← Regulations / Singapore / Operating Models / Custodial SaaS

Custodial wallet / SaaS in Singapore

Hosted wallet provider that holds keys on behalf of end users, often white-labeled to businesses (custody as a service).

Conditional AI-Generated · Unreviewed

Custodial SaaS 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

  • DPT service providers must comply with MAS AML/CFT Notices PSN01 and PSN02 (amendments effective July 2025)
  • Customer due diligence (CDD) at onboarding and ongoing transaction monitoring required under PSN01/PSN02
  • Suspicious transaction reporting (STR) to MAS and Commercial Affairs Department
  • Travel Rule compliance for DPT transfers (receiving/sending DPTs)
  • The white-label SaaS provider (as the licensed DPT service provider) bears primary AML/CFT responsibility, though client obligations may be contractually allocated
  • No specific transaction thresholds stated in cited facts; standard MAS CDD thresholds likely apply (SGD 5,000 for occasional transactions under PSN01)

Key Restrictions

  • Must hold a Major Payment Institution (MPI) license with SGD 250,000 base capital (~$185K USD), or an SPI license with SGD 100,000 base capital (subject to SGD 3M single/SGD 6M aggregate monthly transaction limits)
  • Must have a Singapore-incorporated entity and resident presence
  • Customer assets must be held in a statutory trust (mandatory since 2024) — segregation is mandatory
  • Security deposits of SGD 100K–200K are required
  • Two-year track record for major roles (CEO, directors) is typically required
  • Marketing to the general public for crypto services is prohibited (MAS guidelines Jan 2022) — no incentive programs, no ATMs in public areas
  • If the wallet holds security tokens (SFA-covered assets), a separate Capital Markets Services (CMS) license for custodial services may be required under the Securities and Futures Act
  • MAS Technology Risk Management Guidelines (2021) apply — cybersecurity, data protection, operational resilience requirements

Key Risks

  • Very low approval rate for MPI licenses (only ~20-30 out of 170+ applications granted) — high regulatory gatekeeping risk
  • Regulatory ambiguity between PSA (DPT services) and SFA (custody of security tokens) — if underlying assets are security tokens, dual licensing may be required
  • MAS actively discourages retail crypto speculation; enforcement risk for perceived retail-facing marketing
  • No explicit proof-of-reserves or insurance requirements cited in the facts, but expectation management around asset safeguarding is high
  • White-label SaaS model creates ambiguity: the SaaS provider is the licensed entity bearing full AML/CFT liability, but may have limited control over the white-label client's end-user KYC/AML practices

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 90% confidence

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.

licensing 95% confidence

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.

licensing 93% confidence

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.

licensing 95% confidence

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.

licensing 92% confidence

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.

licensing 90% confidence

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.

licensing 90% confidence

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.

licensing 92% confidence

The Payment Services Act 2019 is the main Singapore statute for cryptocurrency services; section 2(1) defines a digital payment token as a digital representation of value expressed as a unit, not denominated in or pegged by its issuer to any currency, and intended as a public medium of exchange.

licensing 20% confidence

Dealing in DPTs (e.g., buying and selling on behalf of customers).

licensing 90% confidence

Providing a platform that allows persons to exchange digital payment tokens is a regulated DPT service under the Payment Services Act 2019, and from 4 April 2024 facilitating the exchange of DPTs is regulated even where the provider does not come into possession of the moneys or DPTs.

licensing 20% confidence

Receiving or sending DPTs (e.g., cross-border DPT transfers).

licensing 92% confidence

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.

licensing 20% confidence

Providing custodial services for security tokens.

Evidence fact sg.licensing.mas-amlcft-notices-eg-psn01 not found (may have been renamed).

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
medium

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

Conditional — custodial wallet / SaaS operators can serve Singapore residents under an MPI license (with SGD 250K capital, mandatory segregated statutory trust for customer assets, SGD 100K–200K security deposit, and full AML/CFT compliance under MAS Notices PSN01/PSN02), but the operator must be a Singapore-incorporated entity, faces a very low license approval rate, and must avoid marketing to the general public; if custody involves security tokens, additional CMS licensing under the SFA may apply.

Questions this verdict aims to answer

  • What custody license / qualified-custodian status applies?
  • What segregation, insurance, and proof-of-reserves rules apply?
  • What AML obligations attach to the SaaS vs the white-label client?