Fit and Proper Compliance: What MAS Expects — And How Pecuniya Can Help
Fit and Proper Compliance: What MAS Expects — And How Pecuniya Can Help
The Monetary Authority of Singapore (MAS) has reinforced its expectations on Fit and Proper assessments under the Representative Notification Framework (RNF), through updates to Guideline FSG-G01 and the foundational Circular CMI 01/2011.
These expectations go beyond documentation—they require a structured, independent due diligence framework that’s verifiable and defensible.
To ensure your institution meets these regulatory standards, focus on the following key areas:
1. Rigorous Reference Checks
MAS expects FIs to conduct independent reference checks with current and past employers before certifying that an individual is fit and proper.
Pecuniya facilitates these checks—including direct outreach to past employers—and provides a full report with findings relevant to integrity, misconduct history, and employment accuracy.
“The FI is expected to conduct reference checks with the proposed representative’s previous employer(s) to confirm that he has not been dismissed or asked to resign, and to ask if he has any material adverse record…”
— MAS Circular CMI 01/2011, Annex 2
2. Due Diligence Documentation & Certification Support
FIs must certify to MAS that they have conducted appropriate due diligence before lodging a representative notification.
Pecuniya provides full-service support for Fit and Proper certifications:
• Drafting declarations
• Verifying identity and credentials
• Compiling due diligence documentation
• Lodgement preparation under RNF
3. Fit and Proper Framework Design or Enhancement
Beyond the basics, your organisation must have a defined and documented framework that governs how fitness and propriety is assessed, especially in cases involving adverse disclosures.
Pecuniya helps you design, enhance, and operationalize a framework aligned with MAS standards—including protocols for handling red flags and supervisory measures for conditionally approved representatives.
4. Ongoing Assessments & Annual Declarations
MAS expects regular monitoring—not just at the time of appointment.
Pecuniya helps establish annual declaration collection systems and periodic re-checks, including:
- Sanctions
- Politically Exposed Persons
- Bankruptcy and insolvency status
- Litigation
- Adverse media records
- Updated conflict of interest assessments
- Regulatory Enforcement Check
- Past Employment Screening Report
“MAS expects the FI to conduct the same due diligence checks on a periodic basis… Frequency should be risk-based.”
— CMI 01/2011, Paragraph 13
5. Handling Adverse Information with Confidence
When red flags arise, MAS expects FIs to justify why the individual is still considered fit and proper—with evidence and documentation.
Pecuniya supports your internal decision-making with:
• Risk-based assessment templates
• Documented justifications
• Advisory on conditional appointments or enhanced supervision
Whether you’re preparing for a new appointment or responding to MAS queries, Pecuniya ensures you’re compliant, audit-ready, and regulator-proof.
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