Incomplete and non-compliant transfers
A Singapore licensee that receives a DPT transfer lacking the required information has three lawful responses: execute and follow up, suspend pending information, or reject and return. The notice requires a risk-based policy that says which response applies in which circumstances, and MAS expects the policy to be more restrictive for higher-value transfers and for counterparties of unknown status.1 The blockchain introduces a complication that fiat does not have: the value has already arrived. Rejection means sending it back, which is itself a transfer subject to the rule and may itself be the laundering step if the originating address was compromised. The safer course for anything above a modest value is to suspend, credit nothing to the customer and request the information from the counterparty. If it does not arrive within a set period, the firm should consider a suspicious transaction report (Chapter IV) before deciding whether to return the funds.
Repeated receipt of non-compliant transfers from the same counterparty is itself a finding. The notice expects the licensee to take this into account in deciding whether to continue dealing with that counterparty and whether to report. A counterparty list that records the compliance history of each VASP is the tool for this, and MAS inspectors ask to see it.
Practice note
You can implement the Singapore travel rule in a form that will also satisfy a Swiss inspector by adopting four settings. - Collect the full PSN02 information set for every transfer regardless of value, which removes the S$ 1,500 distinction from your systems. - Require signed-message proof of control before any withdrawal to an unhosted wallet, which satisfies FINMA Guidance 02/2019 and exceeds the MAS expectation. - Maintain one counterparty VASP register with a status for each counterparty that both entities use. - Retain travel-rule data for ten years, the longer of the two statutory periods. The cost is a small loss of convenience for Singapore retail customers. The gain is a single control that passes inspection in both hubs.
Notes
- MAS Notice PSN02, para. 13, on risk-based policies and procedures for determining when to execute, reject or suspend a value transfer lacking required originator or beneficiary information. ↩
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.