‘Good’ regulation

Studied under David Jackman for the Diploma in Anti money-laundering (Module 4). See more about him at the end of this article.

It is my belief that a viable culture is vital for successful compliance/regulation. Hence, I am following up on his teachings on regulatory maturity (for possible further research). He states 4 stages/levels from the document Ethics for Regulators. (2016). https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/553826/David_Jackman_-_Ethics_for_regulators.pdf [UK government site].

I quote here the middle two stages and highlight a tiny bit of the final stage.


2. Procedural

  • Question: What do we have to do?
  • Unthinking, mechanical compliance
  • Dispersed decision-making /decision-sharing
  • By the book – black or white answers, ticking boxes
  • Bureaucratic and costly
  • Jobs-worth, inflexible application of principles
  • Culture of dependency on ppolicies and procedures
  • Outsourcing ‘conscience’

3. Embedding

  • Question: How can we be more effective?
  • Making the business case
  • Reputational repair or building trust
  • Helps in delivering on objectives, no just a cost
  • Part of decision-making at all levels
  • Staff give space to grow and trusted to make decisions
  • Judgment led
  • Public accountability and kpis
  • Long-term planning of developing principles

4. Values-led would involve:

  • Question: What do we want to do?
  • Good habit not audit driven


Related posts/Information:

Personal Data Protection Act 2012 (PDPA) – Singapore

Specimen Paper and Reflections – Anti Money Laundering


[from the main source article] “Regulatory Maturity:
1. Effectiveness of the regulatory body in delivering its stated objectives,
including the sophistication of the regulatory tools and techniques used
2. Maturity of the relationship between regulator and regulated, and other
3. Integrity of the internal regulatory culture, including the degree to which
the seven principles are embedded


David Jackman. Company Overview of Jersey International Business School. https://www.bloomberg.com/research/stocks/private/person.asp?personId=61166528&privcapId=102276049. Bloomberg.

Read an article written by him in 2012. David Jackman: Business won’t be ethical until it shares society’s values again. http://www.independent.co.uk/voices/commentators/david-jackman-business-wont-be-ethical-until-it-shares-societys-values-again-7965044.html. The Independent. UK.

David Jackman. Strategic Advisor. Meet the ICA Advisory Committee. https://www.int-comp.org/ica-advisory-committee/meet-the-ica-advisory-committee/. International Compliance Association. International Compliance Association. London.


Personal Data Protection Act 2012 (PDPA) – Singapore

This legislation oversees and manages the gathering, utilisation, dissemination, and the general “care of personal data.”

Officially, ‘personal data’ means:

data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access.

The National University of Singapore’s Data Protection Policy (2 Jul 2014) uses the same definition. Para 1.1 from the (seven page A4 sized) document gives instances of these like “names, identification numbers, contact information, medical records, photographs and video images.” By inference, nicknames even though fictitious can be used to identify an individual.

As of 26 Dec 2017, there have been 39 Data Protection Enforcement Cases (or decisions) by the Personal Data Protection Commission (PDPC) [set up on 2 January 2013]. At least 2 involved educational institutions.

For organisations, (at least) one data protection officer (DPO) is to be assigned to handle the below (non-exhaustive) list of duties:

  • “Ensure compliance of PDPA when developing and implementing policies and processes for handling personal data;”
  • Encourage a data protection culture among employees and inform stakeholders of personal data protection policies;
  • Respond to personal data protection related concerns and complaints;
  • Highlight risks related to personal data to the organisational management;
  • Communicate accordingly with the PDPC on data protection issues.

There are 9 principles (“Obligations”) for organisations. [The Second Schedule of the PDPA, ‘Collection of Personal Data without consent’, provides for exemptions.]

I briefly interpret/paraphrase/reproduce them below.

  • Consent (which can be disallowed by the individual)
  • Purpose Limitation (gather, utilise and disseminate data within ‘reasonable’ boundaries)
  • Notification (provider of data is to informed of the intent for the data)
  • Access and Correction
  • Accuracy (correct and complete)
  • Protection (execute reasonable efforts to pre-empt “unauthorised access, collection, use, disclosure or similar risks.”)
  • Retention Limitation (dispose securely such data or dissociate such data from persons when the business/legal purpose has expired)
  • Transfer Limitation (Transfer personal data to another country only according to the requirements prescribed under the regulations, to ensure that the standard of protection provided to the personal data so transferred will be comparable to the protection under the PDPA, unless exempted by the PDPC.)
  • Openness (Give information about organisational data protection policies, practices and complaints processes when requested.)


  1. Personal Data Protection Act 2012 (No. 26 of 2012). https://sso.agc.gov.sg/Act/PDPA2012 Republic of Singapore. Government Gazette, Acts Supplement. Singapore Statutes Online.
  2. Personal Data Protection Commission (PDPC). https://www.pdpc.gov.sg/

Leave – Singapore Employment Act

The below sites from the Singapore Government were sought (on 2 Nov 2017) in producing this post. [Again, bear in mind this is applicable to personnel under the Employment Act.]

(http://www.mom.gov.sg/employment-practices/leave/annual-leave/eligibility-and-entitlement) and;



Assuming that you have worked the equivalent of 3 months or more,  you would be legally allocated paid annual leave. For the first year worker, this is 7 days (though it can be pro-rated, if you have yet to complete the first year of service. After the 8th year, you are entitled to 14 days of paid annual leave.)

Loss/Forfeiture/Forgoing of Annual Leave

The entitlement can be forfeited:

  • due to absence from work without permission/reasonable excuse for more than 20% of the working days in the months or year
  • because of failure to consume leave within 12 months after the end of 12 months of continuous service
  • due to dismissal/firing from misconduct

An alternative solution is for your employer to encash the unconsumed leave at the gross rate of pay based on the last drawn salary.

