MAS Technology Risk Management Independent Review — AKATI Sekurity
+Secure | Governance & Compliance

MAS Technology Risk Compliance Review

Independent Assessment Against MAS Technology Risk Management Guidelines

The Monetary Authority of Singapore's Technology Risk Management Guidelines (January 2021) set out risk management principles and best practices for all regulated financial institutions to establish sound technology risk governance, maintain cyber resilience, and safeguard the confidentiality, integrity, and availability of IT systems and data.

AKATI Sekurity provides independent, third-party compliance reviews across the full 15-section scope of the MAS TRM Guidelines — from board oversight and SDLC security through to cyber incident management and cloud risk. Non-observance impacts MAS's risk assessment of your institution.

January 2021
15 Sections
Best Practice Framework
All MAS-Regulated FIs

Not legally binding — but observance directly impacts MAS's risk assessment of your institution. The TRM Guidelines supersede the 2013 edition and complement MAS Notices on Cyber Hygiene (CMG-N02, CMG-N03) which carry statutory penalties. Financial institutions jointly regulated by other regulators must comply with the more stringent requirements.

Jan 2021
Who Must Comply

MAS-Regulated Financial Institutions

The MAS TRM Guidelines apply to all financial institutions regulated by MAS. Implementation must be proportionate to the size, complexity, and risk profile of each institution's operations.

Banks
Merchant Banks
Finance Companies
Insurers
Insurance Brokers
Capital Markets Services Licensees
Financial Advisers
Payment Service Providers
Approved Exchanges
Clearing Houses
Trade Repositories
Central Depositories
Trust Companies
Money Changers & Remittance
Regulatory Architecture

13 Compliance Domains

The MAS TRM Guidelines span 13 substantive sections (§3–§15). Select any domain below to explore the key requirements AKATI Sekurity assesses during an independent compliance review.

3Governance & Oversight
4IT Project Management
5Software Development
6IT Service Management
7System Reliability
8Infrastructure Security
9Data & Asset Management
10Access Control
11Online Financial Services
12Payment Card Security
13Cyber Security Management
14Cyber Security Assessment
15Cyber Incident Management
Section 3

Technology Risk Governance & Oversight

Board and senior management responsibilities, policies, information asset management, third-party oversight, security awareness training, and the enterprise risk management framework.

  • Board and senior management establish and maintain a TRM Framework
  • Appoint CIO and CISO (or equivalent) with requisite experience and expertise
  • Policies, standards, and procedures reviewed regularly against evolving threat landscape
  • Comprehensive information asset inventory: data, hardware, software — classified by criticality
  • Third-party due diligence, contractual controls, ongoing monitoring, and exit strategies
  • Annual security awareness training for all staff including board and senior management
  • Enterprise risk management framework integrating technology risk identification and assessment
  • Clear risk appetite, risk tolerance, and reporting lines from operational to board level
Section 4

IT Project Management & Security-by-Design

Structured project management for technology initiatives with security embedded from inception through deployment.

  • Detailed IT project plans with scope, milestones, deliverables, and defined roles
  • Project risk assessment covering delivery timeline, budget, quality, and security impact
  • Security-by-Design: security specifications built into every phase of the SDLC
  • Post-implementation review for all critical technology projects
  • Independent quality assurance and security testing before production deployment
  • Change management with risk and impact analysis, rollback plans, and approval processes
Section 5

Software Application Development & Management

Secure coding, source code review, application security testing, API security, and management of third-party and open-source software.

  • SDLC framework with continuous security evaluation at each development phase
  • Secure coding standards and mandatory source code review for critical applications
  • Application security testing: SAST, DAST, and dependency scanning
  • API security: authentication, rate limiting, input validation, and encryption
  • Third-party and open-source software vetting with vulnerability tracking
  • Cryptographic standards and key management for data protection
  • Separation of development, testing, and production environments
  • Patch management for application components and third-party libraries
Section 6

IT Service Management

System configuration, change management, patch management, technology refresh, and capacity planning to maintain stable and secure operations.

  • Standardised system configuration with hardened security baselines
  • Change management: risk assessment, approval, testing, rollback, and audit trail
  • Patch management with timely deployment based on severity and criticality
  • Technology obsolescence monitoring: EOL/EOS tracking and refresh planning
  • Capacity planning and performance monitoring to prevent service degradation
  • Configuration management database (CMDB) with accurate asset inventory
Section 7

System Reliability, Availability & Recoverability

Business continuity, disaster recovery, data backup, and system resilience to ensure critical financial services remain available.

  • Business impact analysis (BIA) identifying critical business functions and RTOs
  • Disaster recovery plan with clearly defined recovery procedures and responsibilities
  • DR testing at least annually with documented results and remediation of gaps
  • Data backup strategy with regular testing to verify successful restoration
  • System redundancy and failover for critical infrastructure components
  • Data centre physical security, environmental controls, and resilience measures
  • Cloud service availability and recovery requirements aligned with BIA
Section 8

Operational Infrastructure Security Management

Network security, endpoint protection, virtualisation, IoT, BYOD, and emerging technology controls.

  • Network architecture with defence-in-depth: firewalls, IDS/IPS, segmentation
  • Endpoint protection: anti-malware, device management, and security monitoring
  • Virtualisation security: hypervisor hardening, VM isolation, resource controls
  • IoT device security: inventory, authentication, firmware updates, network isolation
  • BYOD policy with data separation, remote wipe, and access controls
  • Email and web security: filtering, sandboxing, and phishing protection
Section 9

Data & Infrastructure Asset Management

Data classification, data loss prevention, encryption, data retention, disposal, and secure management of information assets throughout their lifecycle.

