This page provides AWS financial institution customers with information about the legal and regulatory requirements in Singapore that may apply to their use of AWS services.
Regulations
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Can financial institutions use AWS?
Yes. Financial institutions in Singapore are permitted to use cloud services, provided that they comply with applicable legal and regulatory requirements, such as those described below.
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Who is the financial regulator?
The Monetary Authority of Singapore (MAS) regulates and supervises all financial institutions in Singapore, including banks, finance companies, insurers, money brokers, securities and futures and fund management, financial advisers, trust companies, payment and settlement systems, and finance companies.
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What regulations apply to financial institutions using AWS?
Financial institutions in Singapore may be subject to a number of different legal and regulatory requirements when they use cloud services. The MAS has published a number of guidelines that provide a framework for financial institutions in Singapore when they are planning to use cloud services. Key guidelines include the following:
- MAS Guidelines on Outsourcing - In effect until December 10th 2024
- MAS Guidelines on Outsourcing (Banks) - Effective on December 11th 2024
- MAS Notice 658 Management of Outsourced Relevant Services for Banks - Effective on December 11th 2024
- MAS Notice 1121 Management of Outsourced Relevant Services for Merchant Banks - Effective on December 11th 2024
- MAS Guidelines on Outsourcing (Financial Institutions other than Banks) - Effective on December 11th 2024
- Advisory on Addressing the Technology and Cyber Security Risks Associated with Public Cloud Adoption
The above framework covers a variety of contractual and operational areas, including due diligence, risk management, business continuity, and monitoring and oversight. The AWS whitepaper AWS User Guide to Financial Services Regulations and Guidelines in Singapore provides information on the applicable MAS guidelines that will help customers conduct due diligence on AWS with regard to IT security and risk management.
Customers that have questions about the applicable regulations, and how these may apply to their use of AWS services, can reach out to their account representative.
Regulations are changing rapidly in this space, and AWS is working to help customers proactively respond to new rules and guidelines. AWS encourages its financial institutions customers to obtain appropriate advice on their compliance with all regulatory and legal requirements that are relevant to their business, including other local regulations, guidelines and laws.
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Key considerations for financial institutions using AWS
AWS is committed to offering customers a strong compliance framework and advanced tools and security measures that customers can use to evaluate meet, and demonstrate compliance with applicable legal and regulatory requirements.
Financial institutions who are using or planning to use AWS services can take the following steps to better understand their compliance needs:
1. Consider the purpose of the workload(s) under consideration and the relevant categories of data in order to anticipate which legal and regulatory requirements may apply.
2. Assess the materiality or criticality of the relevant workload(s) in light of local requirements. For example, MAS regulated institutions should be prepared to demonstrate their observance of the MAS Guidelines on Outsourcing (Banks) - Effective on December 11th 2024 in relation to material workloads to the MAS.
3. Review the AWS Shared Responsibility Model and map AWS responsibilities and customer responsibilities according to each AWS service that will be used. Customers can also use AWS Artifact to access AWS’s audit reports and conduct their assessment of the control responsibilities.
4. Customers who have further questions about how AWS services can enable their security and compliance needs, or who would like more information, can contact their account representative.
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Key data privacy and protection considerations for financial institutions using AWS
Financial institutions in Singapore using AWS services should also consider applicable privacy requirements, including the Singapore Personal Data Protection Act (PDPA). More information on these requirements are included in the AWS whitepaper Using AWS in the Context of Singapore Privacy Considerations.
If customers process or are planning to process the personal data of data subjects in the European Union (EU), they should visit AWS’s General Data Protection Regulation (GDPR) Center. More information on these requirements is included in Navigating GDPR Compliance on AWS.
Resources
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Country-specific
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General
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Compliance Programs
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Country-specific
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Using AWS in the Context of Singapore Privacy Considerations
The following resources are available for download through AWS Artifact. Please note that an AWS account will be required to access AWS Artifact.
- MAS TRM Guidelines Workbook
- MAS Notice 655 - Cyber Hygiene - Workbook
- MTCS Certification and Self-Disclosure Form
- Outsourced Service Provider Audit Report (OSPAR)
- ABS Cloud Computing Implementation Guide 2.0 – Workbook
The following resources are publicly available:
AWS User Guide to Financial Services Regulations and Guidelines in SingaporeThis document provides information to assist customers whowant to use AWS to store or process content containing personal data, in the context of key privacy considerations and the Personal Data Protection Act 2012 (“PDPA”). It will help customers understand: The way AWS services operate, including how customers can address security and encrypt their content. The geographic locations where customers can choose to store content and other relevant considerations. The respective roles the customer and AWS each play in managing and securing content stored on AWS services.
This document provides information to helpregulated financial institutions (FIs) operating in Singapore as they accelerate their use of Amazon Web Services (AWS) Cloud services.
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General
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Payment Card Industry Data Security Standard (PCI DSS) 3.2.1 on AWSUsing AWS in the Context of Common Privacy and Data Protection Considerations
This guide provides customers with sufficient information to be able to plan for and document the Payment Card Industry Data Security Standard (PCI DSS) compliance of their AWS workloads. This includes the selection of controls that meet specific PCI DSS 3.2.1 requirements, planning of evidence gathering to meet assessment testing procedures, and explaining their control implementation to their PCI Qualified Security Assessor (QSA).
AWS Compliance Quick Reference GuideThis document provides information to assist customers who want to use AWS to store or process content containing personal data, in the context of common privacy and data protection considerations. It will help customers understand the way AWS services operate, including how customers can address security and encrypt their content. The geographic locations where customers can choose to store content and other relevant considerations. The respective roles the customer and AWS each play in managing and securing content stored on AWS services.
AWS Operational ResilienceAWS has many compliance-enabling features that you can use for your regulated workloads in the AWS cloud. These features allow you to achieve a higher level of security at scale. Cloud-based compliance offers a lower cost of entry, easier operations, and improved agility by providing more oversight, security control, and central automation.
Data Classification and Secure Cloud AdoptionThe purpose of this paper is to describe how AWS and our customers in the financial services industry achieve operational resilience using AWS services.
AWS Policy Perspectives: Data ResidencyThis paper provides insight into classification schemes for public and private organizations to leverage when moving data to the cloud. It identifies practices and models currently implemented by global first movers and early adopters, examines how implementation of these schemes can simplify cloud adoption, and recommends practices to harmonize national requirements to internationally recognized standards and frameworks.
AWS Risk and ComplianceThis paper addresses: The real and perceived security risks expressed by governments when they demand in-country data residency. Commercial, public sector, and economic impact of in-country data residency policies with a focus on government data. Considerations for governments to evaluate before enforcing requirements that can unintentionally limit public sector digital transformation goals leading to increased cybersecurity risk.
AWS Security Audit GuidelinesThis document is intended to provide information to assist AWS customers with integrating AWS into their existing control framework supporting their IT environment. This document includes a basic approach to evaluating AWS controls and provides information to assist customers with integrating control environments. This document also addresses AWS-specific information around general cloud computing compliance questions.
Guidelines for systematically reviewing and monitoring your AWS resources for security best practices.
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Compliance Programs
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MTCS Tier 1
ISO 9001
PCI DSS Level 1
OSPAR
ISO 27001
SOC
CSA
ISO 27017
GDPR
ISO 27018
We are continually adapting to evolving regulations. Check often for updates.
