Singapore, 19 September 2025… The Monetary Authority of Singapore (MAS) has issued a composition fine of $93,750 against Singlife Financial Advisers Pte. Ltd. (SFAPL), formerly known as Aviva Financial Advisers Pte Ltd (AFA), for failing to implement effective policies relating to recruitment of representatives, leading to inadequate supervision and training of representatives as well as breaches of the Financial Advisers Act (FAA) and the Financial Advisers Regulations (FAR)Section 38(4)(a) of the Financial Advisers Act (Cap. 110) and Regulation 14(1)(b)(i) of the Financial Advisers Regulations.

2 MAS also issued prohibition orders of up to four years against three individuals, formerly affiliated with AFA. Chee Boon Chai Lionel, former Chief Executive Officer (CEO), was issued a one-year prohibition order for failing to ensure AFA’s compliance with the FAA and FAR. Two former representatives of AFA were issued prohibition orders for their involvement in the breaches. One of these representatives had also taught other representatives to make false and/or misleading statements in the sales pitch of policies to prospective customers. The individuals are prohibited from providing any financial advisory service and from taking part in the management, acting as a director, or becoming a substantial shareholder of any financial advisory firm under the FAA. Five other individuals were issued reprimands. The individuals and the regulatory action taken against them are set out in the table below:

3 Each agency group in AFA consisted of 3 tiers of representatives. The lowest tier (Tier 1) representatives were supervised by Tier 2 representatives, who are in turn supervised by Tier 3 representatives (agency managers). The Life Insurance Association Singapore’s (LIA) Guidelines on Span of Control recommended that the number of representatives under each Tier 2 and Tier 3 representatives be capped, in order to ensure adequate supervision and training of the relevant representatives.

4 MAS’ investigation found that:

(a)  AFA allowed their Tier 3 representatives to recruit more Tier 1 representatives than they were allowed to supervise and to “park” the additional Tier 1 representatives under a Tier 2 representative, who would then be responsible for supervising and managing these Tier 1 representatives. However, AFA did not implement or ensure that its representatives complied with effective written policies on the practice of “parking” representatives, and on the supervision and management of the Tier 1 representatives.

(b)  Taking advantage of this lack of effective written policies, Mr Khoo and Mr Alvin Lee recruited more Tier 1 representatives than they were allowed to supervise, and “parked” their excess Tier 1 representatives under Ms Goh and Mr Tan. Mr Khoo and Mr Alvin Lee entered into private arrangements with Ms Goh and Mr Tan respectively, where it was agreed that Mr Khoo and Mr Alvin Lee would coach and supervise the Tier 1 representatives “parked” under Ms Goh and Mr Tan respectively. It was also agreed that Mr Khoo and Mr Alvin Lee would receive the variable income generated from sales made by the “parked” Tier 1 representatives while Ms Goh and Mr Tan would receive a fee for the arrangements.

(c)  As a result of these private arrangements, AFA failed to determine the remuneration of Mr Khoo, Mr Alvin Lee, Ms Goh and Mr Tan based on the performance of the Tier 1 representatives that they in fact supervised, in accordance with the Balanced Scorecard (BSC) Framework.

(d)  Mr Pang and Mr Yap were responsible as Tier 3 agency managers to supervise Ms Goh and Mr Tan. However, Mr Pang and Mr Yap left the supervision of Ms Goh and Mr Tan to Mr Khoo and Mr Alvin Lee.

(e)  Mr Khoo also taught some Tier 1 representatives, including Mr Derrick Lee, to make false and/or misleading statements in the sales pitch of a policy to prospective customers. Subsequently, in Mr Derrick Lee’s sales pitch to a prospective customer, he misrepresented an endowment policy by likening the returns under the policy to the interest generated under a bank savings account. In reality, unlike a bank savings account, the returns under the endowment policy were not guaranteed and the endowment policy did not allow the flexibility of withdrawal at any time.

5 Mr Chee was the CEO of AFA at the material time. MAS found that Mr Chee failed, as CEO of AFA, to take reasonable steps to secure AFA’s compliance with the FAA and the FAR. MAS further notes that Mr Chee was previously reprimanded by MAS in June 2021 for not putting in place compliance functions or arrangements to monitor an external consultant’s activities within AFA, which resulted in AFA breaching the BSC Framework.

6  The breaches were committed by AFA before AFA’s parent company, Aviva Ltd, merged with Singapore Life Pte Ltd in September 2020. MAS notes that following the merger of Aviva Ltd with Singapore Life Pte Ltd, SFAPL has put in place safeguards to prevent similar breaches of the FAA and FAR from reoccurring.

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Additional Information

Balanced Scorecard Requirements

MAS requires financial advisory (FA) firms to put in place a Balanced Scorecard (BSC) framework for remunerating their representatives and supervisors. Under the BSC framework, representatives will be assessed based on 4 non-sales key performance indicators (KPIs), namely (i) understanding a client’s needs; (ii) suitability of product recommendations; (iii) adequacy of information disclosure; and (iv) standards of professionalism and ethical conduct in relation to the provision of FA services. They will be assigned a BSC grading every quarter based on the number and severity of infractions uncovered from post-transaction sample checks by the Independent Sales Audit unit, mystery shopping surveys and customer complaints. The BSC grading will determine the amount of variable remuneration that the representative is entitled to in each quarter. A representative who is graded A in a quarter will be entitled to 100% of his or her remuneration in that quarter. Conversely, a representative who is graded E will either not receive any remuneration or will only be entitled to less than 25% of his remuneration for the same period. As supervisors play an important role in coaching and monitoring the conduct and performance of their representatives, their BSC grades and variable remuneration will also be affected if representatives under their supervision fail to meet the non-sales KPIs. More information on the BSC requirements can be found here .

Requirements to put in place compliance arrangements

The RM Guidelines provide guidance to FIs on sound and prudent internal control practices. FA firms are also required under regulation 14 of the Financial Advisers Regulations to put in place compliance arrangements to ensure they comply with the applicable legal and regulatory requirements. Effective compliance arrangements help protect customers’ interests and reduce the possibility of unexpected losses or damage. Please refer to the RM Guidelines here .

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