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The Singapore regulator has extended the scope of cross-border money transfer, domestic money transfer and digital payment token services under the Payment Services Act. The amendments, published on the 2nd April, came into effect from 4th April. Firms now caught under the expanded scope will need to notify the MAS by 3rd May for a temporary exemption.
Activities now in scope of the MAS Payment Services Act
The amendments mean the following ‘new’ activities are regulated under the Payment Services Act 2019 (PS Act). It’s worth quickly checking through the changes to see if your firm is now in scope.
Cross-border money transfer: Any service of arranging for the transmission of money from any country or territory to another country or territory, whether as principal or agent.
Domestic money transfer: Service of accepting money for the purpose of executing, or arranging for the execution of, a payment transaction between a payer in Singapore and a payee in Singapore (except in the case where both the payer and the payee are financial institutions).
DPT service: Provision of custodial services for digital payment tokens (DPTs), and facilitation of the transmission of DPTs between accounts and facilitation of the exchange of DPTs. This is the case even where the service provider does not come into possession of the moneys or DPTs.
(You can read the full scope of ‘new’ regulated activities in the First Schedule to the PS Act.)
Timeline for affected firms
- By 3 May 2024: A notification must be sent to the MAS for the purpose of temporary exemption from holding a licence under the PS Act, and to continue operations on a temporarily exempt basis under the Transitional Regulations 2024.
- Before 4 October 2024: An application for the appropriate licence under the PS Act must be made to the regulator.
- Before 4 January 2025: An attestation report on the firm’s business activities and compliance with AML/CFT and user protection requirements should be completed by an external auditor.
How we can help
We have supported a number of firms with their payment services licences and are able to assess whether your business operations will come under the expanded scope of regulated activities.
Our team can support you with any notifications to the MAS and send the appropriate PS licence application for you on your behalf.
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