Regulations for Digital Asset license in Singapore

Singapore’s cryptocurrency framework is regulated by the Monetary Authority of Singapore (MAS), which ensures businesses comply with strict anti-money laundering (AML) and counter-terrorist financing (CFT) laws. These regulations protect the financial ecosystem from illicit activities and promote transparency and security.

The regulatory framework ensures stability and legal compliance within the Digital Asset Sector. Businesses seeking a digital payment token license (DPT) must adhere to stringent guidelines set by MAS, covering areas such as financial reporting, cybersecurity standards, and consumer protection. Below are the key regulatory requirements for obtaining a digital asset license in Singapore.

1. Registration and Licensing

1. Registration and Licensing

  • Crypto-related businesses in Singapore are required to obtain a Payment Services License under the Payment Services Act (PSA), regulated by the Monetary Authority of Singapore (MAS). This license is essential for activities such as cryptocurrency exchanges, digital token payments, and custodial wallet services. The specific licensing requirements depend on the types of services offered, including standard or major payment institutions. MAS ensures that licensed companies comply with anti-money laundering (AML) and counter-terrorist financing (CFT) measures to safeguard the financial system.
3. Financial Reporting and Auditing

3. Financial Reporting and Auditing

  • Cryptocurrency companies in Singapore must undergo regular financial audits by independent auditors to ensure compliance with MAS standards. They are also required to submit regular reports on financial performance to maintain transparency and meet regulatory obligations.
2. Anti-Money Laundering (AML) and Know Your Customer (KYC)

2. Anti-Money Laundering (AML) and Know Your Customer (KYC)

  • In Singapore, businesses involved in cryptocurrency activities must adhere to the Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations enforced by the Monetary Authority of Singapore (MAS). These regulations include customer identification, continuous monitoring of financial transactions, and timely reporting to regulatory authorities.
  • MAS sets guidelines in PSN01 and PSN02 for AML and KYC compliance. PSN01 focuses on transaction monitoring and reporting suspicious activities, while PSN02 emphasizes customer due diligence, ensuring identity verification of clients and beneficial owners.
4. Consumer Protection

4. Consumer Protection

  • Cryptocurrency businesses in Singapore are mandated to maintain transparent communication with consumers about the services they offer, including the associated fees, risks, and potential liabilities linked to digital assets. In accordance with regulatory standards, companies must implement secure, insured custodial services to protect consumer funds. Ensuring that consumers are well-informed about these protective measures fosters trust and helps safeguard assets in the digital economy.
5. Cybersecurity Standards

5. Cybersecurity Standards

  • Businesses must implement stringent cybersecurity protocols, including encryption, two-factor authentication, regular security audits, and compliance with the Personal Data Protection Act (PDPA).
  • In the event of a cybersecurity breach, companies must promptly notify MAS and take immediate corrective measures to minimize damage, as outlined in PSN03. Businesses must assess and report any data breaches that cause significant harm within three days to ensure minimal impact.
  • Companies must comply with the PDPA’s rules on transferring personal data internationally, ensuring that any data transferred outside Singapore is accorded the same level of protection as within the country
6. Operational, Risk, and Governance Requirements

6. Operational, Risk, and Governance Requirements

  • Capital Requirements: To obtain a Payment Services License in Singapore, companies must meet the minimum capital requirements based on the license type. For standard payment institutions, the minimum capital is SGD 100,000, while for major payment institutions, it is SGD 250,000. These requirements ensure financial stability and the ability to cover operational risks.
  • Internal Controls: Businesses are required to establish strong internal control systems to mitigate operational risks and maintain regulatory compliance. This includes having well-defined governance frameworks, risk management policies, and internal audits to prevent financial crimes, including money laundering and fraud.
  • Record-Keeping: Cryptocurrency companies are obligated to maintain detailed records of all transactions and communications for transparency and accountability. These records must be accessible to regulatory authorities for a specified period, usually not less than 5 years.
7. International Cooperation and Regulatory Compliance

7. International Cooperation and Regulatory Compliance

Singapore collaborates globally to align cryptocurrency regulations, working with organizations like the Financial Action Task Force (FATF) to combat cross-border financial crimes.

The Monetary Authority of Singapore (MAS) engages in information exchange with international regulators to strengthen anti-money laundering (AML) and counter-terrorist financing (CFT) efforts.

Singapore also adheres to global standards set by the International Organization of Securities Commissions (IOSCO) to ensure regulatory consistency across different jurisdictions.

