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Singapore MAS License

Singapore MAS License


As the most dynamic country in Southeast Asia, Singapore has also come to the forefront in the electronic asset industry, and its attitude towards digital currency has attracted much attention. The Payment Services Bill (PSB) is an Act to provide for the licensing and regulation of payment service providers, the oversight of payment systems, and connected matters. PSB was passed in Parliament on 14 January 2019. This regulation will make a big effect to digital currency exchange service provider, wallet service and OTC platforms.

PSA comprises of two (2) parallel regulatory frameworks – (a) a designation regime and (b) a licensing regime which allows the MAS to regulate a wide range of payment services in a way that matches the scope and scale of such services provided by each service provider. The payment services covered under each class of licence are broadly:
  • the money-changing licence;
  • the standard payment institution licence;
  • the major payment institution licence.


  • The money-changing licence is required where a licensee carries on a business of providing a money-changing service unless the licensee has a standard payment institution licence or major payment institution licence that allows such licensee to carry on money-changing services.

    The standard payment institution licence is required where the licensee carries on one of the payment services (save for money-changing service) or two or more of the payment services (including money-changing service):
    The specified thresholds refer to accepting, processing, or executing a monthly average of:
    Payment transactions up to S$3 million for any payment service; or

    Up to S$6 million for two or more payment services, in one calendar year.

    These thresholds do not apply to e-money account issuance services, i.e. account issuance services which offer payment accounts that store e-money, or e-money issuance services.Instead, such service providers will need to apply for a standard payment institution licence if they issue an average daily e-money float of up to S$5 million over a calendar year.

    The major payment institution licence is required where:
    the licensee carries on one or more of the payment services (save for money-changing service or e-money account issuance service) and the average of the total value of all payment transactions by the licensee in one (1) month exceeds S$3 million (or equivalent in foreign currency) for any one of the payment services or S$6 million (or equivalent in foreign currency) for 2 or more of those aforementioned payment services;

    the licensee carries on the business of providing e-money account issuance service and the average over a calendar year of total value in one day of all e-money stored in any payment account exceeds S$5 million (or equivalent in foreign currency); or

    (the licensee carries on the business of providing e-money issuance service and the average over a calendar year of the total value in one day of all specified e-money issued by the licensee exceeds S$5 million (or equivalent in foreign currency); and

    In respect of blockchain and FinTech activities, this Article will be focusing primarily on the standard and major payment institution licences.


    Compliance program:

    Licensee is required to develop and implement an anti-money laundering (AML) compliance program. The program should reasonably prevent individuals from conducting money laundering or to finance terrorist activities. Each program must be written and take into account the inherent risks, as well as:

  • Collect customer's identity information;
  • Establish and update internal policies and procedures to complete, review, submit and retain all reports and records required by applicable laws and regulations;
  • Monitor transactions and investigate any material deviations from normal activities;
  • Implement a records management system to properly store and retrieve documents, files, forms and logs;
  • Update risk assessments regularly;
  • Provide information to law enforcement agencies as required by applicable laws and regulations;
  • Compliance officers have the right to interact with law enforcement, which is involved in preventing money laundering, financing terrorism and other illegal activities.


  • Know your client:

    As a payment and exchange service business, you must verify the identity of clients for certain activities and transactions. Part of knowing your client includes feature to identify clients, as well as conducting certain additional activities as listed below:
  • Identification of the customer by obtaining certain information pertaining to the customer and, where the customer is not a natural person, certain other persons associated with that customer;
  • Verifying the identification information obtained;
  • Where the customer is not a natural person, identifying and verifying the identity of the natural persons appointed to act on the customer’s behalf;
  • Determining if there exists any beneficial owner and applying the identification and verification procedures to those beneficial owners;
  • Where business relations are to be established, obtaining information as to the nature and purpose of the intended business relations;
  • After business relations are established, conducting ongoing monitoring of business relations; and
  • Reviewing periodically the adequacy of customer information after business relations are established.


  • Legal Requirement

  • At least one natural person as shareholder
  • At least two directors, one local director (citizen, PR or employment pass)
  • Company secretary
  • Permanent place of business in Singapore with local staff
  • Compliance officer and staff
  • Audit requirement
  • Inspection/investigation by MAS
  • Technology risk management


  • All key personnel are required fit and proper.

    Minimum capital requirements:
    Standard payment license: S $ 100,000
    Major Payment License: S $ 250,000
    Deposit to MAS:
    Monthly average transaction volume is less than S $ 6 million: deposit of S $ 100,000
    In other cases: S $ 200,000

    Documentation Requirement:

  • Individual shareholder and director notarised copy of passport
  • Individual shareholder and director notarised copy of utility bills/ proof of address within three months
  • Shareholding company certificate, company registration and constitution
  • Shareholding company ultimate beneficial owner and director notarised copy of passport, utility bills/ proof of address within three months
  • Certificate of Incorporation
  • Company or group financial statements for the past three years
  • Organization Chart
  • Business plan
  • Shareholding Structure Diagram
  • Relevant compliance documents
  • Academic certificate and CV
  • Application form template

    UCG Services

  • Company formation
  • License application document preparation assistance
  • AML CTF program, compliance program and risk assessment
  • Provision of local compliance officer which is requested by MAS
  • Application lodgment to MAS
  • Maintanence after application success



  • Duration to set up: 3 month