Singapore MAS Executive Director (Investment Intermediaries) Teo Kok Ming Keynote Speech at 11th Regulatory Forum (11/7/25): 1) Fund Managers Need to Adopt Robust Risk Management Practices to Safeguard Interests of Investors in Times of Uncertainty, 2) Liquidity Risk Management (LRM) is Key for Collect Investment Schemes Particularly Open-Ended Funds, 3) Will Update 2018 Guidelines on Liquidity Risk Management Practices for Fund Management Companies (Categorization of Funds by Liquidity & Redemption Terms, Fund Managers Access to Liquidity Management Tools, Enhanced Governance Standards & Disclosures), 4) Commitment to Develop Innovative Solutions for Industry Such as Variable Capital Company (VCC) Launched in 2020, 5) Review of VCCs Highlighted Lacked of Proper Custody Arrangements & Importance of Compliance with Anti-Money Laundering Framework & Controls, 6) New Quarterly Survey Starting from 2025 2H as Regulators Require Data & Insights to Effectively Monitor Risks & Trends, 7) Concerns on Cyberattacks, Impersonations & Scams
4th July | Hong Kong
Monetary Authority of Singapore (MAS) Executive Director (Investment Intermediaries) Teo Kok Ming keynote speech at the 11th Regulatory Forum (11/7/25) in Singapore, with key highlights including 1) Fund managers need to adopt robust risk management practices to safeguard interests of investors in times of uncertainty, 2) Liquidity Risk Management (LRM) is key for collect investment schemes particularly open-ended funds, 3) Will update 2018 Guidelines on Liquidity Risk Management Practices for fund management companies (Categorization of funds by liquidity & redemption terms, fund managers access to liquidity management tools, enhanced governance standards & disclosures), 4) Commitment to develop innovative solutions for industry such as Variable Capital Company (VCC) launched in 2020, 5) Review of VCCs highlighted lacked of proper custody arrangements & importance of compliance with anti-money laundering framework & controls, 6) New quarterly survey starting from 2025 2H as regulators require data & insights to effectively monitor risks & trends, 7) Concerns on cyberattacks, impersonations & scams. See below for full speech:
“ Singapore MAS Executive Director (Investment Intermediaries) Teo Kok Ming Keynote Speech at 11th Regulatory Forum (11/7/25): 1) Fund Managers Need to Adopt Robust Risk Management Practices to Safeguard Interests of Investors in Times of Uncertainty, 2) Liquidity Risk Management (LRM) is Key for Collect Investment Schemes Particularly Open-Ended Funds, 3) Will Update 2018 Guidelines on Liquidity Risk Management Practices for Fund Management Companies (Categorization of Funds by Liquidity & Redemption Terms, Fund Managers Access to Liquidity Management Tools, Enhanced Governance Standards & Disclosures), 4) Commitment to Develop Innovative Solutions for Industry Such as Variable Capital Company (VCC) Launched in 2020, 5) Review of VCCs Highlighted Lacked of Proper Custody Arrangements & Importance of Compliance with Anti-Money Laundering Framework & Controls, 6) New Quarterly Survey Starting from 2025 2H as Regulators Require Data & Insights to Effectively Monitor Risks & Trends, 7) Concerns on Cyberattacks, Impersonations & Scams “
Singapore MAS Executive Director (Investment Intermediaries) Teo Kok Ming Keynote Speech at 11th Regulatory Forum (11/7/25): 1) Fund Managers Need to Adopt Robust Risk Management Practices to Safeguard Interests of Investors in Times of Uncertainty, 2) Liquidity Risk Management (LRM) is Key for Collect Investment Schemes Particularly Open-Ended Funds, 3) Will Update 2018 Guidelines on Liquidity Risk Management Practices for Fund Management Companies (Categorization of Funds by Liquidity & Redemption Terms, Fund Managers Access to Liquidity Management Tools, Enhanced Governance Standards & Disclosures), 4) Commitment to Develop Innovative Solutions for Industry Such as Variable Capital Company (VCC) Launched in 2020, 5) Review of VCCs Highlighted Lacked of Proper Custody Arrangements & Importance of Compliance with Anti-Money Laundering Framework & Controls, 6) New Quarterly Survey Starting from 2025 2H as Regulators Require Data & Insights to Effectively Monitor Risks & Trends, 7) Concerns on Cyberattacks, Impersonations & Scams
“Resilience and Adaptability in an Ever-Changing Fund Management Industry” – Keynote Speech by Mr Teo Kok Ming, Executive Director (Investment Intermediaries), Monetary Authority of Singapore, at the Investment Management Association of Singapore’s 11th Regulatory Forum on 2 July 2025