8. Innovation and Adaptability

8. Innovation and Adaptability

  • Singapore’s regulatory environment encourages financial innovation by supporting initiatives like regulatory sandboxes. This allows businesses to safely test new technologies and models while maintaining consumer protection and financial stability.
  • The Monetary Authority of Singapore (MAS) and the government provide a supportive ecosystem, promoting growth in fintech and blockchain sectors. This ensures businesses can adapt to rapidly changing market and technology trends.

Types of Crypto licensing in Singapore

In Singapore, cryptocurrency businesses need to obtain one of two main types of licenses under the Payment Services Act (PSA) to legally operate within the country. The two license types, Standard Payment Institution (SPI) and Major Payment Institution (MPI), differ based on the scale and nature of the services provided. For crypto related services in Singapore is necessary to obtain authorization for digital payment token (DPT). The Monetary Authority of Singapore (MAS) regulates both licenses to ensure financial stability, promote transparency, and guard against money laundering and terrorist financing.

The Monetary Authority of Singapore (MAS) oversees the following seven types of services:

Service typeDescription of license

Digital payment token service

Facilitating the buying, selling, and exchanging of cryptocurrencies.

Domestic money transfer service

Facilitating local fund transfers.

Cross-border money transfer service

Managing international remittances.

Merchant acquisition service

Processing merchant payments.

E-money issuance service

Issuing digital currency for transactions.

Account issuance service

Issuing payment accounts and e-wallets.

Overview of requirements to obtain Crypto license in Singapore

  • Businesses must be legally incorporated and registered with MAS under the Payment Services Act (PSA) with authorization for digital payment token service.
  • A registered address in Singapore is mandatory, though a physical office may not be required for all business models.
  • A qualified compliance officer experienced in financial regulations, including AML and KYC, is required.
  • The minimum capital required is S$100,000 for SPI licenses and S$250,000 for MPI licenses.
  • Companies must adhere to AML and KYC requirements, ensuring proper transaction monitoring and customer verification.
  • Regular financial audits and reports must be submitted to MAS for compliance purposes.
  • Secure technical infrastructure is essential to protect customer data and mitigate fraud.

Estimated time frames

Gathering documents

1-2 weeks

Company formation

up to 2 weeks

Documents preparation

5-6 weeks

DPT License Issuance

3-6 months

*The timeline may vary based on the completeness of documentation and the responsiveness of the regulatory bodies.

Detailed Requirements for Crypto licensing in Singapore

Obtaining a crypto or DPT license in Singapore involves a comprehensive, multi-step process that requires strict compliance with regulations set by the Monetary Authority of Singapore (MAS) under the Payment Services Act (PSA). This framework is designed to ensure that cryptocurrency operations are legally compliant and secure, protecting the integrity of Singapore’s financial system.

The process of applying for a crypto license includes establishing robust anti-money laundering (AML), know your customer (KYC), and countering the financing of terrorism (CFT) procedures, among other critical compliance measures. Below is a breakdown of the requirements needed for crypto licensing in Singapore, along with the necessary steps.

List of required documents

  • AML/KYC/CFT Policy
    • Detailed measures to ensure compliance with anti-money laundering regulations, including customer identification and transaction monitoring.
  • Application Form: The application should include a full business description, the specific services provided (e.g., trading, custody, exchange), target markets, and an explanation of the business model. Financial forecasts and risk assessments should also be provided. Additionally, detailed information about company partners and shareholders is required for regulatory compliance.
  • Financial Statements: The company must submit audited financial statements. Projected financial forecasts are also mandatory for businesses that are not yet operational.
  • Compliance Manual: A manual outlining internal policies and procedures designed to meet MAS’s compliance requirements. This includes monitoring, reporting procedures, and training for AML/KYC/CFT policies.
  • Constitution (Company Incorporation Document): The company must be incorporated in Singapore, with documents registered with ACRA (Accounting and Corporate Regulatory Authority). These include Articles of Association, which detail the company’s structure, roles, and shareholding.
  • Risk Management Policies: A risk management framework addressing operational and financial risks. It should specify processes for managing AML/CFT risks, including high-risk client management, fraud prevention measures, and data security. Specific risk types such as liquidity risk, cybersecurity risk, and fraud prevention must also be outlined.
  • Technology Risk Management Plan: Businesses must submit documentation on their cybersecurity protocols, including measures for data protection, breach handling, and business continuity. Regular penetration testing and cybersecurity audits are also required.
  • Professional Indemnity Insurance (PII): A mandatory insurance cover for businesses applying for payment licenses, ensuring coverage against professional errors and operational risks.
  • Auditor Reports: Regular financial audits must be conducted, and a report provided by a licensed auditor approved by MAS.
  • Cyber Hygiene Documentation : Companies must comply with MAS’s cybersecurity requirements.This includes ensuring regular system patches, strong encryption, incident reporting, and proper access controls to safeguard against cyber threats.
  • Business Plan: A comprehensive document outlining the company’s objectives, strategies, and projected financial performance. It should also include detailed market analysis, revenue models, and operational plans to ensure regulatory authorities of the company’s viability.
  • External Auditor’s Report: For new applicants providing Digital Payment Token Services, an independent external auditor’s assessment report is required. The report must review the applicant’s AML/CFT and Consumer Protection policies, and be issued within three months prior to the application submission.
  • Legal Opinion: A legal opinion from a law firm experienced in the Payment Services Act (PSA) is required. This document should provide a detailed analysis of how the regulated payment services apply to each of the applicant’s proposed services or products, ensuring compliance with Singapore’s regulatory framework.

