About the role
We are hiring a senior investment compliance lead to own the second-line framework across the full regulated product set of both entities — capital markets products, funds and VCC structures, custody, and tokenised / RWA products — as well as the exchange, surveillance and derivatives obligations that sit alongside them. Both entities deal exclusively with accredited and institutional investors; there is no retail distribution, and investor classification is itself a control this role owns. This is a build role: the successful candidate will be designing and defending controls, not maintaining someone else's.
Key responsibilities
3.1 Regulatory framework and licensing
- Own the compliance framework, policies and procedures for both entities and keep them mapped to the Securities and Futures Act 2001 and the Securities and Futures (Licensing and Conduct of Business) Regulations.
- Maintain the regulatory obligations register and licence condition tracker; run horizon scanning across MAS notices, guidelines and consultations, and convert changes into control changes with named owners and deadlines.
- Manage licence variations, new regulated activity applications, and MAS notifications for appointments, representatives and changes in business.
- Own fit and proper assessments under the MAS Guidelines on Fit and Proper Criteria (FSGG01) and representative competency requirements under MAS Notice SFA-04-N22, including the Register of Representatives.
- Own capital adequacy monitoring and breach reporting under MAS Notice SFA-04-N13, working with Finance.
3.2 Product and investment compliance
- Act as second-line approver on the New Product Approval process for capital markets products, funds, tokenised products and derivatives.
- Run product due diligence, classification and approval, and sign off offer documents, term sheets, risk disclosures and marketing material. Because both entities deal only with accredited and institutional investors, the retail suitability regime under MAS Notice SFA-04-N12 operates as a boundary control: this role owns the classification work and the escalation path if any product, channel or client type would take the business outside that perimeter.
- Own investor eligibility and classification — accredited, expert and institutional investor status, opt-in and opt-out handling, periodic re-verification, and the section 309B exemptions relied on for offers — together with restricted scheme obligations, including the annual CISNet declaration under MAS Notice SFA-13-N02.
- Design and supervise investment restriction and mandate monitoring for the fund management business: pre- and post-trade limits, concentration and liquidity, side letters, valuation, fair allocation and cross-trades.
- Own best execution and order handling controls under MAS Notice SFA-04-N16 (intermediary) and MAS Notice SFA-02-N03 (market operator), including periodic execution quality review.
- Own personal account dealing, conflicts of interest, information barriers and research conflicts (MAS Guidelines SFA-04-G06), gifts and entertainment, and outside business interests.
3.3 Custody and client asset protection
- Oversee the customer money and customer assets framework under the SF(LCB)R — segregation, trust account arrangements, reconciliation cycles, deficiency escalation and reporting.
- Oversee digital asset custody controls, including MPC wallet governance, key management, address whitelisting, and due diligence on third-party custodians and sub-custodians.
- Approve material outsourcing and service provider arrangements against the MAS Guidelines on Outsourcing for Financial Institutions (other than banks).
3.4 Exchange (RMO) obligations and market conduct
- Own RMO compliance: participant admission, and ongoing supervision of market participants compliance with the market rules and Part XII of the SFA under MAS Notice SFA-02-N02; listing and delisting notification and controls under MAS Notice SFA-02-N01.
- Own the market surveillance and exchange transaction monitoring framework end to end — scenario design and calibration, alert triage and disposition quality, investigations, and escalation.
- Own the AML/CFT obligations applicable to the market operator under MAS Notice SFA02-N05.
- Own suspicious transaction reporting to the STRO and the separate capital markets report to MAS under MAS Notice CMGN01.
3.5 Financial crime interface
- Apply MAS Notice SFA04-N02 and its Guidelines across capital markets intermediary activity, and MAS Notice SFA04-N20 across fund management activity — ensuring investor and counterparty CDD, source of wealth and source of funds, the enterprise-wide risk assessment and customer risk assessment are fit for the products offered.