- Ms Carmen Wee, IMAS Chief Executive Officer
- Panel Speakers
- Members of IMAS
- Ladies and Gentlemen
Resilience despite uncertainties
1. Good afternoon and thank you for inviting me to this year’s forum.
2. 2025 has been characterised by significant uncertainty in the global macro landscape.
- Geopolitical tensions and conflicts persist in Eastern Europe and the Middle East, with no clear signs of resolution.
- The unexpected announcement of tariffs earlier this year raised the risk of trade wars, disrupted supply chains, and led to volatility spikes in financial markets.
- These developments not only affect the confidence of businesses and consumers in the real economy but also challenge fund managers worldwide to cope with the unpredictability.
3. Singapore’s fund management sector has remained relatively resilient. During a turbulent month of April, we were glad to see that most of our fund managers were able to maintain orderly operations, meet margin calls promptly and handle redemptions effectively.
4. A close partnership between MAS and the industry has proven invaluable during these challenging times. This collaboration remains crucial as we:
- Monitor new and evolving risks;
- Weave in new practices to strengthen our defences against emerging risks; and
- Work together to build a more resilient and sustainable industry amidst global economic headwinds.
5. Against this backdrop, I will cover four key areas this afternoon.
- First, I will touch on how we can foster resilience through enhanced risk management practices – specifically on upcoming changes to the liquidity risk management guidelines for open-ended funds.
- Second, I will share some observations and supervisory expectations regarding the governance and management of Variable Capital Companies (VCCs).
- Third, I will outline some changes to our supervisory approach, focusing on our data collection initiatives.
- Finally, to raise awareness and vigilance within our industry, I will share some observations on instances where our fund managers have been targeted by cyberattacks and impersonation scammers, along with lessons that can be learned from these incidents.
Fostering resilience through enhanced risk management practices – updates to Guidelines on Liquidity Risk Management Practices for Fund Management Companies
6. As markets become more unpredictable, fund managers need to adopt robust risk management practices to safeguard the interests of investors in times of uncertainty.
7. Liquidity Risk Management (LRM) is key to ensuring orderly functioning of collective investment schemes, particularly Open-ended Funds.
- This has been an area of focus for the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO), both organisations of which MAS is a member.
- In 2023, FSB published its Revised Policy Recommendations to Address Structural Vulnerabilities from Liquidity Mismatch in Open-ended Funds[1]. IOSCO followed up by publishing the Final Report on Revised Recommendations for Liquidity Risk Management for Collective Investment Schemes[2], alongside its Implementation Guidance[3] in May this year.
8. We intend to align our expectations with FSB’s and IOSCO’s recommendations and guidance by updating our 2018 Guidelines on Liquidity Risk Management Practices for Fund Management Companies. We will consult on the revised guidance later this year, focusing on the following three key areas:
- First, the introduction of a categorization approach, under which funds would be grouped based on the underlying assets’ liquidity. This approach aims to promote better alignment between the liquidity of the assets held in funds with the funds’ redemption terms and conditions;
- Second, placing greater emphasis on fund managers’ access to a broader set of liquidity management tools (LMTs) such as anti-dilution tools (ADTs) which include, among others, swing pricing and anti-dilution levy; and
- Third, enhanced governance standards to ensure clear decision-making process on the use of LMTs, including clear disclosures on the objectives and operations of such tools.
