On Jun. 6, 2025, SIN MAS clarified regulatory regime for DTSP effective Jun. 30, 2025.
Clarifies scope of new regulation and transition requirements for DTSPs providing services relating to digital payment tokens and tokens of capital market products.
From Jun. 30, 2025, DTSPs providing services solely to customers outside Singapore re digital payment tokens and tokens of capital market products must obtain license.
SIN MAS set high licensing bar and will generally not issue licenses for offshore-only operations; money laundering risks higher in such business models where substantive regulated activity occurs outside Singapore, unable to effectively supervise providers.
DTSPs without license must cease regulated activities; providers serving customers in Singapore already subject to regulation with no changes to permitted activities.
Licensed providers serving Singapore customers may also provide services to offshore customers; existing reg framework continues to apply to Singapore-facing DTSPs.
Providers of services relating to tokens used only as utility tokens and governance tokens not subject to licensing or regulation under new regime, not impacted.
The existing DTSPs which are serving only customers outside Singapore are subsequently required to cease activity when the regime takes effect Jun. 30, 2025.
On May 30, SIN MAS issued guides, notices re digital token services.
SIN MAS issued guidelines, notices, forms for digital token service providers (DTSPs).
Guidelines and operational notices support the implementation of the Financial services and markets act 2022 regulatory framework, all effective from Jun. 30, 2025.
Follows SIN MAS May 2025 issued digital token service provider framework, #228597.
Guidelines
Guidelines on licensing for digital token service providers establish eligibility criteria and application procedures for digital token service providers under the act.
Guidelines to MAS notice FSM-N27 guides DTSPs on relevant AML/CFT requirements.
Notices
MAS notice FSM-N27 prevention of money laundering and countering the financing of terrorism sets requirements for digital token service providers to put in place robust controls to detect and deter illicit funds flow through Singapore's financial system.
MAS notice FSM-N28 reporting of suspicious activities and incidents of fraud sets requirements for digital token service providers to report suspicious activities or incidents of fraud which subsequently affect the safety, soundness or reputation.
MAS notice FSM-N29 submission of regulatory returns sets periodic regulatory reporting requirements for information related to licensees' digital token services.
MAS notice FSM-N30 technology risk management sets requirements for high level of reliability, availability and recoverability of critical IT systems and rollout of IT controls.
MAS notice FSM-N31 cyber hygiene sets cyber security rules re securing administrative accounts, applying security patching, setting baseline security standards, deploying network security devices, rolling out anti-malware, strengthening user authentication.
MAS notice FSM-N32 conduct sets conduct requirements for all regulated DTSPs.
MAS notice FSM-N33 disclosures and communications sets requirements for licensed DTSPs to provide certain disclosures to customers and potential customers.
MAS notice FSM-N34 specified matters and forms sets out regulatory forms and other administrative matters for digital token service providers; some forms specified below.
Forms
Form 3A - notification for appointment of appointed representative for licensed financial advisers, capital markets services licensees, banks, merchant banks, finance companies and insurers to notify SIN MAS of the appointment of representatives.
Form 3B - notification for appointment of provisional representative for licensed financial advisers, those exempt to notify SIN MAS of appointment of provisional reps.
Jun. 2025 Regulatory Clarification
On Jun. 6, 2025, SIN MAS clarified regulatory regime for DTSP effective Jun. 30, 2025.
Clarifies scope of new regulation and transition requirements for DTSPs providing services relating to digital payment tokens and tokens of capital market products.
From Jun. 30, 2025, DTSPs providing services solely to customers outside Singapore re digital payment tokens and tokens of capital market products must obtain license.
SIN MAS set high licensing bar and will generally not issue licenses for offshore-only operations; money laundering risks higher in such business models where substantive regulated activity occurs outside Singapore, unable to effectively supervise providers.
DTSPs without license must cease regulated activities; providers serving customers in Singapore already subject to regulation with no changes to permitted activities.
Licensed providers serving Singapore customers may also provide services to offshore customers; existing reg framework continues to apply to Singapore-facing DTSPs.
Providers of services relating to tokens used only as utility tokens and governance tokens not subject to licensing or regulation under new regime, not impacted.
The existing DTSPs which are serving only customers outside Singapore are subsequently required to cease activity when the regime takes effect Jun. 30, 2025.
Regulators
SIN MAS
Entity Types
B/D; MSB
Reference
PR 6/6/2025; Gd, Nt FSM-N27, FSM-N28, FSM-N29, FSM-N30, FSM-N31, FSM-N32, FSM-N33, FSM-N34, Form 3A, 3B, 5/30/2025
