, overdraft or facility	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Cheating to obtain bank account, payment service or guarantee	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Cheating by personation as customer or authorised signatory	Penal Code 1871, ss416, 419	Covers cheating by pretending to be another person or by personation.	Applies where a person impersonates a customer, banker, authorised signatory, regulator, vendor, cardholder or beneficial owner.	Imprisonment up to 5 years, fine, or both.
Impersonating bank officer or MAS officer	Penal Code 1871, ss416, 419	Covers cheating by pretending to be another person or by personation.	Applies where a person impersonates a customer, banker, authorised signatory, regulator, vendor, cardholder or beneficial owner.	Imprisonment up to 5 years, fine, or both.
Loan application fraud	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Mortgage or property-finance fraud	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Trade-finance fraud involving invoices, bills or letters of credit	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Credit card application or usage fraud	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Debit card, ATM or payment-card fraud	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Internet banking scam or payment instruction fraud	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Business email compromise affecting bank payments	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Fraud by false representation to bank	Penal Code 1871, s424A	Covers fraud by false representation, non-disclosure or abuse of position.	Applies where banking position, information, system access or customer trust is abused for dishonest gain or to cause loss.	Imprisonment up to 20 years, fine, or both.
Fraud by failing to disclose material banking information	Penal Code 1871, s424A	Covers fraud by false representation, non-disclosure or abuse of position.	Applies where banking position, information, system access or customer trust is abused for dishonest gain or to cause loss.	Imprisonment up to 20 years, fine, or both.
Fraud by abuse of banking position	Penal Code 1871, s424A	Covers fraud by false representation, non-disclosure or abuse of position.	Applies where banking position, information, system access or customer trust is abused for dishonest gain or to cause loss.	Imprisonment up to 20 years, fine, or both.
False collateral, guarantee or security representation	Penal Code 1871, s424A	Covers fraud by false representation, non-disclosure or abuse of position.	Applies where banking position, information, system access or customer trust is abused for dishonest gain or to cause loss.	Imprisonment up to 20 years, fine, or both.
False invoice or inflated billing to bank	Penal Code 1871, s424A	Covers fraud by false representation, non-disclosure or abuse of position.	Applies where banking position, information, system access or customer trust is abused for dishonest gain or to cause loss.	Imprisonment up to 20 years, fine, or both.
Ghost vendor, ghost service or ghost employee scheme	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Unauthorised refund, fee waiver or reversal	Penal Code 1871, ss405-406	Covers dishonest misappropriation or conversion of property entrusted to a person.	Applies where staff, agents or service providers misuse funds, securities, devices, access tokens, documents or customer property entrusted to them.	Imprisonment up to 7 years, fine, or both.
Unauthorised transfer or withdrawal from bank account	Penal Code 1871, s420	Covers cheating that dishonestly induces delivery of property or alteration/destruction of valuable security.	Applies to fraudulent loan, account, card, investment, trade-finance, guarantee, insurance or payment claims.	Imprisonment up to 10 years and liable to fine.
Mischief causing damage to ATM, branch or bank equipment	Penal Code 1871, ss425-427	Covers wrongful loss or damage to property, including disruption of services or public agency functions.	Applies to damaging bank property, ATMs, network equipment, branch premises, records, safes or payment infrastructure.	Punishment depends on section and damage; may include imprisonment, fine, or both.
Criminal trespass into branch, cash room, vault or data centre	Penal Code 1871, ss441, 447-448	Covers criminal trespass and house-breaking into buildings or secured places.	Applies to unauthorised access to branches, cash rooms, data centres, vaults, operations floors or restricted premises.	Punishment depends on section; criminal trespass may carry imprisonment, fine, or both.
Abetment, conspiracy or attempt in banking theft, CBT or fraud	Penal Code 1871, ss107-109, 120A-120B and relevant principal offence	Covers abetment, conspiracy and attempts involving underlying offences.	Applies where staff, customers, vendors, mule account holders or outsiders coordinate or attempt banking-related dishonesty.	Generally punished according to the principal offence, subject to applicable provisions.

Part B: FORGERY, FALSE RECORDS, DOCUMENTATION AND EVIDENCE OFFENCES — Number of Offences: 30