9. We believe that the revisions, when adopted by the industry, will further strengthen existing liquidity risk management practices in preparation for future episodes of market volatility. We look forward to receiving feedback from IMAS and its members when we consult on the revised LRM guidance.
Governance and management of Variable Capital Companies – observations and areas of improvement
10. Strong governance practices form the bedrock of resilience in the fund management sector. The Variable Capital Company (VCC) framework, launched in 2020, has become one of Singapore’s key differentiators as a global asset management hub. It also reflects our commitment to develop innovative solutions to meet the evolving needs of the industry.
11. Last week, we published a circular outlining key observations and findings from our 2024 thematic review of VCCs. I would like to take the opportunity to share two key observations and expectations regarding the governance and management of VCCs.
12. First, on custody arrangements. Our thematic review revealed several instances where VCCs lacked proper custody arrangements for assets such as listed equities and fixed income instruments. I want to reiterate that except for private equity or venture capital investments that are exclusively offered to accredited or institutional investors, VCC managers must establish independent custody arrangements for their assets under management.
13. Second, on Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) framework and controls. We have established comprehensive requirements to maintain the integrity of our financial system. Our recent review highlighted three key observations:
- One, VCCs must implement robust controls and processes in compliance with their AML/CFT obligations, including those outlined in the MAS notices and regulations specific to VCCs.
- Two, it is crucial to understand that while Eligible Financial Institutions (EFIs) may be appointed to handle these matters, the ultimate responsibility lies with the VCC directors. They must exercise effective oversight to ensure thorough customer due diligence, accurate beneficial ownership records, and enhanced screening for high-risk customers.
- Three, we want to emphasise the importance of regular training for directors and EFIs in money laundering and terrorism financing risk management, along with maintaining constant vigilance and being alert to emerging risk typologies in the sector.
14. All VCC managers should take the opportunity to conduct a thorough review of their operations against the observations highlighted in the circular and ensure that gaps are closed.
Revisiting our supervisory approach – changes to data collection initiatives for fund management companies
15. Just as fund managers need agility and robust monitoring processes, regulators require timely data and insights to effectively monitor risks and trends, and if necessary, intervene to safeguard financial stability and protect investors’ interests.
- International regulatory bodies such as the FSB and IOSCO are focused on addressing systemic risks posed by the Nonbank Financial Intermediation (NBFI) sector, of which fund management companies represent a significant proportion of the entities in scope.
- Given the sector’s size, diversity of entities, and close linkages with the rest of the financial system, regulators need to identify appropriate data and metrics that will help uncover potential risks and their transmission channels.
16. There will be strong impetus for regulators, including MAS, to review their data collection frameworks in the short to medium term.
- Currently, licensed fund managers file returns under various regulations and notices pursuant to the Securities and Futures Act 2001, with the latest notice (SFA 04-N23) covering daily position data of Authorised Collective Investment Schemes excluding REITs. This daily data collection was operationalised earlier this year, representing an important leap in our surveillance capabilities.
- For funds and accounts that do not fall under the Authorised scheme, MAS continues to rely on the annual Fund Management Risk Assessment Questionnaire.
- While the annual survey provides invaluable insights, its relative infrequency means the data is dated and does not support effective surveillance and timely intervention.
17. We are therefore planning to implement a shortened and streamlined survey that will collect standardised data across all fund strategy types on a quarterly basis.
- This new survey will provide more timely and comparable insights into funds’ risk profiles.
- Data that we do not require as frequently for surveillance will continue to be collected annually.
- These streamlined surveys will replace the lengthy annual Fund Management Risk Assessment Questionnaire.
