Monetary Authority of Singapore Outlines Enforcement Priorities for 2025–26

On April 14, 2025, the Monetary Authority of Singapore (MAS) published its latest enforcement report for 2023–24 (Enforcement Report). The Enforcement Report sets out MAS enforcement actions for the period between July 1, 2023, and December 31, 2024 (the Reporting Period), and outlines key MAS enforcement priorities for 2025 to 2026, among other things.

We set out below some updates from the Enforcement Report.

Past Investigations and Enforcement Actions 

During the Reporting Period, there were 163 review and investigation cases opened by MAS, with a significant number pertaining to market misconduct issues such as insider trading and false trading (58 cases). There were also a notable number of investigation cases on persons carrying out regulated activities without a licence (19 cases), breaches of anti-money laundering and countering the financing of terrorism (AML/CFT) related requirements (16 cases), as well as breaches of business conduct rules by financial institutions (14 cases). 

In terms of enforcement actions taken against financial institutions, over the Reporting Period, MAS imposed S$4.4 million in financial penalties and compositions, cancelled the registration of one financial institution, and issued 35 reprimands, 116 warnings, 86 letters of advice, and 305 supervisory reminders. Actions taken against individuals included criminal convictions and the imposition of civil penalties and prohibition orders. 

Featured Case Against Fund Manager 

One noteworthy case featured in the Enforcement Report is a prosecution against a former fund manager and director of a now-defunct Singapore fund management company (FMC). The individual was convicted of two counts for engaging in acts likely to defraud investors of a fund managed by the FMC (Fund A).  

In that case, the individual had sold two over-the-counter (OTC) bonds at lower prices from Fund A to another fund managed by the FMC (Fund B) in which he was the majority investor while knowing that there were earlier available bids at higher prices. The individual carried out his misconduct by first soliciting bids from various market participants via the Bloomberg chat messaging system. He then used lower bid prices as the reference prices to sell the two OTC bonds from Fund A to Fund B through an intermediary, instead of selling the bonds to a market participant who had offered higher prices, or using those higher bid prices as the reference prices to sell the OTC bonds to Fund B. The individual subsequently sold the two OTC bonds to the market at a profit and caused a loss of US$342,500 to Fund A’s investors.

After a 26-day trial, the individual was convicted and sentenced to six months’ imprisonment for fraudulent or deceptive conduct under Section 201(b) of the Securities and Futures Act 2001. He has filed an appeal against his conviction.

Priorities for 2025–26

Looking ahead, MAS has said it will be focusing on the following areas as its enforcement priorities: 

1. Market misconduct: MAS will continue to focus on pursuing manipulative conduct in the securities markets, which remains one of its evergreen priorities. 
2. Enforcing AML/CFT controls: MAS will focus on taking robust action where financial institutions have failed to comply with AML/CFT requirements. At the same time, it will look to provide financial institutions with comprehensive guidance on AML/CFT practices, deepen channels for data sharing among and with financial institutions, and review penalty frameworks to ensure that they remain proportionate and dissuasive. 
3. Building enforcement capabilities in the digital asset ecosystem: As the digital asset landscape continues to evolve, MAS has and will put in place regulations to address key risks arising from money laundering and terrorism financing, technology risks, and risks to consumers.

A copy of the Enforcement Report is available here. 

If you have any questions, please contact any one of the Sidley contacts listed below.