Offence / Misconduct / Breach	Legislation / Section	What the Section Is For	When It Applies in the Organisation	Punishment in Law
Making a false banking document or electronic record	Penal Code 1871, ss463-465	Defines forgery and making false documents or electronic records.	Applies to false forms, signatures, instructions, statements, confirmations, facility documents, guarantees or digital records.	Imprisonment up to 4 years, fine, or both.
Forgery for purpose of cheating a bank or customer	Penal Code 1871, s468	Covers forgery committed for the purpose of cheating.	Applies where forged banking documents are used to obtain accounts, credit, payments, transfers, securities or regulatory advantage.	Imprisonment up to 10 years and liable to fine.
Using forged banking document as genuine	Penal Code 1871, s471	Covers fraudulent or dishonest use of a forged document or electronic record as genuine.	Applies where forged forms, cheques, trade documents, statements or identity documents are submitted to a bank.	Punished as if the person had forged the document or record.
Forgery of customer signature or mandate	Penal Code 1871, ss463-465	Defines forgery and making false documents or electronic records.	Applies to false forms, signatures, instructions, statements, confirmations, facility documents, guarantees or digital records.	Imprisonment up to 4 years, fine, or both.
Forgery of cheque, cashier’s order or bank draft	Penal Code 1871, s468	Covers forgery committed for the purpose of cheating.	Applies where forged banking documents are used to obtain accounts, credit, payments, transfers, securities or regulatory advantage.	Imprisonment up to 10 years and liable to fine.
Forgery of letter of credit or trade-finance document	Penal Code 1871, s468	Covers forgery committed for the purpose of cheating.	Applies where forged banking documents are used to obtain accounts, credit, payments, transfers, securities or regulatory advantage.	Imprisonment up to 10 years and liable to fine.
Forgery of bank guarantee or standby credit	Penal Code 1871, s468	Covers forgery committed for the purpose of cheating.	Applies where forged banking documents are used to obtain accounts, credit, payments, transfers, securities or regulatory advantage.	Imprisonment up to 10 years and liable to fine.
Forgery of account opening or KYC document	Penal Code 1871, ss463-465	Defines forgery and making false documents or electronic records.	Applies to false forms, signatures, instructions, statements, confirmations, facility documents, guarantees or digital records.	Imprisonment up to 4 years, fine, or both.
Forgery of identity document or proof of address submitted to bank	Penal Code 1871, s468	Covers forgery committed for the purpose of cheating.	Applies where forged banking documents are used to obtain accounts, credit, payments, transfers, securities or regulatory advantage.	Imprisonment up to 10 years and liable to fine.
Forgery of board resolution or authorised signatory list	Penal Code 1871, s468	Covers forgery committed for the purpose of cheating.	Applies where forged banking documents are used to obtain accounts, credit, payments, transfers, securities or regulatory advantage.	Imprisonment up to 10 years and liable to fine.
Forgery of loan, mortgage or security document	Penal Code 1871, s468	Covers forgery committed for the purpose of cheating.	Applies where forged banking documents are used to obtain accounts, credit, payments, transfers, securities or regulatory advantage.	Imprisonment up to 10 years and liable to fine.
Forgery of valuation, income or employment document	Penal Code 1871, s468	Covers forgery committed for the purpose of cheating.	Applies where forged banking documents are used to obtain accounts, credit, payments, transfers, securities or regulatory advantage.	Imprisonment up to 10 years and liable to fine.
Forgery of financial statement or management account	Penal Code 1871, s468	Covers forgery committed for the purpose of cheating.	Applies where forged banking documents are used to obtain accounts, credit, payments, transfers, securities or regulatory advantage.	Imprisonment up to 10 years and liable to fine.
Falsification of bank accounts, ledgers or reconciliations	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
Falsification of customer due diligence records	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
Falsification of transaction monitoring notes	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
Falsification of credit assessment or approval records	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
Falsification of collateral or security records	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
Falsification of treasury, trading or position records	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
Falsification of audit, compliance or risk records	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
Backdating of approvals, instructions or confirmations	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
False regulatory return or MAS submission	Penal Code 1871, ss191-193, 196, 199 and related provisions	Protects legal, regulatory and investigative proceedings from false evidence and false statements.	Applies where false statements, declarations, evidence, confirmations or reports are given to auditors, MAS, police, court or investigators.	Punishment depends on section; false evidence may carry imprisonment and fine.
False statement to auditor, MAS, police or investigator	Penal Code 1871, ss191-193, 196, 199 and related provisions	Protects legal, regulatory and investigative proceedings from false evidence and false statements.	Applies where false statements, declarations, evidence, confirmations or reports are given to auditors, MAS, police, court or investigators.	Punishment depends on section; false evidence may carry imprisonment and fine.
False suspicious transaction explanation or investigation note	Penal Code 1871, ss191-193, 196, 199 and related provisions	Protects legal, regulatory and investigative proceedings from false evidence and false statements.	Applies where false statements, declarations, evidence, confirmations or reports are given to auditors, MAS, police, court or investigators.	Punishment depends on section; false evidence may carry imprisonment and fine.
Concealment or destruction of bank records	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Deletion or alteration of audit logs or CCTV evidence	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Refusal to produce documents when legally required	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Obstruction of MAS, police, auditor or internal investigation	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Witness intimidation or coaching in bank inquiry	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Abetment, conspiracy or attempt in forgery or false-record offences	Penal Code 1871, ss107-109, 120A-120B and relevant principal offence	Covers abetment, conspiracy and attempts involving underlying offences.	Applies where staff, customers, vendors, mule account holders or outsiders coordinate or attempt banking-related dishonesty.	Generally punished according to the principal offence, subject to applicable provisions.

Part C: BANKING ACT, MAS LICENSING, PRUDENTIAL AND REGULATORY COMPLIANCE BREACHES — Number of Offences: 40

