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On-shore VASP in Singapore

Locally-incorporated VASP that operates under full local jurisdiction, holding all required licenses and registrations.

Conditional AI-Generated · Unreviewed

On-shore VASP 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

  • Must comply with MAS AML/CFT Notices PSN01 and PSN02 (amendments effective July 2025)
  • Customer due diligence (CDD) and ongoing monitoring required per MAS notices
  • Travel Rule applies: must obtain, verify, and transmit originator and beneficiary information for DPT transfers of SGD 1,500 or more
  • Originator information: name, account number, physical address, national identity number (or customer ID), date and place of birth
  • Beneficiary information: name and account number
  • Information must be transmitted immediately and securely with the DPT transfer; if technically infeasible, by other means within reasonable time
  • Suspicious transaction reporting (STR) obligations to MAS
  • No specific AML/CFT threshold for general CDD — applies to all DPT service activities
  • Supervised by MAS for AML/CFT compliance

Key Restrictions

  • MAS explicitly discourages retail crypto speculation — marketing to general public prohibited (since Jan 2022)
  • No incentive programs (e.g., referral bonuses) for DPT services
  • No ATMs in public areas for DPT services
  • Must be a Singapore-incorporated entity
  • Customer asset segregation mandatory (statutory trust since 2024)
  • Security deposits of SGD 100K–200K required for custody activities
  • SPI license has transaction limits: SGD 3M single / SGD 6M aggregate monthly
  • Stablecoin 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 from 170+ applications) — significant uncertainty of obtaining license
  • MAS active enforcement against unlicensed and non-compliant DPT service providers
  • Regulatory ambiguity around treatment of novel token types (utility tokens, NFTs) under PSA vs SFA
  • No capital gains tax for individuals, but IRAS may recharacterize frequent trading as taxable business income — tax risk for operators who also trade
  • Marketing and promotion restrictions severely limit customer acquisition strategies

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 90% confidence

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.

licensing 20% confidence

Monetary Authority of Singapore (MAS): This is the central bank and integrated financial regulator of Singapore. MAS is the primary body responsible for regulating all digital asset and crypto-related activities, issuing licenses, and enforcing compliance with financial regulations.

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 75% confidence

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).

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

licensing 20% confidence

These notices lay out the specific Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) requirements for financial institutions, including DPT service providers.

travel-rule 92% confidence

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).

travel-rule 90% confidence

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).

travel-rule 90% confidence

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).

travel-rule 88% confidence

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.

travel-rule 90% confidence

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.

travel-rule 88% confidence

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).

travel-rule 90% confidence

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.

travel-rule 82% confidence

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).

travel-rule 20% confidence

Effective Date: January 28, 2020.

travel-rule 20% confidence

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).

travel-rule 85% confidence

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.

Evidence fact sg.tax not found (may have been renamed).

Evidence fact sg.tax.for-businesses-companies-and-sole not found (may have been renamed).

tax 90% confidence

Under IRAS's e-Tax Guide on digital tokens (30 January 2026), a gain on disposal of payment tokens is taxable income when the disposal is revenue in nature under the badges of trade, for example when the taxpayer is a trader in payment tokens (para 5.7, Annex A); a company that mines is regarded as carrying on a business of mining and is taxed on disposal of the mined tokens.

tax 80% confidence

No capital gains tax applies to gains from selling or disposing of crypto held as a capital asset (e.g., long-term investments by individuals).

Evidence fact sg.tax.digital-payment-tokens-dpts not found (may have been renamed).

tax 90% confidence

From 1 January 2020, a token qualifying as a digital payment token for GST (expressed as a unit, fungible, not denominated in or pegged by its issuer to any currency, and a medium of exchange accepted by the public without substantial restrictions) is outside GST when used as payment, as a disregarded supply; exchanging it for fiat currency or other digital payment tokens, and lending it, are exempt supplies.

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 — an on-shore VASP in Singapore must obtain an MPI license (or SPI license with transaction limits) under the Payment Services Act 2019, be a Singapore-incorporated entity with SGD 250,000 base capital (MPI), comply with MAS AML/CFT Notices PSN01/PSN02 including Travel Rule at SGD 1,500 threshold, observe strict marketing restrictions, and face a highly competitive licensing process with low approval rates.

Questions this verdict aims to answer

  • What license(s) are required to operate locally?
  • What capital, governance, and reporting obligations apply?
  • What is the application process and timeline?