by jiawen
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The Five MAS Safeguards
1. Choice of Digital Media
Financial institutions must ensure the platforms they use are appropriate for financial advertising.
- Maintain an approved list of suitable platforms and an exclusion list of those that do not meet standards.
- Consider reputation, track record, and whether financial ads are allowed.
- Ensure ads can be located, amended, or removed promptly if needed.
2. Characteristics, Risks and Disclosures
FIs must assess platform limitations and ensure important disclosures are clear and prominent.
- Each ad must be fair and balanced on its own.
- It is not acceptable to highlight benefits in one post while placing risks elsewhere.
- Disclose sponsorships, remuneration, conflicts of interest, and whether influencers are licensed.
- FIs remain responsible for influencer content, including opinions, and for re-posted testimonials.
3. Assessment and Selection of Digital Marketers
FIs must carefully select and train their digital marketers.
- Assess suitability based on qualifications, communication style, and track record.
- Address conflicts of interest.
- Provide policies, templates, and compliance training.
- Contracts with external marketers must set out obligations and conflict management measures.
4. Monitoring and Oversight
FIs must monitor all digital advertising activities — including those outsourced.
- Keep a register of campaigns, accounts used, and duration.
- Approve external accounts used for advertising.
- Deploy monitoring tools (e.g. web crawlers, social listening, online mystery shopping).
- Take immediate action on unauthorised ads: remove, alert customers, preserve evidence, and report if required.
5. Disciplinary Action
FIs must take disciplinary action against errant digital marketers.
- Internal staff: apply proportionate actions such as warnings, stricter monitoring, or suspension.
- Agencies: enforce penalties in contracts.
- Repeat offenders: escalate to prohibition from digital advertising.
What This Means for Financial Institutions?
These Guidelines mark a significant tightening of MAS’ expectations on digital marketing. With enforcement action already taken against some content creators in Singapore, MAS is signalling that compliance will be closely scrutinised.
To prepare for the March 2026 implementation, financial institutions can begin by reviewing their internal digital advertising policies and updating agreements with agencies and influencers to reflect compliance obligations. Strengthening oversight through registers and monitoring systems, as well as building awareness among both internal teams and external partners through training, will also support smoother adoption of the new requirements.
📖 References
Monetary Authority of Singapore (2025, September 25). Guidelines on Standards of Conduct for Digital Advertising Activities (FSG-03). https://www.mas.gov.sg/regulation/guidelines/guidelines-on-standards-of-conduct-for-digital-advertising-activities
Monetary Authority of Singapore (2025, September 25). MAS Introduces Initiatives to Promote Responsible Online Financial Content, Issues Advisory Letters to Content Creators. https://www.mas.gov.sg/news/media-releases/2025/initiatives-to-promote-responsible-online-financial-content
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