Offence / Misconduct / Breach	Legislation / Section	What the Section Is For	When It Applies in the Organisation	Punishment in Law
Carrying on banking business without licence	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
Operating outside scope of banking licence or approval	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
Breach of bank licence condition or MAS restriction	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
Failure to comply with MAS direction or requirement	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
False or misleading information in banking licence application	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
Failure to obtain approval for substantial shareholding or control change	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to comply with fit-and-proper expectations for directors or senior managers	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to maintain minimum capital or capital adequacy requirement	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to maintain liquidity or liquidity coverage requirements	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to comply with large exposure limits	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Excessive related-party exposure or connected lending breach	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Breach of credit concentration or country risk limits	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Improper classification or provisioning of credit exposures	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to maintain sound credit underwriting controls	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to manage non-performing loans and impaired assets properly	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to maintain proper risk management framework	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to maintain internal controls over branch operations	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to maintain segregation of duties in banking operations	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to maintain compliance function independence	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to maintain internal audit coverage	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to maintain outsourcing controls for material services	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to manage overseas branch or subsidiary regulatory risk	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Improper use of bank name, licence status or MAS authorisation	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
Misleading representation that entity is authorised as a bank	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
Breach of bank secrecy or customer information rules	Banking Act 1970, customer information confidentiality provisions; PDPA 2012 where applicable	Protects customer information and restricts unauthorised disclosure.	Applies where customer account, transaction, credit, wealth, KYC or personal data is disclosed without lawful basis.	Banking Act/PDPA penalties, MAS action, civil liability and disciplinary consequences depending facts.
Unauthorised access to or disclosure of customer financial information	Banking Act 1970, customer information confidentiality provisions; PDPA 2012 where applicable	Protects customer information and restricts unauthorised disclosure.	Applies where customer account, transaction, credit, wealth, KYC or personal data is disclosed without lawful basis.	Banking Act/PDPA penalties, MAS action, civil liability and disciplinary consequences depending facts.
Improper disclosure to related company or external vendor	Banking Act 1970, customer information confidentiality provisions; PDPA 2012 where applicable	Protects customer information and restricts unauthorised disclosure.	Applies where customer account, transaction, credit, wealth, KYC or personal data is disclosed without lawful basis.	Banking Act/PDPA penalties, MAS action, civil liability and disciplinary consequences depending facts.
Failure to safeguard customer statements, account files or KYC data	Banking Act 1970, customer information confidentiality provisions; PDPA 2012 where applicable	Protects customer information and restricts unauthorised disclosure.	Applies where customer account, transaction, credit, wealth, KYC or personal data is disclosed without lawful basis.	Banking Act/PDPA penalties, MAS action, civil liability and disciplinary consequences depending facts.
Failure to notify MAS of material incident or breach where required	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to submit accurate prudential returns	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to submit accurate statistical, liquidity or capital reports	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to keep proper books, accounts and records	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to comply with MAS inspection or supervisory review	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to remediate MAS inspection finding	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to comply with public disclosure or financial reporting requirements	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Failure to comply with deposit-taking restrictions	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
Failure to comply with merchant bank regulatory obligations	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
Failure to comply with credit card or charge card regulatory obligations	Banking Act 1970; Monetary Authority of Singapore Act 1970; MAS notices, directions and licensing conditions	Regulates licensing, prudential soundness, governance, supervision and conduct of banking business.	Applies where a bank, merchant bank, branch, subsidiary, controller, officer or outsourced service provider breaches banking regulatory requirements.	MAS directions, reprimands, composition, civil penalties, licence restrictions/revocation or prosecution; exact provision to verify.
Concealment of material banking regulatory breach	Banking Act 1970, relevant provisions; MAS notices and guidelines	Supports MAS supervision through accurate information, approval requirements, prudential rules and regulatory reporting.	Applies to breaches involving capital, liquidity, exposures, related-party transactions, outsourcing, risk management, governance or returns.	Regulatory action, financial penalties, licence conditions or prosecution depending provision; verify exact penalty.
Abetment, conspiracy or attempt in Banking Act or MAS regulatory breaches	Penal Code 1871, ss107-109, 120A-120B and relevant principal offence	Covers abetment, conspiracy and attempts involving underlying offences.	Applies where staff, customers, vendors, mule account holders or outsiders coordinate or attempt banking-related dishonesty.	Generally punished according to the principal offence, subject to applicable provisions.

Part D: AML/CFT, SANCTIONS AND FINANCIAL CRIME COMPLIANCE BREACHES — Number of Offences: 40

Offence / Misconduct / Breach	Legislation / Section	What the Section Is For	When It Applies in the Organisation	Punishment in Law
Failure to conduct customer due diligence before establishing relationship	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to identify or verify beneficial owner	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to conduct enhanced due diligence for high-risk customer	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to conduct politically exposed person screening	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to screen against sanctions or designated persons lists	MAS regulations/notices; United Nations Act 2001; Terrorism (Suppression of Financing) Act 2002	Implements financial sanctions, asset freezing and prohibitions on dealing with designated persons or entities.	Applies where a bank processes, facilitates or fails to block prohibited transactions or sanctioned relationships.	Criminal/regulatory penalties, directions and financial penalties depending sanction regime; verify exact provision.
