Centralized exchange in Singapore
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is conditionally permitted in Singapore with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- MAS AML/CFT Notices PSN01 and PSN02 apply (amendments effective July 2025), requiring comprehensive AML/CFT programs including customer due diligence, transaction monitoring, and suspicious transaction reporting to MAS.
- Travel Rule applies for DPT transfers ≥ SGD 1,500 — must obtain and transmit originator info (name, account number, physical address, national ID or customer ID, date/place of birth) and beneficiary info (name, account number) immediately and securely with the transfer.
- Non-custodial wallet withdrawals exceeding SGD 20,000 monthly may require additional verification (Satoshi Test).
- Security deposits required (SGD 100,000–200,000) as part of AML/safeguarding framework.
- MAS is the AML/CFT supervisor — enforcement actions can include fines and license revocation.
Key Restrictions
- Must hold an MPI license (SGD 250,000 base capital) or SPI license (SGD 100,000 base capital with transaction limits of SGD 3M single/SGD 6M aggregate) under the Payment Services Act 2019.
- Customer asset segregation mandatory under statutory trust arrangement (since 2024) — custody is regulated under the DPT MPI license.
- MAS prohibits marketing or advertising DPT services to the general public (Jan 2022) — no incentive programs, no public-area ATMs.
- Security tokens (qualifying as capital markets products under SFA) require separate CMS license and SGX rules may apply if listed.
- Must comply with MAS Technology Risk Management Guidelines (2021) on cybersecurity, data protection, and operational resilience.
- Stablecoin-related services must comply with MAS stablecoin framework — issuers must maintain 100%+ reserves in cash/equivalents at SG-licensed institutions.
Key Risks
- Very low approval rate for MPI licenses — ~20-30 full licenses granted out of 170+ applications — significant licensing timeline and uncertainty.
- MAS explicitly discourages retail crypto speculation; enforcement risk for perceived public marketing or incentivizing retail participation.
- Double-regulation risk if tokens cross the line into security tokens (SFA applies alongside PSA), requiring both MPI and CMS licenses.
- Travel rule compliance is technically complex for withdrawals to non-custodial wallets; penalties for non-compliance can include fines and license revocation.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
MAS licenses payment service providers, including DPT service providers, under the Payment Services Act 2019 (standard payment institution, major payment institution and money-changing licences), imposes AML/CFT requirements on DPT licensees through Notice PSN02, and requires DPT licensees to comply with Notice FSM-N13 on technology risk management from 6 November 2024.
The Payment Services Act 2019 (Act 2 of 2019) licenses digital payment token services through standard and major payment institution licences; it commenced on 28 January 2020, and Act 1 of 2021 widened its DPT scope with effect from 4 April 2024.
The Securities and Futures Act 2001 governs digital tokens that are capital markets products, and a person carrying on a regulated activity in such tokens must hold a capital markets services licence granted under section 86 unless exempt.
MAS Notice PSN02, issued 2 April 2024 under section 16 of the Financial Services and Markets Act 2022 and in force from 4 April 2024, sets the AML/CFT requirements for Payment Services Act licensees providing a digital payment token service; its latest amendment, dated 30 June 2025, took effect on 1 July 2025.
MAS published its Technology Risk Management Guidelines (now listed as Guidelines on Risk Management Practices – Technology Risk) on 18 January 2021; they set non-binding technology risk principles for financial institutions, including payment institutions, covering technology risk governance, IT resilience, data and infrastructure security and cyber security operations.
Crypto service providers in Singapore are licensed under the Payment Services Act 2019; as of 14 October 2026 the MAS directory lists 38 major payment institutions for DPT services and no standard payment institutions. Base capital is S$250,000 for an MPI and S$100,000 for an SPI, which is capped at S$3 million monthly for one service or S$6 million for two or more.
