Banking Sector Offences

PART A – ENTRIES 1 TO 40: THEFT, CRIMINAL BREACH OF TRUST, CHEATING, FRAUD AND DECEPTION OFFENCES

1

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.

2

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.

3

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.

4

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.

5

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.

6

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.

7

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.

8

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.

9

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.

10

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.

11

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.

12

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.

13

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.

14

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.

15

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.

16

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.

17

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.

18

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.

19

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.

20

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.

21

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.

22

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.

23

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.

24

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.

25

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.

26

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.

27

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.

28

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.

29

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.

30

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.

31

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.

32

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.

33

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.

34

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.

35

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.

36

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.

37

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.

38

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.

39

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.

40

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 – ENTRIES 41 TO 70: FORGERY, FALSE RECORDS, DOCUMENTATION AND EVIDENCE OFFENCES

41

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.

42

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.

43

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.

44

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.

45

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.

46

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.

47

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.

48

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.

49

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.

50

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.

51

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.

52

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.

53

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.

54

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.

55

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.

56

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.

57

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.

58

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.

59

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.

60

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.

61

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.

62

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.

63

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.

64

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.

65

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.

66

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.

67

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.

68

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.

69

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.

70

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 – ENTRIES 71 TO 110: BANKING ACT, MAS LICENSING, PRUDENTIAL AND REGULATORY COMPLIANCE BREACHES

71

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.

72

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.

73

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.

74

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.

75

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.

76

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.

77

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.

78

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.

79

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.

80

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.

81

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.

82

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.

83

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.

84

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.

85

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.

86

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.

87

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.

88

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.

89

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.

90

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.

91

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.

92

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.

93

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.

94

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.

95

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.

96

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.

97

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.

98

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.

99

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.

100

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.

101

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.

102

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.

103

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.

104

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.

105

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.

106

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.

107

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.

108

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.

109

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.

110

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 – ENTRIES 111 TO 150: AML/CFT, SANCTIONS AND FINANCIAL CRIME COMPLIANCE BREACHES

111

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.

112

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.

113

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.

114

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.

115

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.

116

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.

117

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.

118

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.

119

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.

120

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.

121

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.

122

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.

123

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.

124

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.

125

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.

126

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.

127

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.

128

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.

129

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.

130

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.

131

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.

132

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.

133

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.

134

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.

135

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.

136

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.

137

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.

138

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.

139

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.

140

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.

141

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.

142

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.

143

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.

144

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.

145

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.

146

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.

147

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.

148

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.

149

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.

150

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 – ENTRIES 151 TO 190: CYBER, TECHNOLOGY, DIGITAL BANKING, PAYMENT SYSTEMS AND DATA PROTECTION OFFENCES

151

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.

152

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.

153

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.

154

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.

155

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.

156

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.

157

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.

158

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.

159

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.

160

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.

161

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.

162

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.

163

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.

164

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.

165

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.

166

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.

167

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.

168

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.

169

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.

170

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.

171

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.

172

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.

173

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.

174

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.

175

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.

176

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.

177

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.

178

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.

179

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.

180

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.

181

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.

182

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.

183

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.

184

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.

185

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.

186

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.

187

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.

188

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.

189

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.

190

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 – ENTRIES 191 TO 230: SECURITIES, FINANCIAL ADVISORY, INVESTMENT, MARKET CONDUCT AND CUSTOMER MIS-SELLING OFFENCES

191

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.

192

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.

193

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.

194

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.

195

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.

196

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.

197

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.

198

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.

199

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.

200

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.

201

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.

202

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.

203

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.

204

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.

205

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.

206

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.

207

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.

208

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.

209

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.

210

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.

211

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.

212

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.

213

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.

214

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.

215

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.

216

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.

217

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.

218

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.

219

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.

220

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.

221

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.

222

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.

223

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.

224

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.

225

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.

226

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.

227

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.

228

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.

229

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.

230

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 – ENTRIES 231 TO 260: CORRUPTION, ETHICS, GOVERNANCE, AUDIT, OPERATIONAL RISK, WSH AND PUBLIC PROTECTION BREACHES

231

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.

232

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.

233

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.

234

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.

235

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.

236

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.

237

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.

238

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.

239

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.

240

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.

241

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.

242

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.

243

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.

244

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.

245

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.

246

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.

247

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.

248

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.

249

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.

250

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.

251

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.

252

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.

253

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.

254

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.

255

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.

256

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.

257

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.

258

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.

259

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.

260

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.