Failure to perform ongoing monitoring of customer relationship	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to monitor unusual or suspicious transactions	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to file suspicious transaction report where required	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Tipping off customer about suspicious transaction report or investigation	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to maintain AML/CFT policies, procedures and controls	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to keep customer identification and transaction records	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to perform wire transfer originator or beneficiary information checks	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to reject or hold incomplete wire transfer where required	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to manage correspondent banking AML/CFT risk	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Payable-through account or nested relationship risk not controlled	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Trade-based money laundering control failure	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Private banking high-risk relationship control failure	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Shell company or nominee structure risk not addressed	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Mule account onboarding or retention failure	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to detect scam proceeds, fraud funds or illicit account activity	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to freeze or block sanctioned funds or assets	MAS regulations/notices; United Nations Act 2001; Terrorism (Suppression of Financing) Act 2002	Implements financial sanctions, asset freezing and prohibitions on dealing with designated persons or entities.	Applies where a bank processes, facilitates or fails to block prohibited transactions or sanctioned relationships.	Criminal/regulatory penalties, directions and financial penalties depending sanction regime; verify exact provision.
Dealing with designated terrorist, sanctioned person or prohibited entity	MAS regulations/notices; United Nations Act 2001; Terrorism (Suppression of Financing) Act 2002	Implements financial sanctions, asset freezing and prohibitions on dealing with designated persons or entities.	Applies where a bank processes, facilitates or fails to block prohibited transactions or sanctioned relationships.	Criminal/regulatory penalties, directions and financial penalties depending sanction regime; verify exact provision.
Facilitating terrorism financing transaction	MAS regulations/notices; United Nations Act 2001; Terrorism (Suppression of Financing) Act 2002	Implements financial sanctions, asset freezing and prohibitions on dealing with designated persons or entities.	Applies where a bank processes, facilitates or fails to block prohibited transactions or sanctioned relationships.	Criminal/regulatory penalties, directions and financial penalties depending sanction regime; verify exact provision.
Facilitating proliferation financing or sanctioned trade transaction	MAS regulations/notices; United Nations Act 2001; Terrorism (Suppression of Financing) Act 2002	Implements financial sanctions, asset freezing and prohibitions on dealing with designated persons or entities.	Applies where a bank processes, facilitates or fails to block prohibited transactions or sanctioned relationships.	Criminal/regulatory penalties, directions and financial penalties depending sanction regime; verify exact provision.
Failure to escalate sanctions match or false-positive decision properly	MAS regulations/notices; United Nations Act 2001; Terrorism (Suppression of Financing) Act 2002	Implements financial sanctions, asset freezing and prohibitions on dealing with designated persons or entities.	Applies where a bank processes, facilitates or fails to block prohibited transactions or sanctioned relationships.	Criminal/regulatory penalties, directions and financial penalties depending sanction regime; verify exact provision.
Inadequate AML/CFT training for staff	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Inadequate AML/CFT independent audit or testing	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to apply group-wide AML/CFT controls	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to manage AML/CFT risk in outsourcing or agent arrangements	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
False AML/CFT assurance or compliance attestation	Penal Code 1871, ss191-193, 196, 199 and related provisions	Protects legal, regulatory and investigative proceedings from false evidence and false statements.	Applies where false statements, declarations, evidence, confirmations or reports are given to auditors, MAS, police, court or investigators.	Punishment depends on section; false evidence may carry imprisonment and fine.
Concealment of suspicious transaction or financial crime indicator	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Assisting another person to retain benefits of criminal conduct	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Money laundering involving conversion, transfer or concealment of criminal benefits	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Acquiring, possessing, using or dealing with criminal benefits	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Failure to comply with production, disclosure or information order in AML investigation	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Failure to provide accurate account information to law enforcement or MAS	Penal Code 1871, ss191-193, 196, 199 and related provisions	Protects legal, regulatory and investigative proceedings from false evidence and false statements.	Applies where false statements, declarations, evidence, confirmations or reports are given to auditors, MAS, police, court or investigators.	Punishment depends on section; false evidence may carry imprisonment and fine.
Failure to remediate AML/CFT control deficiencies	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Systemic AML/CFT governance failure by bank management	MAS Notice 626; CDSA 1992; Terrorism (Suppression of Financing) Act 2002; relevant sanctions law	Requires customer due diligence, monitoring, suspicious transaction reporting and controls against money laundering and terrorism financing.	Applies to onboarding, account monitoring, trade finance, correspondent banking, private banking, remittance, sanctions and high-risk customers.	MAS enforcement action, financial penalties, directions and criminal penalties under applicable statutes; exact provisions to verify.
Abetment or conspiracy in AML/CFT, sanctions or financial crime breaches	Penal Code 1871, ss107-109, 120A-120B and relevant principal offence	Covers abetment, conspiracy and attempts involving underlying offences.	Applies where staff, customers, vendors, mule account holders or outsiders coordinate or attempt banking-related dishonesty.	Generally punished according to the principal offence, subject to applicable provisions.
Attempt to evade AML/CFT or sanctions controls	Penal Code 1871, ss107-109, 120A-120B and relevant principal offence	Covers abetment, conspiracy and attempts involving underlying offences.	Applies where staff, customers, vendors, mule account holders or outsiders coordinate or attempt banking-related dishonesty.	Generally punished according to the principal offence, subject to applicable provisions.