Taking leave

Any leave taken will be considered a full-day of leave, even if it is taken on a half working day. Dependent on employer’s decision, it can nevertheless be counted as a half-day’s leave.

A related post would be Public Holidays – Singapore Employment Act.


Public Holidays – Singapore Employment Act

This site from the Singapore government was visited on 2 Nov 2017. (http://www.mom.gov.sg/employment-practices/public-holidays-entitlement-and-pay)

Under coverage by the Employment Act, one is entitled to 11 paid public holidays per calendar year. For those working less than 35 hours, one is legislated under the Employment of Part-Time Employees Regulations. Other exclusions from the Employment Act include salaries exceeding $4500 (manager/executive).

if a public holiday falls on a non-working day, you are entitled to another day off or one extra day’s salary in lieu of the public holiday at the gross rate of pay.”

If you work on a public holiday, by default, your employer should pay you. Alternatively, by mutual agreement, you can get a public holiday in lieu; or time off in lieu (applies only to managers and executives).

If you are required to work on a public holiday, you should be paid an extra day’s salary at the basic rate of pay.

  • Your monthly gross salary already includes payment for the holiday, so your employer need only pay you an additional day’s pay.
  • If you are absent without reason on the working day before or after the holiday, you are not entitled to the holiday pay. Your employer can therefore deduct one day’s pay at the gross rate from your monthly gross salary.”

The would be 3 variations as to how and what payment and paid holiday arrangements are executed dependent on whether the work was done on a work/non-work/rest day.


The Learning Brain (2013) – Notes – Ch.3

A separate return to The Learning Brain (2013) – Notes.

Our author points to how a brain matures by age 25. (Nonetheless, Hertz the car rental company as at 2017 “rents cars to those 20 years old and up.*”). The additional requirements are:

  • *… there is an added surcharge under some circumstances for renters between 20 and 24 years old. This added fee is subject to change based on the type and location of the car rental.
  • *Renters under 25 years old are subject to Age Differential Charge. Charge varies based on car class and renting location. Car class restrictions apply. Excludes certain corporate accounts. Excludes rentals in Australia, minimum age is 21. Additional terms and conditions apply, see Rental Terms for details.

See UNDER 25 CAR RENTAL | AVAILABLE AT HERTZ (2017). https://www.hertz.com.sg/rentacar/misc/index.jsp?targetPage=Hertz_Renting_to_Drivers_Under_25.jsp.

The minimum age for taxi drivers in Singapore is 30. [Minimum age of private-hire car drivers in the spotlight after fatal Uber accident. (13 Jul 2017). http://www.channelnewsasia.com/news/singapore/minimum-age-of-private-hire-car-drivers-in-the-spotlight-after-9027842]

The author truly put faith in his research by submitting a scientific opinion, along with 11 other neuroscientists, to the US Supreme Court for the case of TERRANCE JAMAR GRAHAM, PETITIONER v. FLORIDA. It posited that an ‘average’ teenager ‘cannot be expected to act with the same control or foresight as a mature adult.’ It is unclear if this had a significant impact on the ruling of 17 May 2010 of which we see below (from the Legal Information Institute, Cornell University Law School)

Justice Kennedy:

The Constitution prohibits the imposition of a life without parole sentence on a juvenile offender who did not commit homicide. A State need not guarantee the offender eventual release, but if it imposes a sentence of life it must provide him or her with some realistic opportunity to obtain release before the end of that term. The judgment of the First District Court of Appeal of Florida affirming Graham’s conviction is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.

It is so ordered.


A Theory of Justice – abstract

Through Raymond Wacks. (2017). Justice: a beginner’s guide. London. Oneworld. Chapter 5.

John Rawls in his own words [A Theory of Justice. (2002). Oxford University Press. p. 12.]

My aim is to present a conception of justice which generalises and carries to a higher level of abstraction the familiar theory of the social contract found, say in Locke, Rousseau and Kant. In order to do this we are not to think of the original contract as one to enter a particular society or set up a particular form of government. Rather, the guiding idea is that the principles of justice for the basic structure of society are the object of the original agreement. They are the principles that free and rational persons concerned to further their own interests would accept in an initial position of equality as defining the fundamental terms of their association. These principles are to regulate all further agreements; they specify the kinds of social cooperation that can be entered into and the forms of government that can be established. This way of regarding the principles of justice I shall call justice as fairness. 


Law & Health – Mobile/Hand/Cell phones

5 years on in two different cases, the first in the Supreme Court and the latter in a regional one (north Italian town Ivrea), mobile phone usage was deemed to have ‘causal link(s)‘ with brain tumours. [In effect, the Supreme Court judgment became the legal precedent.]


Cancer cells: Italian court rules ‘mobile phones can cause brain tumors’. (20 Oct 2012). RT News. (TV-Novosti) https://www.rt.com/news/italy-phone-causes-tumor-840/.

Italian court rules mobile phone caused tumour. (21 Apr 2017). Special Broadcasting Service (SBS). Australia. http://www.sbs.com.au/news/article/2017/04/21/italian-court-rules-mobile-phone-caused-tumour.

CBC Radio (Canada) through its show ‘The Current’ ran an episode entitled: Cellphone in your pocket? CBC’s Marketplace investigates why you might reconsider. (24 Mar 2017). http://www.cbc.ca/radio/thecurrent/the-current-for-march-24-2017-1.4038259/cellphone-in-your-pocket-cbc-s-marketplace-investigates-why-you-might-reconsider-1.4038287.