- Ensure sanctions screening and asset freezing obligations under MAS Notices SNR-N01 and SNR-N03 are met at investor, counterparty and on-chain level, in partnership with the Group financial crime compliance team.
- Ensure on-chain KYT and value transfer / Travel Rule controls extend appropriately to tokenised products and digital asset custody.
3.6 Governance, regulatory engagement and reporting
- Maintain the compliance monitoring programme, annual testing plan, and issue and remediation tracker; report to the Board, Risk Management Committee and ManCo.
- Act as the primary day-to-day contact for MAS on investment compliance matters — inspections, thematic reviews, information requests, and incident and breach notifications.
- Support the annual audit cycle, external assurance reviews and internal audit; own management responses to compliance findings.
- Embed the MAS Guidelines on Individual Accountability and Conduct (accountability maps, senior managers and material risk personnel) and the Guidelines on Risk Management Practices across the investment businesses.
- Deliver targeted compliance training to front office, product, fund management and operations teams.
3.7 Leadership
- Build and lead the investment compliance team; set standards, priorities and development paths.
- Partner credibly with trading, product, fund management, technology and operations — a commercial, solution-oriented second line that says no with a reasoned alternative rather than simply blocking.
Requirements
- 8+ years in compliance, legal or regulatory roles in a MAS-regulated capital markets, brokerage, exchange, asset management or private banking environment, with at least 3 years at manager level or above.
- Deep working knowledge of the SFA 2001 and the SF(LCB)R, and of the MAS notices and guidelines applicable to CMS licensees — capital adequacy, sale of investment products, execution of customers orders, representative competency, and AML/CFT.
- Demonstrated ownership of product compliance for capital markets products — CIS and funds, structured notes, securities and fixed income — covering product approval, product classification and investor eligibility. Experience in an accredited / institutional-only distribution model is preferred over a retail background.
- Practical experience in at least two of: fund management compliance (mandate and restriction monitoring); custody and client asset segregation; exchange or market operator compliance; tokenised or digital asset products.
- Hands-on experience running transaction monitoring or market surveillance — designing scenarios, calibrating thresholds, and defending the outcome to a regulator or auditor.
- Track record of direct MAS engagement: licence applications or variations, inspections, thematic reviews, or breach and incident notifications.
- Strong drafting — policies, procedures, regulatory submissions and board papers.
- Degree in law, finance, accounting or a related discipline. Relevant CMFAS modules and a professional certification (ICA, ACAMS, CFA or equivalent) are an advantage.
- Meets the MAS fit and proper criteria under FSGG01.
Preferred
- Derivatives. Exchange-traded and OTC exposure, including margin and collateral, clearing arrangements, and trade reporting under the Securities and Futures (Reporting of Derivatives Contracts) Regulations. A strong plus.
- ETF creation and redemption. Authorised participant arrangements, in-kind and cash basket mechanics, NAV / iNAV and primary market controls.
- Corporate finance. Capital raising, placements and listing advisory — deal conflicts, wall-crossing, restricted and watch lists, and information barriers. A plus.
- VCC. Umbrella and sub-fund structures, segregation of sub-fund assets, re-domiciliation and transfer of registration, and VCC-specific fit and proper and lodgement obligations under the Variable Capital Companies Act 2018.
- RWA tokenisation and digital assets. Security token characterisation, on-chain analytics and screening, digital asset custody, and the DPT / Payment Services Act interface.
- Multi-jurisdictional exposure. Hong Kong SFC, ADGM / FSRA, or Canadian regimes, given the Group's international footprint.
- Mandarin. Working proficiency for engagement with China-based teams, funds and portfolio companies.
Competencies we are screening for
- Sound judgement under commercial pressure — able to hold a position with the front office and with senior management, and to evidence the reasoning.
- Comfortable in a scaling, product-led environment where the framework is still being built.
- Fluent across both traditional capital markets and digital asset markets, and able to move between the two without treating either as exotic.
- Credible with regulators, the board and the trading floor alike.