Share Capital and Government Fees

  • Minimum Share Capital: Companies applying for a crypto license must meet specific capital requirements based on the type of license. The minimum for a Standard Payment Institution (SPI) is S$100,000, and for a Major Payment Institution (MPI), it’s S$250,000.
  • Government Fees: You are required to pay a non-refundable application fee. The amount of application fees you will have to pay depends on the payment services you are applying for. Full list of prices can be found here – Application Fees

    License Issuance Fee: Upon approval, an SPI license has an issuance fee of S$5,000, while the fee for an MPI license is S$10,000.

    Annual Licensing Fees: Annual supervisory fees are based on the services provided. SPI licenses have a base fee of S$5,000, which can increase depending on the scope of services, such as the addition of Digital Payment Token (DPT) services.

Personnel Requirements

  • Companies must appoint a Compliance Officer who resides in Singapore. The CO must have a deep understanding of AML and CFT regulations, with experience in managing financial crime risks.
  • At least one director must be a Singapore resident. The director must have significant experience in finance, management, or legal operations, and be responsible for overall compliance with MAS standards.
  • For companies handling high-risk transactions or large volumes, an additional AML Manager may be required. This person must specialize in managing AML and CFT measures, ensuring all regulatory requirements are met.
  • All personnel involved in financial transactions must undergo regular training to stay updated on the latest MAS regulatory requirements. This includes AML/CFT training and compliance updates.

Business premises requirements

  • In Singapore, having a physical office is generally required for businesses applying for a cryptocurrency license. The office is needed for official correspondence, regulatory checks, and operational activities. Companies can also consider virtual offices for official registration, but the MAS might require more depending on the business model and operational needs.
  • Additionally, companies must provide proof of having a suitable IT infrastructure to ensure compliance with regulatory and security standards. This is crucial for businesses that handle cryptocurrency transactions, where secure data handling and customer information protection are of utmost importance.

Roadmap of obtaining Crypto license in Singapore

Securing a Crypto License in Singapore requires compliance with the Payment Services Act (PSA), which governs all licensing for payment services. Following the regulations set by the Monetary Authority of Singapore (MAS), the process ensures transparency, proper Anti-Money Laundering (AML) protocols, and full compliance with KYC and CFT standards.

Our team provides expert guidance throughout this licensing journey, helping businesses meet every legal requirement efficiently.

For more details, refer to the PSA legislation here, or contact our experts for personalized assistance.

Eriks Fijalovs

Head of Blockchain and Crypto

1

Client Assessment and Business Model Review

We start by gathering all necessary documents and performing a thorough review of your business model and corporate structure. This ensures that everything is in line with Singapore’s regulatory requirements, particularly if your company includes any external shareholders. An initial compliance check will be conducted to ensure your business meets the standards set by MAS.

2

Incorporating the Company in Singapore

Our team will assist you with registering your business in Singapore through ACRA. This process involves drafting the necessary incorporation documents and establishing a registered office. We also ensure that key personnel, such as a Compliance Officer and AML Manager, are appointed as required by Singapore’s crypto regulations.

3

Preparing and Submitting the Crypto License Application

We handle the preparation of your application, which includes documents such as the Compliance Manual, AML/KYC policies, and a detailed risk management plan. Your application will be submitted to MAS for either an SPI or MPI license, including proof of compliance with Singapore’s financial regulations and meeting the required capital thresholds.