Part E: CYBER, TECHNOLOGY, DIGITAL BANKING, PAYMENT SYSTEMS AND DATA PROTECTION OFFENCES — Number of Offences: 40

Offence / Misconduct / Breach	Legislation / Section	What the Section Is For	When It Applies in the Organisation	Punishment in Law
Unauthorised access to core banking system	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Unauthorised access to internet or mobile banking platform	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Unauthorised access to ATM or card management system	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Unauthorised access to SWIFT, payments or settlement system	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Unauthorised modification of customer account data	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Unauthorised modification of transaction, limit or standing instruction data	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Unauthorised modification of credit, collateral or risk records	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Unauthorised deletion of logs, alerts or investigation records	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Malware or ransomware affecting bank systems	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Phishing, credential harvesting or account takeover involving bank users	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Unauthorised disclosure or sharing of access code, OTP or token	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Credential sharing or privilege misuse by bank staff or vendor	Computer Misuse Act 1993, ss3-7 and related provisions	Criminalises unauthorised access, modification, interception and obstruction of computer systems.	Applies to core banking, mobile banking, internet banking, ATM, SWIFT, payment, customer, CRM, HR and audit systems.	Fines and imprisonment under CMA; enhanced penalties may apply depending damage, intent and protected systems.
Failure to revoke access after staff, vendor or contractor departure	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Failure to restrict privileged access to critical systems	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Failure to protect critical banking systems from cyber risk	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Failure to report or escalate material technology incident	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Failure to maintain business continuity for digital banking services	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Failure to test disaster recovery or system resilience	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Failure to manage third-party technology or cloud service provider risk	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Failure to implement secure software development controls	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Failure to patch critical vulnerability in banking systems	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Failure to detect or respond to fraud alerts in digital banking	Financial Services and Markets Act 2022; MAS Technology Risk Management requirements	Supports sector-wide regulation, technology risk management and operational resilience in financial services.	Applies to material system outages, weak controls, outsourcing failures, cyber resilience lapses or technology-risk governance failures.	MAS directions, financial penalties, licence consequences or prosecution depending provision and breach.
Unauthorised disclosure of personal data	Personal Data Protection Act 2012, ss11-26D, 48D-48J	Regulates collection, use, disclosure, protection, retention and breach notification for personal data.	Applies to customer, employee, applicant, beneficial-owner, guarantor, cardholder and transaction-related personal data handled by banks or vendors.	PDPC directions and financial penalties; individual offences may carry fines/imprisonment depending provision.
Failure to protect personal data through reasonable security arrangements	Personal Data Protection Act 2012, ss11-26D, 48D-48J	Regulates collection, use, disclosure, protection, retention and breach notification for personal data.	Applies to customer, employee, applicant, beneficial-owner, guarantor, cardholder and transaction-related personal data handled by banks or vendors.	PDPC directions and financial penalties; individual offences may carry fines/imprisonment depending provision.
Failure to notify notifiable data breach	Personal Data Protection Act 2012, ss11-26D, 48D-48J	Regulates collection, use, disclosure, protection, retention and breach notification for personal data.	Applies to customer, employee, applicant, beneficial-owner, guarantor, cardholder and transaction-related personal data handled by banks or vendors.	PDPC directions and financial penalties; individual offences may carry fines/imprisonment depending provision.
Improper collection, use or retention of personal data	Personal Data Protection Act 2012, ss11-26D, 48D-48J	Regulates collection, use, disclosure, protection, retention and breach notification for personal data.	Applies to customer, employee, applicant, beneficial-owner, guarantor, cardholder and transaction-related personal data handled by banks or vendors.	PDPC directions and financial penalties; individual offences may carry fines/imprisonment depending provision.
Improper overseas transfer of customer personal data	Personal Data Protection Act 2012, ss11-26D, 48D-48J	Regulates collection, use, disclosure, protection, retention and breach notification for personal data.	Applies to customer, employee, applicant, beneficial-owner, guarantor, cardholder and transaction-related personal data handled by banks or vendors.	PDPC directions and financial penalties; individual offences may carry fines/imprisonment depending provision.
Uploading protected customer data to unauthorised AI or cloud tools	Personal Data Protection Act 2012, ss11-26D, 48D-48J	Regulates collection, use, disclosure, protection, retention and breach notification for personal data.	Applies to customer, employee, applicant, beneficial-owner, guarantor, cardholder and transaction-related personal data handled by banks or vendors.	PDPC directions and financial penalties; individual offences may carry fines/imprisonment depending provision.
Operating payment service without required licence where applicable	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Breach of payment service licence or exemption condition	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Failure to safeguard customer monies or e-money float	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Failure to comply with payment transaction record obligations	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Failure to manage payment system operational risk	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Failure to protect cardholder data or payment credentials	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Unauthorised card issuing, acquiring or merchant payment conduct	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Failure to comply with major payment institution or standard payment institution requirements	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Failure to manage digital payment token risk where bank provides related service	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Misuse of QR, PayNow, FAST, GIRO or payment rail access	Payment Services Act 2019; Banking Act 1970; MAS payment system requirements	Regulates payment services, payment systems and payment-related conduct, risk and safeguarding obligations.	Applies to card issuing, acquiring, e-money, domestic transfers, cross-border transfers, digital payment tokens or payment infrastructure operated by a bank.	MAS regulatory action, financial penalties, licence consequences or prosecution depending provision.
Concealment of technology, cyber, payment or data incident	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Abetment, conspiracy or attempt in cyber, payment or data protection offences	Penal Code 1871, ss107-109, 120A-120B and relevant principal offence	Covers abetment, conspiracy and attempts involving underlying offences.	Applies where staff, customers, vendors, mule account holders or outsiders coordinate or attempt banking-related dishonesty.	Generally punished according to the principal offence, subject to applicable provisions.