18. We recognise that data collection imposes costs on the industry. We will balance these costs against the need to have timelier data for our active surveillance and for early intervention. To minimise the reporting burden, we will:
- Limit the scope of quarterly data collection, and avoid duplicating data already collected through other channels such as the Fund Data Submission for Authorised schemes;
- Standardise the data collected for different fund strategy types to reduce reporting effort for fund managers that manage a variety of fund types;
- Implement an AUM reporting threshold to significantly reduce reporting burden; and
- Offer the option for:
- Manual entry on an online portal for fund managers managing fewer funds; and
- Formatted data file submission for fund managers managing numerous funds.
19. We intend to roll out this initiative in phases, beginning with the collection of a small set of metrics in H2 2025, followed by the full implementation in early 2026.
20. We will be engaging with industry players and associations, including IMAS, to introduce the new data collection framework and trial the new platform.
- We understand that such transitions require adequate preparation time, and we are committed to working closely with the industry to develop practical solutions.
- Looking ahead, we are exploring the possibility of sharing aggregated insights from this data with the industry and welcome suggestions on what information would be most valuable to market participants.
- We encourage ongoing feedback and suggestions to ensure that this initiative benefits not just MAS, but all our regulated fund managers as well.
Vigilance against malicious actors – cyberattacks and impersonation scammers
21. Lastly, I wish to draw attention to instances where fund management companies have been targeted by malicious actors through cyberattacks and impersonation scams.
22. We are concerned that cyberattacks, such as ransomware, disrupt operations and may compromise confidential stakeholder information.
- Fund managers should review their compliance with the Notice on Cyber Hygiene (FSM-N22) to protect their own interests as well as those of investors.
- The age-old proverb “prevention is better than cure” rings true. As perpetrators work to exploit new vulnerabilities, we must remain vigilant by regularly reviewing the security of our systems and addressing any identified weaknesses.
23. On impersonation, while we often hear of banks and government officials being impersonated by scammers, fund management companies are increasingly being targeted. Vulnerable members of the public have fallen prey to these scams, with some losing their life savings. This issue is not unique to Singapore but is a global concern, particularly prevalent in well-regulated jurisdictions where scammers exploit the public’s trust in regulated financial institutions.
24. The scam modality is common amongst the cases that we have come across.
- The scammer targets a specific fund management company by creating a website or application with an identical or similar name, copying many elements from the legitimate fund manager’s website.
- The scammer advertises investment products on social media, promising high returns with low risk.
- Victims are often directed to contact agents via WhatsApp or Telegram. These agents pose as employees of the fund management company, sometimes providing doctored staff passes to appear legitimate.
- Victims are then prompted to transfer money to the scammer, after which the funds dissipate and become unrecoverable.
25. When scammers impersonate a legitimate fund management company, they can damage its reputation and erode public trust. Such cases are on the rise, and it is therefore important that fund management companies stay vigilant and consider adopting the following good practices:
- Conduct periodic online scans to detect if your entity is being impersonated;
- If you discover that your entity is being impersonated, consider posting an advisory on your public channels to inform your investors or the public on how to verify that they are interacting with the legitimate entity; and
- Inform the authorities by filing a police report and notifying your MAS Officer-in-Charge. We will assess the feedback received and, where appropriate, list the impersonating entity on the Investor Alert List. We have done so and will continue to list impersonators and their associated communication channels used to perpetrate the scams on the Investor Alert List.
26. Combating scams is an ongoing, nationwide effort. We all have a part to play in safeguarding the high level of trust the public places in our industry.In this regard, I wish to commend IMAS for publishing an infographic on its website to help the public identify investment scams.
Conclusion
27. In closing, we are navigating through extremely challenging times, but I remain confident in our collective ability to adapt and emerge stronger.
28. The strengthening of liquidity risk management practices and internal controls, enhanced insights through streamlined data collection, and our continued vigilance against malicious actors will fortify our position as a trusted fund management hub. Let us work together to maintain Singapore’s reputation as a robust, innovative, and secure fund management centre.
29. I wish everyone a fruitful discussion this afternoon.
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