Providing custodial services for digital payment tokens became a regulated DPT service under the Payment Services Act from 4 April 2024; regulations requiring DPT service providers to segregate customer assets in a trust account took effect six months later. All 38 DPT licensees in the MAS Financial Institutions Directory hold major payment institution licences, which require S$100,000 or S$200,000 security.
A crypto exchange serving Singapore customers is licensed as a digital payment token service under the Payment Services Act 2019; MAS's 17 January 2022 guidelines bar DPT marketing in public areas, including physical crypto ATMs, and its 23 November 2023 measures bar offering retail customers incentives to trade.
Issuing a token is not one of the digital payment token services MAS lists under the Payment Services Act 2019; an offer or issue of digital tokens is regulated under the Securities and Futures Act where the tokens are capital markets products (MAS Guide to Digital Token Offerings, para 2.1).
The Securities and Futures Act 2001 regulates digital tokens that are capital markets products, which the Act defines as securities, units in a collective investment scheme, derivatives contracts, spot foreign exchange contracts for leveraged foreign exchange trading and other prescribed products.
Singapore applies the travel rule to DPT value transfers through MAS Notice PSN02 ¶13: transfers above S$1,500 must carry full originator information (¶13.6), and transfers at or below S$1,500 carry names plus account or reference numbers (¶13.4).
Under MAS Notice PSN02 ¶13, an ordering DPT service provider must identify the originator, include originator and beneficiary information with each value transfer, and must not execute or arrange the transfer if it cannot comply (¶13.11).
MAS Notice PSN02 ¶13 applies to all DPT value transfers: at or below S$1,500 the message must carry originator and beneficiary names and account or unique reference numbers (¶13.4); above S$1,500 the originator must also be verified and further originator information included (¶13.6).
Evidence fact sg.travel-rule.information-to-be-transmitted not found (may have been renamed).
For DPT value transfers above S$1,500, MAS Notice PSN02 ¶13.6 requires the originator name and account or unique reference number plus any one of: residential or registered address, an identification or registration number, or date and place of birth or incorporation.
MAS Notice PSN02 ¶13.4(c)–(d) requires the beneficiary name and the beneficiary account number, or a unique transaction reference number where no account exists, to accompany every DPT value transfer.
MAS Notice PSN02 ¶13.9 requires all originator and beneficiary information collected by the ordering institution to be immediately and securely submitted to the beneficiary institution; where technical limitations stop the information travelling, the intermediary institution must keep it for at least five years (¶13.18).
The travel rule for Singapore DPT service providers is set out in MAS Notice PSN02 ¶13 (Value Transfers), in the version dated 2 April 2024 and last revised 30 June 2025.
The travel rule has bound Singapore DPT service providers since 28 January 2020, when MAS Notice PSN02 (dated 5 December 2019, value transfers at ¶13) took effect; the current notice applies to every Payment Services Act licensee carrying on a DPT service business (¶1.1).
Effective Date: January 28, 2020.
Threshold Amounts: Applies to virtual asset transfers ≥ S$1,500 (approximately US$1,000 equivalent), requiring VASPs to collect and share sender/recipient personally identifiable information (PII).
MAS Notice PSN02 applies to every Payment Services Act licensee providing a DPT service (¶1.1); the MAS Financial Institutions Directory listed 38 major payment institutions licensed for DPT service on 14 October 2026, and PSN02 ¶6.27 requires enhanced risk mitigation for transfers to or from entities that are not regulated financial institutions.
Penalties for Non-Compliance: Not explicitly detailed in sources, but non-compliance violates MAS regulations under the PSA, subjecting providers to enforcement actions by MAS (e.g., fines, license revocation).
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a centralized exchange operating in Singapore must obtain an MPI license (or SPI license with transaction limits) under the Payment Services Act 2019, establish a Singapore-incorporated entity, maintain mandatory customer asset segregation under statutory trust, comply with MAS AML/CFT notices and the Travel Rule (SGD 1,500 threshold), adhere to marketing restrictions prohibiting public solicitation, and meet MAS Technology Risk Management Guidelines.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?