When a fire alarm sounds in your firm's office building, an appointed fire warden acts immediately. They New regulations for banks and insurers proposed in Singapore borrow an idea that cricket settled decades ago. For a long time, the home side in Test cricket supplied the umpires. Touring teams often suspected those umpires’ calls were leaning towards the home team. By 1994, the International Cricket Council had formally adopted one neutral umpire in every Test to overcome the perceived conflict of interest.
On 30 September 2026, the Monetary Authority of Singapore (MAS) published a consultation paper on its corporate governance regulations for banks, insurers, and designated financial holding companies. We took an employee conflicts of interest lens and noticed the paper treats objective judgement as a core safeguard, noting that the consequences of governance failures “can extend far beyond the institution itself”. Its proposed changes to director independence focus on relationships that, in the regulator’s words, “could undermine a director’s independence in acting in the best interests” of the financial institution.
Key Highlights
- MAS consultation on corporate governance regulations closes 9 December 2026
- Independence tests widen to parent companies, sister companies, and family
- Directors at a substantial shareholder’s affiliate deemed non-independent
- Nominating committees would vet conflicts before bank officers take outside roles
- Banks keep fit and proper duties where Head of Treasury approval ends
What MAS Proposes in Its Regulations for Banks and Insurers
Independence tests would extend to parent and sister companies, and to the business dealings of a director’s immediate family. MAS explained the reasoning in its media release.
“Clear independence criteria support objective judgement and effective challenge.”
- Monetary Authority of Singapore, 30 September 2026
Three of the paper’s proposals stand out for conflicts management. First, a director who also works for, or sits on the board of, an affiliate of a substantial shareholder would be deemed non-independent from that shareholder. The nominating committee (NC) could still treat a non-executive director of the affiliate as independent, but only to the satisfaction of MAS.
Second, the NC would check before the event. An existing executive officer or director may plan a new executive officer or director role in any company, inside or outside the group. The NC would first assess whether it creates a conflict of interest or impairs the person’s duties to the bank, and, where it does, ensure adequate guardrails are in place. MAS aligns the proposal with MAS Notice 106 for insurers.
Third, prior MAS approval for a Head of Treasury would remain only at domestic systemically important banks. Even so, the paper states that “MAS expects all banks to continue conducting adequate due diligence on the fitness and propriety prior to the appointment of the Head of Treasury.”
Why the MAS Consultation Paper Matters
Each of these MAS proposals turns conflicts management into a question of evidence. An NC cannot assess an outside appointment in advance unless someone tells it in time. A director’s independence may also depend on facts a bank may not currently hold, for example a relative’s role at the parent company.
Where Head of Treasury approval falls away, the expectation does not. The fit and proper assessment then rests with the bank alone. MAS proposes that the appointment and approval changes take effect as soon as the amendments are made.
Singapore Enforcement Snapshot
The cases outlined below do not directly involve the proposals in the consultation paper. Rather, each shows how MAS has acted over the past year when conflicts, related-party arrangements, or senior conduct went unchecked at a financial institution, providing more insight into the regulator's current perspective.
Weak Conflict Controls Cost a Licence
On 20 May 2026, MAS announced it had revoked a digital payment token service provider’s Major Payment Institution licence, with effect from 14 May. An onsite inspection found significant weaknesses in its conflict of interest policies, and a failure to meet MAS’ outsourcing guidelines in its arrangements with related entities. The firm had also given MAS false or misleading information on several occasions. MAS listed the related-entity arrangements among the serious breaches.¹
Senior Management Held to Account
On 18 May 2026, MAS reprimanded the chief executive and an executive director of a fund manager for failing to discharge their duties, including ensuring the firm complied with MAS regulations. The firm received a composition fine of S$40,000 for breaches that included an inadequate risk management framework and a base capital shortfall it did not report. MAS held the individuals and the firm to account.²
The Broader Industry Story
MAS is aligning its independence rules more closely with SGX’s listing rules and building on its Guidelines on Individual Accountability and Conduct. MAS describes the changes as risk-based. It links removing Head of Treasury approval at most banks to the Guidelines, which it says have helped strengthen senior managers’ individual accountability since September 2021. Banks would still carry out their own due diligence. Under the proposals, a director’s immediate family members’ business dealings and a senior officer’s outside executive or director appointments become matters for the nominating committee to assess.
From Home Umpires to Neutral Judgement
According to ESPNcricinfo, home teams’ win-loss ratio actually improved after neutral umpires arrived.³ In actuality, the change was less about catching biased officials than about removing any reason to doubt the decision.
The MAS proposals read the same way. They do not assume bad faith, the NC can rebut several presumptions, and some rules are even relaxed. The key takeaway for financial firms is that board judgement needs to be independent, be seen to be independent, and have the records to show it.
Operationalising Independence and Conflicts Oversight
How firms operationalise these expectations will be critical to reducing regulatory risk if MAS adopts the proposals. Compliance teams often ask which tools help them manage conflicts. A purpose-built RegTech platform, such as MCO (MyComplianceOffice), brings disclosures and fit and proper records into one place.
With MCO’s Conflicts of Interest Management and Licensing and Accountability solutions, firms can:
- Capture outside business activities (OBAs), close personal relationships, and connected persons
- Route proposed new appointments for review before they begin
- Record mitigating measures with a full audit trail
- Keep fit and proper records current for key appointees such as the Head of Treasury
Learn more about MCO’s complete compliance solution.
References
- Monetary Authority of Singapore, “MAS Revokes the Major Payment Institution Licence of Bsquared Technology Pte Ltd”, 20 May 2026.
- Monetary Authority of Singapore, “MAS Takes Enforcement Action against Havenport Investments Pte Ltd and its Senior Management for Breaches of MAS Regulations”, 18 May 2026.
- ESPNcricinfo, “Turning Points”, on the introduction of neutral umpires in Test cricket.
- Monetary Authority of Singapore, “MAS Consults on Targeted Updates to Corporate Governance Requirements for Banks, Insurers and Designated Financial Holding Companies”, 30 September 2026.
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