4

DPT License Review and Approval

Once submitted, MAS will begin reviewing your application. During this stage, additional documents or clarifications may be requested. We keep you updated throughout the review process, ensuring everything is in order. Once approved, your company will be issued a crypto license, allowing you to begin operations.

5

Opening a Corporate Bank Account

We assist in setting up a corporate bank account with a Singaporean bank to facilitate your business’s financial activities, ensuring the account adheres to AML and regulatory standards.

6

Operational Launch

With your license and bank account in place, we guide you through the final steps of launching your business. This includes preparing your team for regulatory compliance, implementing necessary security protocols, and ensuring all operations are aligned with Singapore’s legal requirements.

Detailed Time Frames to Obtain a Crypto License in Singapore

The process of obtaining a crypto license in Singapore involves multiple stages. Each stage has its own timeline. Below is an estimated timeline for completing the licensing process under the Payment Services Act (PSA):

1.  Preparation and Documentation

Estimated Time Frame: 5-6 weeks

To begin the process, you will need to develop AML/KYC policies in line with Singapore’s regulatory requirements, establish internal control systems for compliance, and provide the company’s Constitution, risk management policies, compliance manual, financial statements, and technology risk management plan. Additionally, new applicants must include a legal opinion on regulated payment services, and an external auditor’s assessment report on AML/CFT processes. Ensure that all auditor reports are prepared for submission to MAS.

2.  Submission of Application

Estimated Time Frame: 1-3 days

Once all necessary documents are gathered, you can submit the application to MAS. This submission should include a business plan, compliance manual, AML/KYC policies, risk management plan, financial projections, and shareholder details to ensure compliance with regulatory standards.

3.  Review and Processing by Singapore Regulatory Authorities

Estimated Time Frame: 3 months

4.  Registration and Confirmation

Estimated Time Frame: 1-2 weeks

After a successful review, MAS will grant the crypto license, enabling the business to operate legally within Singapore’s jurisdiction.

Overall Estimated Time Frame – Approximately 6-9 months

Factors Affecting the Time Frame

Obtaining a crypto license in Singapore is a comprehensive, multi-step process that requires submitting detailed documentation and adhering to strict regulatory standards set by the Monetary Authority of Singapore (MAS). The typical timeframe for obtaining a license ranges from 6 to 9 months, depending on the complexity of the business model and regulatory requirements. By adhering to compliance measures and utilizing expert legal guidance, businesses can streamline the process and secure their license efficiently, ensuring smooth entry into Singapore’s dynamic fintech ecosystem.

Advantages of the Crypto license in Singapore

Links for legislation related to Crypto business in Singapore

Tthe main regulator for cryptocurrency activities in Singapore.

the primary legislation governing payment services and cryptocurrency companies, including licensing requirements for digital payment tokens and services.

provides the legal foundation for licensing financial intermediaries and cryptocurrency exchanges dealing in regulated products.

requires companies offering insurance for crypto assets to comply with regulations outlined in this Act.

This document provides guidance on licensing requirements for companies offering services related to digital payment tokens, including compliance with KYC and AML requirements.

This code outlines the responsibilities of payment service providers to ensure adherence to regulatory standards.

MAS requires cryptocurrency companies to follow cybersecurity hygiene standards, such as patching systems, data encryption, and incident reporting.

VIII. PSN01 & PSN02 Notices

Set the Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) standards that companies must adhere to.

IX. PSN03 & PSN04 Notices

PSN03 requires businesses to report suspicious activities and fraud incidents to relevant authorities, while PSN04 outlines the procedures for submitting regulatory returns to MAS.

DPT or digital asset license in Singapore

Taxation of Cryptocurrency Companies in Singapore

Taxation of cryptocurrency companies in Singapore is a vital part of the country’s regulatory landscape. The government aims to ensure that digital assets are properly integrated into the financial system while maintaining compliance with tax laws. Below are the key tax components relevant to crypto businesses in Singapore:

1. Corporate Tax

1. Corporate Tax

  • The corporate tax rate in Singapore is 17%, making it competitive for businesses, including cryptocurrency companies. However, the effective tax rate can be lower due to various tax incentives offered by the government to promote economic activity.
  • Newly established cryptocurrency startups may benefit from partial tax exemptions for the first three years of assessment.
2. Dividend and Withholding Tax

