Get Ready to Comply With The Newest MAS Requirements with eeCheck

The Monetary Authority of Singapore (MAS) is taking a proactive stance in mitigating the risks of potential misconduct within the financial industry. To ensure adequate due diligence and to prevent the movement of “rolling bad apples”, MAS is proposing mandatory reference checks for prospective representatives, and is considering extending this requirement to other employees in the industry. This is in line with the international focus on preventing the movement of “bad apples”, as outlined in the toolkit published by the Financial Stability Board Working Group on Governance Frameworks. While the practice of conducting reference checks is not new in Singapore, differing standards have been observed. To ensure consistency and meaningful information exchange, MAS is proposing minimum mandatory information to be provided within a specified period of time. This proposal is intended to be applied on a prospective basis.


How Does the MAS

Mandate Reference Check Scheme Work?

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As a leading global background check firm with a strong presence in Singapore, eeCheck is well-equipped to assist your organization in complying with the MAS Mandate Reference Check Scheme. Our comprehensive services are designed to help you navigate the complex regulatory landscape and ensure that your organization remains in compliance with the latest requirements.

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What Are The Proposed Changes And How Will They Affect You?

Summary Chart

A wide range of financial institutions (see corresponding section)

Proposed to expand more than representatives to senior managers who may negatively impact a financial institution (see corresponding section).

5 Years

21 Calendar Days

  • Employment History
  • Compliance Record
  • Balanced Scorecard Rating (if applicable)
  • Persistency Ratio of Insurance Policies (if applicable)

A transitional period of 6 months after the Notice(s) issued

What Are The Proposed Changes And How Will They Affect You?

Scope of FIs

Because individuals who engage in misconduct can move between different sectors of the financial industry, it is necessary for all financial institutions to work together to prevent this risk. To address this issue, MAS is proposing that reference checks and responses to reference check requests be mandatory for a wide range of financial institutions.

Find out more in our MAS WhitePaper
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What Are The Proposed Changes And How Will They Affect You?

Scope of Employees

In summary, the requirements for financial institutions (FIs) to conduct reference checks and respond to reference check requests on their representatives are discussed in the Consultation Paper on “Revisions to Misconduct Reporting Requirements and Proposals to mandate Reference Checks for Representatives” issued in July 2018.

The paper also identifies senior managers as individuals whose misconduct can negatively impact an FI's soundness, reputation, customers' interests, or public confidence. Furthermore, MAS is considering two options for expanding the scope of employees that FIs need to perform reference checks and respond to reference check requests.

Option 1

FIs must perform reference checks on individuals in risk-taking functions, risk management and control functions, critical system administration, and those who can authorize or approve payments. Option 1 aligns with the scope of functions under the proposed Harmonized and Expanded Power to issue Prohibition Orders (POs).


Option 2

It is narrower, focusing only on functions that can cause or result in financial risks to FIs or customers, and excludes individuals responsible for operational risk, technology risk, legal risk, regulatory risk, or reputational risk.

Mandatory Information

Mandatory information to be provided for Reference Check by Financial Institutions

Information related to the individual’s employment history with the Financial Institution:

i. the duration of employment.
ii. the roles and job functions of the individual (including last position held); and
iii. the reason for the cessation of employment, including but not limited to the following:

– resignation.
– resignation by paying compensation in lieu of notice prior to or during investigation
– termination.
– dismissal; or
– expiry of contract.

The Financial Institution should obtain compliance records related to the individual’s fitness and propriety, unless doing so could risk tipping off the individual and compromising the integrity of ongoing investigations. These records should include information on:

i. Investigations that have concluded with reasonable grounds to believe that a wrongdoing has been committed, as well as the extent of consumer harm resulting from the wrongdoing (if applicable).
ii. Ongoing investigations and the extent of consumer harm resulting from substantiated wrongdoing.
iii. Instances where the Financial Institution has knowledge of, or reasonable grounds to believe that the individual has or may have breached legal or regulatory requirements while performing their duties as an employee of the Financial Institution, and the extent of consumer harm resulting from the incident.
iv. Disciplinary actions taken against the individual, or that would have been taken against them if they were still employed by the Financial Institution (if applicable).
v. Whether misconduct reports were filed against the individual with MAS, and if so, details on the nature of the misconduct committed and the extent of consumer harm resulting from the misconduct.

The FI should provide information on the individual’s most recent four balanced scorecard ratings, if applicable.

If available and applicable, the FI should provide information on the persistency ratio of any insurance policies sold by the individual, as well as the method used to calculate the ratio.

Key Implications from eeCheck

To comply with the upcoming mandatory reference check requirements, financial institutions must take action now. This includes reviewing existing HR policies and procedures, and making any necessary changes to ensure compliance with the new regulations within the required timeframe.

Financial institutions should consider establishing protocols for requesting the necessary information from previous employers. This includes identifying which employees require reference checks, ensuring that all necessary information is available to make these requests, revising the reference check questionnaire to comply with MAS’ requirements.

In addition to requesting information, financial institutions must also establish protocols for releasing information as previous employers. This includes implementing record-keeping and data release policies to ensure that only relevant and accurate information is shared, the process is smooth enough to be released according to the 21 calendar day requirement, and that all data protection and privacy regulations are followed.

To ensure compliance with the latest regulations, financial institutions must stay informed about any new guidance or directives from MAS. This includes the mentality for the corresponding teams to make necessary changes to policies and procedures in accordance with any updates.

The new mandatory reference check requirements should be integrated with the overall employment screening process. This means identifying how the new reference check processes fit into the screening process and ensuring that all relevant employees are involved in the process.

Financial institutions may benefit from engaging a professional employment background check vendor such as eeVoices to help navigate the new requirements. We can help to provide valuable insights into best practices, streamline the process, and ensure compliance with the regulations.

Why eeCheck?

We combine local and global experience in screening, HR and compliance

As a prominent global employment screening firm with a significant presence and diverse client base across Singapore and various countries in Asia, it is imperative for us to conduct in-depth research and gain a comprehensive understanding of the latest and forthcoming regulatory obligations pertinent to our field of expertise. In this regard, we are pleased to present a whitepaper that outlines information and our insights on the “Public Consultation on Proposals to Mandate Reference Checks” issued by the Monetary Authority of Singapore (MAS) on May 14, 2021. This whitepaper serves as a valuable resource for our clients and stakeholders, providing a succinct summary of the consultation’s contents and our professional perspectives on its potential implications for our industry.

Full Compliance

Compliance and data security at global industry standard.


Consultative approach to help set up the entire process.

HR Focused

Workflows and solutions designed for HR and Recruitment.


Easy to use and can integrate with different workflows.

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    MAS Mandate Reference Check