DPT services are not limited to "receiving coins and then selling them"
The expanded scope rules published by the Monetary Authority of Singapore (MAS) in 2024 have brought activities such as digital payment token (DPT) custody, facilitating the transfer of tokens, and facilitating exchanges without holding funds or tokens within the regulatory perimeter. Therefore, describing oneself as a "technology platform" or "non-custodial" is not a conclusion. Teams should explain who organizes transactions, accepts instructions, arranges counterparties, and who can alter the path of asset transfers; whether technical services have entered regulated activities depends on actual functions.
Payment institution classes and the scope of permitted services must be considered separately
Standard Payment Institutions (SPIs) and Major Payment Institutions (MPIs) are licence classes, whereas DPT services and the like are business items. Obtaining a licence in a given class does not mean that functions such as fiat remittance, merchant acquisition, and account issuance are all automatically permitted. The scope of application should be determined according to the applicable thresholds, conditions, and the combination of services intended to be carried on. In 2024, MAS also expanded the scope of cross-border transfer services; certain cross-border arrangements in which funds do not flow through Singapore may still be regulated, and the fund path cannot be treated as the sole criterion for determining geographic scope.
Break down the merchant coin-collection product into two verifiable segments
Assume that the platform first collects stablecoins on behalf of the merchant and then remits fiat currency to the merchant's overseas account. The first segment requires an assessment of DPT transfer, exchange, or custody, while the second segment requires a separate review of payment services such as cross-border transfers. If the second segment is completed by a licensed partner, it must still be clear to whom the customer gives instructions, who bears the commitment that funds will be credited, and who handles refunds when they occur. Only where the contract, system permissions, and fund arrangements are consistent with the division of responsibilities can the admissibility of the platform's remaining activities be assessed; pasting a partner's licence on one's own website cannot be regarded as completing licensing.
Before applying, first test whether the team can perform its duties over the long term
MAS's licensing page requires verification of matters such as local entity and office arrangements, directors and officers, and compliance and technology risk capabilities. For start-ups, more useful preparation is to enable specific personnel to explain the product and the customer asset flow, rather than to accumulate policy documents. It is advisable to first determine the launch customer regions, core currencies, and minimum service scope, and then allocate customer verification, asset safekeeping, system anomalies, and complaint responsibilities to positions; when adding new services, re-examine the licence scope to avoid developing beyond the perimeter after obtaining a licence.
Recommended actions
- List DPT exchange, transfer, custody, trading arrangement, and fiat payment functions item by item, and identify the respective roles of the company and its partners.
- Confirm the SPI/MPI class, business items, and applicable conditions in accordance with MAS's current licensing guidelines, and verify the partner against the official register.
- Prepare genuine local management, personnel, and technology risk arrangements, and test whether responsibilities are complete through a normal payment and a refund.
- Establish a separate business line for overseas clients, confirm whether the PSA or the overseas DTSP regime applies, and do not conflate the place of establishment with the client's region.
Information note: This article provides general information and does not replace legal advice based on specific facts.
References
- MAS Expands Scope of Regulated Payment Services, 2 April 2024 — Monetary Authority of Singapore
- Licensing for Payment Service Providers — Monetary Authority of Singapore
- MAS Clarifies Regulatory Regime for Digital Token Service Providers, 6 June 2025 — Monetary Authority of Singapore