Part F: SECURITIES, FINANCIAL ADVISORY, INVESTMENT, MARKET CONDUCT AND CUSTOMER MIS-SELLING OFFENCES — Number of Offences: 40

Offence / Misconduct / Breach	Legislation / Section	What the Section Is For	When It Applies in the Organisation	Punishment in Law
Dealing in capital markets products without proper authorisation	Securities and Futures Act 2001; MAS capital markets conduct rules	Regulates securities, derivatives, capital markets products, market conduct and licensed activities.	Applies where a bank deals in, advises on, distributes, trades or intermediates capital markets products or securities-linked products.	Civil penalties, criminal penalties, licence action, prohibition orders or MAS enforcement depending provision.
Bank representative conducting regulated activity without proper appointment	Securities and Futures Act 2001; MAS capital markets conduct rules	Regulates securities, derivatives, capital markets products, market conduct and licensed activities.	Applies where a bank deals in, advises on, distributes, trades or intermediates capital markets products or securities-linked products.	Civil penalties, criminal penalties, licence action, prohibition orders or MAS enforcement depending provision.
Misrepresentation in sale of investment product	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Unsuitable investment recommendation to customer	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Failure to disclose material product risk	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Failure to disclose fees, charges or commissions	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Failure to conduct customer knowledge or risk-profile assessment	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Mis-selling of structured products or dual currency investments	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Mis-selling of unit trusts, bonds or securities-linked products	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Mis-selling of insurance or bancassurance product	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
False or misleading statement in financial advisory process	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Unauthorised financial advice by bank staff	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Failure to supervise financial advisory representatives	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Improper switching, churning or replacement of products	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Improper handling of vulnerable customer advisory process	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Failure to maintain advisory documentation and rationale	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Failure to deal fairly with customers in product distribution	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Misleading advertisement or product marketing material	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Insider trading involving bank staff or customer information	Securities and Futures Act 2001, market misconduct provisions	Prohibits insider trading, market manipulation, false trading, price rigging and misleading statements.	Applies where bank staff, traders, analysts, relationship managers or customers misuse information or manipulate markets through bank channels.	Civil/criminal penalties and possible imprisonment, fines and prohibition orders depending offence.
False trading or market manipulation through bank channels	Securities and Futures Act 2001, market misconduct provisions	Prohibits insider trading, market manipulation, false trading, price rigging and misleading statements.	Applies where bank staff, traders, analysts, relationship managers or customers misuse information or manipulate markets through bank channels.	Civil/criminal penalties and possible imprisonment, fines and prohibition orders depending offence.
Market rigging, price manipulation or matched orders	Securities and Futures Act 2001, market misconduct provisions	Prohibits insider trading, market manipulation, false trading, price rigging and misleading statements.	Applies where bank staff, traders, analysts, relationship managers or customers misuse information or manipulate markets through bank channels.	Civil/criminal penalties and possible imprisonment, fines and prohibition orders depending offence.
Dissemination of false or misleading market information	Securities and Futures Act 2001, market misconduct provisions	Prohibits insider trading, market manipulation, false trading, price rigging and misleading statements.	Applies where bank staff, traders, analysts, relationship managers or customers misuse information or manipulate markets through bank channels.	Civil/criminal penalties and possible imprisonment, fines and prohibition orders depending offence.
Front-running client orders	Securities and Futures Act 2001, market misconduct provisions	Prohibits insider trading, market manipulation, false trading, price rigging and misleading statements.	Applies where bank staff, traders, analysts, relationship managers or customers misuse information or manipulate markets through bank channels.	Civil/criminal penalties and possible imprisonment, fines and prohibition orders depending offence.
Misuse of confidential order or research information	Securities and Futures Act 2001, market misconduct provisions	Prohibits insider trading, market manipulation, false trading, price rigging and misleading statements.	Applies where bank staff, traders, analysts, relationship managers or customers misuse information or manipulate markets through bank channels.	Civil/criminal penalties and possible imprisonment, fines and prohibition orders depending offence.
Improper personal account dealing by bank employee	Securities and Futures Act 2001, market misconduct provisions	Prohibits insider trading, market manipulation, false trading, price rigging and misleading statements.	Applies where bank staff, traders, analysts, relationship managers or customers misuse information or manipulate markets through bank channels.	Civil/criminal penalties and possible imprisonment, fines and prohibition orders depending offence.
Failure to maintain information barriers or Chinese walls	Securities and Futures Act 2001; MAS capital markets conduct rules	Regulates securities, derivatives, capital markets products, market conduct and licensed activities.	Applies where a bank deals in, advises on, distributes, trades or intermediates capital markets products or securities-linked products.	Civil penalties, criminal penalties, licence action, prohibition orders or MAS enforcement depending provision.
Failure to manage conflicts in research, sales or trading	Securities and Futures Act 2001; MAS capital markets conduct rules	Regulates securities, derivatives, capital markets products, market conduct and licensed activities.	Applies where a bank deals in, advises on, distributes, trades or intermediates capital markets products or securities-linked products.	Civil penalties, criminal penalties, licence action, prohibition orders or MAS enforcement depending provision.
Improper allocation of IPO, bond or structured product opportunities	Securities and Futures Act 2001; MAS capital markets conduct rules	Regulates securities, derivatives, capital markets products, market conduct and licensed activities.	Applies where a bank deals in, advises on, distributes, trades or intermediates capital markets products or securities-linked products.	Civil penalties, criminal penalties, licence action, prohibition orders or MAS enforcement depending provision.
Failure to comply with client asset or custody obligations	Securities and Futures Act 2001; MAS capital markets conduct rules	Regulates securities, derivatives, capital markets products, market conduct and licensed activities.	Applies where a bank deals in, advises on, distributes, trades or intermediates capital markets products or securities-linked products.	Civil penalties, criminal penalties, licence action, prohibition orders or MAS enforcement depending provision.
Failure to provide accurate contract notes or confirmations	Securities and Futures Act 2001; MAS capital markets conduct rules	Regulates securities, derivatives, capital markets products, market conduct and licensed activities.	Applies where a bank deals in, advises on, distributes, trades or intermediates capital markets products or securities-linked products.	Civil penalties, criminal penalties, licence action, prohibition orders or MAS enforcement depending provision.
Failure to keep capital markets records	Securities and Futures Act 2001; MAS capital markets conduct rules	Regulates securities, derivatives, capital markets products, market conduct and licensed activities.	Applies where a bank deals in, advises on, distributes, trades or intermediates capital markets products or securities-linked products.	Civil penalties, criminal penalties, licence action, prohibition orders or MAS enforcement depending provision.
False or misleading report to MAS or exchange	Securities and Futures Act 2001; MAS capital markets conduct rules	Regulates securities, derivatives, capital markets products, market conduct and licensed activities.	Applies where a bank deals in, advises on, distributes, trades or intermediates capital markets products or securities-linked products.	Civil penalties, criminal penalties, licence action, prohibition orders or MAS enforcement depending provision.
Obstruction of capital markets or financial advisory investigation	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Failure to comply with prohibition order or representative restriction	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Improper complaint handling for investment or advisory complaint	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Failure to compensate or remediate customer after systemic mis-selling where directed	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Abetment or conspiracy in securities, advisory or market conduct offence	Penal Code 1871, ss107-109, 120A-120B and relevant principal offence	Covers abetment, conspiracy and attempts involving underlying offences.	Applies where staff, customers, vendors, mule account holders or outsiders coordinate or attempt banking-related dishonesty.	Generally punished according to the principal offence, subject to applicable provisions.
Attempt to commit insider trading, market misconduct or mis-selling offence	Penal Code 1871, ss107-109, 120A-120B and relevant principal offence	Covers abetment, conspiracy and attempts involving underlying offences.	Applies where staff, customers, vendors, mule account holders or outsiders coordinate or attempt banking-related dishonesty.	Generally punished according to the principal offence, subject to applicable provisions.
Failure to manage cross-border advisory or solicitation restrictions	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.
Failure to comply with product due diligence governance	Financial Advisers Act 2001; MAS notices and conduct rules	Regulates financial advisory services, representatives, supervisors and advice on investment products.	Applies to bank wealth management, investment advisory, insurance referrals, structured product recommendations and relationship managers acting as representatives.	Fines, imprisonment, civil penalties, prohibition orders, representative action or MAS enforcement depending provision.