2. Dividend and Withholding Tax

  • No Dividend Tax: Singapore has a one-tier corporate tax system, meaning dividends paid to shareholders are not taxed. This is a significant advantage for cryptocurrency companies looking to distribute profits to shareholders.
  • Withholding Tax: There is no withholding tax on dividends. However, withholding tax may apply to certain payments made to non-residents, such as royalties, interest, or technical service fees. The rates can vary, but are often subject to Double Taxation Agreements (DTAs) that Singapore holds with other countries.
3. Goods and Services Tax (GST)

3. Goods and Services Tax (GST)

  • Zero-rated for Export Services: As of now, the supply of digital payment tokens (such as cryptocurrencies) is exempt from GST in Singapore. This is a significant change that took effect in 2020 under the Goods and Services Tax (Amendment) Act, where cryptocurrencies were classified as financial services.
  • GST applies to the domestic sale of certain goods and services, but cryptocurrency transactions are exempt.
4. Personal Income Tax

4. Personal Income Tax

  • Singapore operates a progressive personal income tax system for individual taxpayers. The rate ranges from 0% to 22%, depending on income. For individuals who are paid in cryptocurrency or hold it as an investment, capital gains are not taxed as Singapore does not impose a capital gains tax.
5. Capital Gains Tax

5. Capital Gains Tax

No Capital Gains Tax: Singapore does not have a capital gains tax. This is particularly beneficial for cryptocurrency investors and companies trading in digital assets, as any gains from the sale of cryptocurrencies are not taxed.

6. International Transactions

6. International Transactions

  • No Tax on Foreign-Sourced Income: Cryptocurrency companies that earn income from foreign sources generally do not need to pay tax on that income, provided the income is not brought into Singapore. This policy encourages global trading and investment for companies based in Singapore.
7. Tax Reporting and Compliance

7. Tax Reporting and Compliance

  • Cryptocurrency companies must submit annual tax returns to the Inland Revenue Authority of Singapore (IRAS). These include income statements, financial documents, and other supporting materials for tax assessment. Cryptocurrency companies are expected to maintain accurate records of all transactions to ensure compliance with tax laws.
8. Regulatory Guidance and Updates

8. Regulatory Guidance and Updates

  • MAS Notice 3001: Under this regulation, cryptocurrency companies are expected to comply with AML/KYC standards. Proper tax reporting of earnings related to cryptocurrency transactions must adhere to Singapore’s strict anti-money laundering and tax evasion laws. The Monetary Authority of Singapore (MAS) continues to issue updates to guide businesses in the fintech sector.

FAQ about Crypto license in Singapore

1. What is a Payment Services License (PSL) in Singapore, and why do I need it for my crypto business?

A Payment Services License (PSL) from the Monetary Authority of Singapore (MAS) is required for companies providing payment services, including crypto businesses. It ensures compliance with regulations on anti-money laundering (AML), countering terrorist financing (CFT), and protecting consumers.

2. What are the primary requirements for obtaining a cryptocurrency license in Singapore?

The key requirements include registering with MAS, appointing local personnel (e.g., a Compliance Officer), implementing robust AML/KYC policies, and meeting capital requirements depending on the license type (SPI or MPI).

3. How long does it take to get a crypto license in Singapore, and what are the key stages?

The process generally takes between x to x months, including document preparation, application submission, and regulatory review by MAS.

4. Are there any tax incentives for cryptocurrency companies in Singapore?

Yes, Singapore offers a competitive corporate tax rate of 17%, and startups may benefit from tax exemptions in their first three years. There is no tax on dividends, which makes it a business-friendly jurisdiction.

5. What is the difference between a Standard Payment Institution (SPI) and a Major Payment Institution (MPI) license in Singapore?

SPI is for businesses with lower transaction volumes (up to S$3 million/month), while MPI is for businesses exceeding this threshold and has stricter capital and compliance requirements.

6. Do I need a physical office to obtain a crypto license in Singapore?

A physical office is generally required for regulatory compliance and business operations. Virtual office options may also be available depending on the nature of the business.

7. What is the cost of applying for and maintaining a cryptocurrency license in Singapore?

Application fees start at S$1,000 for an SPI and S$5,000 for an MPI, with additional costs for compliance, auditing, and annual fees based on the services provided.

8. Is it necessary to appoint a local Compliance Officer and AML Manager for my crypto business in Singapore?

Yes, MAS requires the appointment of a Compliance Officer and, in some cases, an AML Manager to ensure adherence to regulatory standards.

9. What are the benefits of obtaining a crypto license in Singapore compared to other jurisdictions?

Singapore offers a stable regulatory environment, favorable tax rates, and a business-friendly ecosystem, making it an attractive destination for crypto businesses.

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