  • Data classification scheme: confidential, restricted, internal, public
  • Data loss prevention (DLP) for data in-use, in-motion, and at-rest
  • Encryption for sensitive data at rest and in transit using strong cryptographic standards
  • Data retention policies aligned with regulatory and business requirements
  • Secure data disposal and media sanitisation with documented procedures
  • Information asset inventory linked to risk assessment and ownership
Section 10

Access Control

Identity management, authentication, privilege access management, and audit trail for all system and data access.

  • User access provisioning, modification, and revocation based on least privilege
  • Multi-factor authentication (MFA) for sensitive systems and remote access
  • Privileged access management (PAM) with session monitoring and time-bound access
  • Regular access rights review and recertification by data/system owners
  • Password policies: complexity, rotation, and protection against credential attacks
  • Audit logging of all access events with tamper-proof log storage and regular review
Section 11

Online Financial Services

Security of internet-facing financial services including online banking, trading platforms, and mobile applications.

  • Two-factor authentication for online customer accounts and high-risk transactions
  • Transaction signing and verification for fund transfers and payment instructions
  • Session management: timeout, re-authentication, and concurrent session controls
  • Secure mobile application development with code obfuscation and integrity checks
  • Customer notification for sensitive account activities and transactions
  • Fraud detection and monitoring for online and mobile channels
Section 12

Payment Card Security

Security controls for payment card operations aligned with industry standards.

  • Compliance with Payment Card Industry Data Security Standard (PCI DSS)
  • Card data encryption and tokenisation to minimise exposure of cardholder data
  • Point-of-sale terminal security and tamper detection
  • Fraud monitoring and anomaly detection for card transactions
  • Secure key management for payment cryptographic operations
Section 13

Cyber Security Management

Cyber threat intelligence, security operations, vulnerability management, and proactive defence against advanced cyber threats.

  • Cyber threat intelligence: collection, analysis, and sharing within financial ecosystem
  • Security operations centre (SOC) with 24/7 monitoring and alerting
  • SIEM deployment for log correlation, anomaly detection, and incident prioritisation
  • Vulnerability management: scanning, risk-based prioritisation, and timely remediation
  • Advanced persistent threat (APT) detection and response capabilities
  • Cyber security strategy and roadmap reviewed by board and senior management
Section 14

Cyber Security Assessment

Vulnerability assessment, penetration testing, red teaming, and adversarial attack simulation exercises to validate cyber defences.

  • Vulnerability assessment and penetration testing (VAPT) on critical systems at least annually
  • Adversarial attack simulation: red team exercises simulating real-world attacker TTPs
  • Scenario-based cyber exercises and cyber drills testing response capabilities
  • Remediation tracking for all issues identified from assessments and exercises
  • Independent assessment by qualified third-party security professionals
  • Results reported to board and senior management with prioritised remediation plans
Section 15

Cyber Incident Management

Incident detection, response, recovery, root cause analysis, and regulatory notification obligations.

  • Cyber incident response plan with defined roles, escalation paths, and communication protocols
  • Incident classification and severity framework for prioritised response
  • Containment, eradication, and recovery procedures for each incident category
  • Root cause analysis and lessons learned process after every significant incident
  • MAS notification requirements for material cyber incidents and technology disruptions
  • Regular incident response testing through tabletop exercises and simulations
AKATI Sekurity Services

How We Help You Comply

AKATI Sekurity delivers the independent assessments, testing, and advisory services that MAS-regulated financial institutions need to demonstrate alignment with the TRM Guidelines.

Compliance

MAS TRM Gap Analysis

Comprehensive review against all 13 substantive sections. Findings mapped to specific MAS TRM paragraphs with prioritised remediation timelines.

Cybersecurity

VAPT & Red Team Assessment

Vulnerability assessment, penetration testing, and adversarial attack simulation per Section 14 — testing your defences against real-world attacker TTPs.

Operations

24/7 SOC & Threat Intelligence

Managed Security Operations Centre with SIEM, threat intelligence, and incident coordination per Section 13 requirements.

Advisory

Cloud & Third-Party Risk

Cloud adoption risk assessment, service provider due diligence, ongoing monitoring, and exit strategy design per Section 3.4 requirements.

Governance

TRM Framework Development

Design and implementation of TRM Framework — governance, risk management, SDLC security, and access controls aligned to all 15 sections.

Response

Incident Response & Forensics

Cyber incident investigation, containment, recovery, and MAS notification support per Section 15 requirements. Digital forensics and root cause analysis.

Why AKATI Sekurity

Independent. Competent. Proven.

MAS expects financial institutions to engage qualified, independent assessors. AKATI Sekurity meets every threshold — with deep financial services experience across Southeast Asia including Singapore.

Financial Sector Expertise

Experience with banks, insurers, capital markets firms, payment service providers, and fintech platforms regulated by MAS.

Full 15-Section Coverage

Single engagement partner for governance review, VAPT, red teaming, SOC, cloud advisory, incident response, and TRM Framework development.

Certified & Independent

QSA, ASV, CREST-approved, and ISO 27001 certified. Independent from your technology operations — objective assessment without conflicts.

MAS-Ready Reporting

Every finding mapped to specific MAS TRM section and paragraph. Audit-ready documentation that demonstrates alignment and prioritises remediation.

Next Step

Strengthen Your MAS TRM Alignment

Observance of MAS TRM Guidelines directly impacts MAS's risk assessment of your institution. Do not wait for a regulatory review to uncover gaps. Contact AKATI Sekurity for an independent compliance assessment.