Part G: CORRUPTION, ETHICS, GOVERNANCE, AUDIT, OPERATIONAL RISK, WSH AND PUBLIC PROTECTION BREACHES — Number of Offences: 30

Offence / Misconduct / Breach	Legislation / Section	What the Section Is For	When It Applies in the Organisation	Punishment in Law
Bank employee accepting gratification from customer, vendor or intermediary	Prevention of Corruption Act 1960, ss5-6 and related provisions	Criminalises corrupt giving, receiving, soliciting or offering of gratification.	Applies to procurement, credit approval, onboarding, vendor selection, debt recovery, referral, hiring, advisory or regulatory interactions.	Fine up to $100,000, imprisonment up to 5 years, or both; higher in certain public-sector contexts.
Customer, vendor or intermediary offering gratification to bank employee	Prevention of Corruption Act 1960, ss5-6 and related provisions	Criminalises corrupt giving, receiving, soliciting or offering of gratification.	Applies to procurement, credit approval, onboarding, vendor selection, debt recovery, referral, hiring, advisory or regulatory interactions.	Fine up to $100,000, imprisonment up to 5 years, or both; higher in certain public-sector contexts.
Corrupt reward for loan approval, credit limit or facility variation	Prevention of Corruption Act 1960, ss5-6 and related provisions	Criminalises corrupt giving, receiving, soliciting or offering of gratification.	Applies to procurement, credit approval, onboarding, vendor selection, debt recovery, referral, hiring, advisory or regulatory interactions.	Fine up to $100,000, imprisonment up to 5 years, or both; higher in certain public-sector contexts.
Corrupt reward for onboarding, KYC clearance or account opening	Prevention of Corruption Act 1960, ss5-6 and related provisions	Criminalises corrupt giving, receiving, soliciting or offering of gratification.	Applies to procurement, credit approval, onboarding, vendor selection, debt recovery, referral, hiring, advisory or regulatory interactions.	Fine up to $100,000, imprisonment up to 5 years, or both; higher in certain public-sector contexts.
Corrupt procurement, vendor selection or contract award	Prevention of Corruption Act 1960, ss5-6 and related provisions	Criminalises corrupt giving, receiving, soliciting or offering of gratification.	Applies to procurement, credit approval, onboarding, vendor selection, debt recovery, referral, hiring, advisory or regulatory interactions.	Fine up to $100,000, imprisonment up to 5 years, or both; higher in certain public-sector contexts.
Kickback arrangement with broker, valuer, vendor or introducer	Prevention of Corruption Act 1960, ss5-6 and related provisions	Criminalises corrupt giving, receiving, soliciting or offering of gratification.	Applies to procurement, credit approval, onboarding, vendor selection, debt recovery, referral, hiring, advisory or regulatory interactions.	Fine up to $100,000, imprisonment up to 5 years, or both; higher in certain public-sector contexts.
Use of false receipt, invoice or account in corrupt transaction	Prevention of Corruption Act 1960, ss5-6 and related provisions	Criminalises corrupt giving, receiving, soliciting or offering of gratification.	Applies to procurement, credit approval, onboarding, vendor selection, debt recovery, referral, hiring, advisory or regulatory interactions.	Fine up to $100,000, imprisonment up to 5 years, or both; higher in certain public-sector contexts.
Conflict of interest not disclosed in credit, procurement or advisory decision	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Undisclosed outside business, referral or commission arrangement	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Misuse of confidential bank or customer information for private gain	Penal Code 1871, s424A	Covers fraud by false representation, non-disclosure or abuse of position.	Applies where banking position, information, system access or customer trust is abused for dishonest gain or to cause loss.	Imprisonment up to 20 years, fine, or both.
Abuse of authority by senior banker, manager or approving officer	Penal Code 1871, s424A	Covers fraud by false representation, non-disclosure or abuse of position.	Applies where banking position, information, system access or customer trust is abused for dishonest gain or to cause loss.	Imprisonment up to 20 years, fine, or both.
Retaliation against whistleblower or complainant	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Failure to maintain whistleblowing or complaint escalation controls	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Failure to maintain proper governance, risk and compliance framework	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Failure to maintain accurate financial statements or management accounts	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
False or misleading board, committee or risk paper	Penal Code 1871, s477A	Covers falsifying accounts, books, electronic records or documents with intent to defraud.	Applies to false ledgers, reconciliations, approvals, logs, transaction records, account files or audit materials.	Imprisonment up to 10 years, fine, or both.
Failure to retain records required for audit, MAS review or investigation	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Failure to implement audit or regulatory remediation actions	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Failure to maintain operational risk controls in cash, card or branch operations	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Failure to manage fraud risk in customer service, call centre or branch operations	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Failure to maintain safe bank premises and workplace	Workplace Safety and Health Act 2006; Fire Safety Act 1993; relevant workplace and building safety rules	Requires safe workplace, fire safety, emergency preparedness and protection of staff, customers and visitors.	Applies to branches, offices, data centres, ATMs, cash operations, vaults, call centres, events, contractors and facilities management.	Fines, imprisonment, stop-work/remedial orders, fire safety enforcement or civil liability depending breach.
Failure to manage contractor safety in branches, offices or data centres	Workplace Safety and Health Act 2006; Fire Safety Act 1993; relevant workplace and building safety rules	Requires safe workplace, fire safety, emergency preparedness and protection of staff, customers and visitors.	Applies to branches, offices, data centres, ATMs, cash operations, vaults, call centres, events, contractors and facilities management.	Fines, imprisonment, stop-work/remedial orders, fire safety enforcement or civil liability depending breach.
Fire safety breach in branch, vault, office or data centre	Workplace Safety and Health Act 2006; Fire Safety Act 1993; relevant workplace and building safety rules	Requires safe workplace, fire safety, emergency preparedness and protection of staff, customers and visitors.	Applies to branches, offices, data centres, ATMs, cash operations, vaults, call centres, events, contractors and facilities management.	Fines, imprisonment, stop-work/remedial orders, fire safety enforcement or civil liability depending breach.
Failure to secure cash movement, vault or ATM replenishment operation	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Failure to protect customers during branch crowd, emergency or incident	Workplace Safety and Health Act 2006; Fire Safety Act 1993; relevant workplace and building safety rules	Requires safe workplace, fire safety, emergency preparedness and protection of staff, customers and visitors.	Applies to branches, offices, data centres, ATMs, cash operations, vaults, call centres, events, contractors and facilities management.	Fines, imprisonment, stop-work/remedial orders, fire safety enforcement or civil liability depending breach.
Failure to manage physical security at branch, vault, ATM or data centre	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Failure to report serious operational, safety or security incident	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Concealment of operational loss, fraud event or regulatory breach	Penal Code 1871, ss175, 186, 201, 203, 204; MAS statutory powers where applicable	Protects lawful production of documents, investigations and evidence integrity.	Applies where documents are withheld, evidence destroyed, witnesses coached or MAS/police/auditors are obstructed.	Penalty depends on section and underlying offence; regulatory action may also apply.
Corporate or senior management liability for systemic banking failure	Companies Act 1967; Banking Act 1970; MAS governance/risk management requirements; Penal Code where dishonest	Supports sound governance, internal controls, fit-and-proper management, auditability and accountability.	Applies to board, senior management, committees, risk, audit, compliance, finance, outsourcing and reporting functions in banks.	Regulatory, civil, disciplinary and criminal consequences depending breach and statute.
Conspiracy, abetment or attempt in corruption, governance, safety or public protection breaches	Penal Code 1871, ss107-109, 120A-120B and relevant principal offence	Covers abetment, conspiracy and attempts involving underlying offences.	Applies where staff, customers, vendors, mule account holders or outsiders coordinate or attempt banking-related dishonesty.	Generally punished according to the principal offence, subject to applicable provisions.

