ENTRY 01 · COMPLIANCE · STATUS: ACTIVE ▮
Everything defensible.
I'm the sole compliance officer of a Singapore Licensed Fund Management Company serving accredited and institutional investors. Sole means sole: if it touches MAS, the SFA, AML/CFT or an auditor, it crosses my desk. My standard is simple: every control I run can show who did it, when, what was checked, what was found, and who approved it.
| # | Function | Key instruments | Cadence |
|---|---|---|---|
| 01 | Licensing & conduct | SFA · SF(LCB)R · SF(FMR)R · SFA04-G05 | continuous / annual |
| 02 | AML/CFT | SFA04-N02 · CDSA · TSOFA | onboarding / continuous / annual EWRA |
| 03 | Representatives & fit-and-proper | FSG-G01 · SFA04-N22 · Forms 3A / 16 | per appointment / annual |
| 04 | Risk & compliance arrangements | SFA04-G05 · RM Guidelines | continuous / annual |
| 05 | Technology & cyber | TRM Guidelines · Cyber Hygiene Notice · BCM | continuous / ≥annual tests |
| 06 | Outsourcing | Outsourcing Guidelines (non-bank FIs) | continuous / annual review |
| 07 | VCC | VCC Act · VCC-N01 · IID 04/2025 | ongoing / annual return |
| 08 | Submissions & returns | SF(FMR)R Forms 1-2 · QIE · MASNET | quarterly / annual |
| 09 | PAD, dealing & conflicts | SFA conduct + firm policy | per request / annual |
| 10 | Recordkeeping & audit | SF(LCB)R · SFA04-N02 (5y) | continuous / annual audit |
The actual map is longer and lives where it belongs, inside the firm.
Show the work.
"We did it" is not a control. Who did it, when, what was checked, what was found, who approved it: that's a control.
Primary sources only.
I keep an offline library of MAS instruments and read the notice, not the summary of the notice. Versions matter; summaries drift.
Build the register before you need it.
Every recurring obligation gets a tracker, an owner, an expiry and a reminder. Before the first deadline, not after the first miss.
Train people like they'll be tested.
Because they will: by MAS, by auditors, or by the first live incident. Staff training is a control, not a formality.
Credentials on file.
CV ON REQUEST → ENTRY 06ICA Advanced Certificate in Governance, Risk and Compliance
International Compliance Association, awarded with Merit.
IBF Qualified in Compliance (Level 1)
The Institute of Banking and Finance, Singapore.
BIT, Computer Networks & Security
Monash University, Melbourne. The reason the compliance function has its own software.