The Monetary Authority of Singapore (MAS) has launched a consultation paper on controls against market abuse. MAS is seeking to impose new requirements to improve controls and facilitate investigations in cases of market abuse. These new requirements aim to improve controls and facilitate investigations into cases of market abuse such as market manipulation and insider trading, to maintain a fair, orderly and transparent market.

MAS has identified four areas where requirements will be enhanced:

  1. Ultimate beneficial owners (“UBOs”) of orders and trades (“O&T”) executed in omnibus accounts (known as ‘Client Identification Rule’);
  2. Record-keeping of instructions received for broker-assisted O&T;
  3. Unique client device identifier for O&T executed via mobile trading applications; and
  4. Cash payments and payments by third parties (i.e. non-account holders) for the funding of customers’ accounts.

MAS proposes to introduce the following measures: 

  1.  Client identification rule where FIs must establish arrangements with its clients to facilitate the provision of UBO information to MAS or any other law enforcement agency, within five business days upon request.
  2. FIs to Record all communication between their trading representatives and the person instructing the O&T in customers’ account for any capital market products, even if such communication does not result in an actual transaction.
  3. All FIs to capture and record the Device ID for O&T executed via mobile trading applications.
  4. Augment the AML Notice by requiring FIs to maintain a centralized, electronic register of all payments received in cash or from third parties by the FIs into their customers’ accounts.


MAS Seeks comments on the proposed measures to be adopted and invites comments from all FIs and other interested parties to submit their comments by 05 September 2019. 


We, at Argus Global, are a team of consultants who specialize in Regulatory Compliance for Financial Institutions in Singapore that are regulated by MAS.  Argus shall be happy to collect your response and submit it on your behalf to the MAS before the deadline. We will be happy to answer your queries, whether specifically to this article or any other regulatory compliance hurdles you may face. Do reach out to us at

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