Reference and Verification Checklist

Verify all Penal Code 1871 sections and punishments against the current Singapore Statutes Online text.
Verify Banking Act 1970 licensing, bank secrecy, prudential, credit card/charge card, merchant bank and supervisory provisions, including current amendments and MAS instruments.
Verify Monetary Authority of Singapore Act 1970 provisions on MAS powers, inspections, directions, information gathering, resolution and financial-sector oversight.
Verify Financial Services and Markets Act 2022 provisions on sector-wide regulation, technology risk management, prohibition orders and financial-sector misconduct.
Verify MAS Notice 626, Guidelines to Notice 626 and current AML/CFT requirements for banks, including CDD, EDD, STR, wire transfers, correspondent banking, sanctions screening and group controls.
Verify CDSA 1992, Terrorism (Suppression of Financing) Act 2002 and United Nations Act sanctions requirements before publication.
Verify Payment Services Act 2019 obligations where banks provide regulated payment services, e-money, transfer services, digital payment token or payment system functions.
Verify Securities and Futures Act 2001 and Financial Advisers Act 2001 obligations where banks conduct capital markets, wealth management, advisory, securities, derivatives or investment-product distribution activities.
Verify Trust Companies Act 2005, Deposit Insurance and Policy Owners Protection Schemes Act and any other bank-specific or product-specific statutes where applicable.
Verify PDPA 2012 obligations and current PDPC enforcement framework for customer, employee, beneficial-owner and transaction personal data.
Verify Computer Misuse Act 1993 and MAS technology risk requirements for cyber, digital banking, payment, SWIFT, ATM, mobile/internet banking and third-party technology risks.
Verify Prevention of Corruption Act 1960 provisions relating to gratification, procurement corruption, kickbacks, referral arrangements, credit approval, onboarding and customer/vendor dealings.
Verify Companies Act 1967, corporate governance, audit, financial reporting and director/officer duties applicable to bank entities.
Verify WSH Act 2006, Fire Safety Act 1993 and physical security/public-safety obligations for branches, offices, data centres, cash operations and contractors.
Verify MAS Notices, Guidelines, Circulars, Enforcement Reports and current licensing conditions applicable to full banks, wholesale banks, merchant banks, digital banks and relevant banking groups.
Verify all references to penalties, composition, civil penalties, prohibition orders, licence restrictions, revocation, supervisory directions and criminal punishments before training, publication or operational use.

My Library

My Library

Offences, Misconduct, Regulatory Breaches & Punishments

Banks, Merchant Banks, Digital Banks, Branches, Banking Groups, Officers, Representatives, Vendors and Banking Operations

Offence Classification Legend

Offences / Misconducts / Breach

Part A: THEFT, CRIMINAL BREACH OF TRUST, CHEATING, FRAUD AND DECEPTION OFFENCES — Number of Offences: 40

Offence / Misconduct / Breach

Legislation / Section

What the Section Is For

When It Applies in the Organisation

Punishment in Law

Part B: FORGERY, FALSE RECORDS, DOCUMENTATION AND EVIDENCE OFFENCES — Number of Offences: 30

Offence / Misconduct / Breach

Legislation / Section

What the Section Is For

When It Applies in the Organisation

Punishment in Law

Part C: BANKING ACT, MAS LICENSING, PRUDENTIAL AND REGULATORY COMPLIANCE BREACHES — Number of Offences: 40

Offence / Misconduct / Breach

Legislation / Section

What the Section Is For

When It Applies in the Organisation

Punishment in Law

Part D: AML/CFT, SANCTIONS AND FINANCIAL CRIME COMPLIANCE BREACHES — Number of Offences: 40

Offence / Misconduct / Breach

Legislation / Section

What the Section Is For

When It Applies in the Organisation

Punishment in Law

Part E: CYBER, TECHNOLOGY, DIGITAL BANKING, PAYMENT SYSTEMS AND DATA PROTECTION OFFENCES — Number of Offences: 40

Offence / Misconduct / Breach

Legislation / Section

What the Section Is For

When It Applies in the Organisation

Punishment in Law

Part F: SECURITIES, FINANCIAL ADVISORY, INVESTMENT, MARKET CONDUCT AND CUSTOMER MIS-SELLING OFFENCES — Number of Offences: 40

Offence / Misconduct / Breach

Legislation / Section

What the Section Is For

When It Applies in the Organisation

Punishment in Law

Part G: CORRUPTION, ETHICS, GOVERNANCE, AUDIT, OPERATIONAL RISK, WSH AND PUBLIC PROTECTION BREACHES — Number of Offences: 30

Offence / Misconduct / Breach

Legislation / Section

What the Section Is For

When It Applies in the Organisation

Punishment in Law

Reference and Verification Checklist

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