Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
MAS's Enforcement Report 2025/2026, published 7 October 2026, records S$29 million in penalties and compositions, six of them against insurers, 23 prohibition orders and three licence revocations. The line Singapore boards should read twice: MAS says it held principal officers and key individuals to account for oversight failures.
When I was a statutory CRO, the enforcement section of any regulator's annual output was the first thing I sent to the board, ahead of the policy papers. Policy tells you what the regulator hopes for. Enforcement tells you what it is prepared to do. MAS's Enforcement Report 2025/2026, published on 7 October 2026 and covering 1 January 2025 to 30 June 2026, is worth the same treatment. [CONFIRM with Raymond: replace with a real episode if possible]
My reading is simple. The headline numbers are not dramatic. The direction of travel is. MAS is spending more of its effort on whether the people at the top actually oversaw the firm, and less on whether a single rule was technically breached.
The numbers that matter to a board
- S$29 million in financial penalties and compositions, against 7 banks, 6 insurers, 5 major payment institutions, 6 capital markets services licensees, 1 financial advisory firm and 1 individual.
- 23 prohibition orders, nine of them for six years or longer.
- 3 licence revocations, two capital markets services licences and one major payment institution licence.
- 583 lesser actions, including 43 reprimands, 150 warnings and 352 supervisory reminders.
- 233 cases opened, including 31 for breaches of anti-money laundering controls and 32 concerning the conduct of individuals.
Six insurers paying penalties or compositions in an eighteen-month window should end any assumption in our sector that enforcement is a capital markets problem. And 352 supervisory reminders is the number I would ask a board to sit with. A reminder is MAS telling you, privately, that it has noticed. Boards rarely see them unless they ask.
“A supervisory reminder is MAS telling you, privately, that it has noticed. If your board has never been shown one, ask why.”
Oversight failure is now an enforcement theme
In her opening message, Lynn Tan, Executive Director of MAS's Enforcement Department, says MAS held principal officers and key individuals to account for their oversight failures. The licence revocations show what that looks like in practice. Xen Capital Asia lost its licence partly for not maintaining a compliance function suited to the scale and complexity of its business, and MAS separately reprimanded its Executive Director for failing to discharge her duties. One Heritage Capital Management missed capital requirements and ignored repeated reminders to file returns. Bsquared Technology gave MAS false or misleading information more than once.
None of those are exotic failures. An under-resourced compliance function and a habit of ignoring regulator correspondence are things a competent board should catch in a single meeting, if it is looking.
What I would do this quarter: ask management for every MAS letter of advice, warning and supervisory reminder received in the last three years, with the remediation status of each. Ask the head of compliance, without management in the room, whether the function is resourced for the business you have today rather than the one you had when it was set up. And put enforcement trends on the board risk committee agenda once a year, not just when something lands on your own desk.
Common Questions
What does the MAS Enforcement Report 2025/2026 cover?
The report, published on 7 October 2026, covers MAS enforcement activity from 1 January 2025 to 30 June 2026. It records S$29 million in financial penalties and compositions against 26 institutions and one individual, 23 prohibition orders, 3 licence revocations, 19 criminal or civil penalty actions and 583 other actions such as reprimands and warnings. MAS publishes the report once every 18 months.
Were Singapore insurers penalised in the MAS Enforcement Report 2025/2026?
Yes. Six insurers were among the institutions that paid financial penalties or compositions during the reporting period, alongside seven banks, five major payment institutions, six capital markets services licensees and one financial advisory firm. MAS also issued prohibition orders against former insurance representatives in the months after the reporting period closed, so insurance boards should treat enforcement as a live sector risk.
Does MAS hold directors and senior management personally accountable for oversight failures?
MAS's Enforcement Department states in the 2025/2026 report that it held principal officers and key individuals to account for their oversight failures. In one licence revocation case, MAS also reprimanded the firm's Executive Director for failing to discharge her duties. Singapore boards should assume that weak compliance functions and unremediated supervisory findings will be traced back to the individuals responsible for oversight.
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About the author
Raymond Cheung is a Chartered Actuary, C-suite executive and board adviser with more than 20 years of experience across Asia in risk management, insurance, ESG and corporate governance. He is the CEO of CER Consultancy and an accredited trainer at SMU Academy and the Singapore College of Insurance.