MAS DTSP under FSMA Part 9
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The digital token service provider regime catches Singapore-based persons who provide digital token services outside Singapore and who are not already licensed under the PSA, SFA or another MAS-administered Act. Since 30 June 2025 such a person must hold a DTSP licence or cease the activity, and MAS has stated that licences will be granted only in extremely limited circumstances.1 The checklist therefore begins with the question whether the regime applies at all and whether restructuring is the better course. A group that decides to apply should expect the same depth of examination as for a PSA licence, with MAS additionally asking why the business cannot be conducted under an existing licence.
Checklist
- Map every digital token service performed by any person in Singapore (employees, directors, contractors) and identify whether any service is provided to persons outside Singapore.
- Determine whether the Singapore entity or individual is already licensed, exempt or regulated under the PSA, SFA, Financial Advisers Act or another Act, in which case Part 9 does not apply.
- If Part 9 applies and the activity has continued past 30 June 2025 without a licence, obtain advice on the exposure and consider a voluntary approach to MAS.
- Evaluate restructuring: move the regulated activity to the licensed Swiss or other entity, limit the Singapore entity to unregulated group services, document that no Singapore person negotiates, onboards, executes or custodies.
- If applying: prepare the business plan, the explanation of why the activity cannot be performed under a PSA or SFA licence, and the home-regulation analysis of the overseas customers' jurisdictions.
- Evidence base capital of S$ 250,000 and the resident director and compliance officer requirements.
- Prepare the AML/CFT framework aligned with the FSMA DTSP notice and the FATF standards for VASPs, including travel rule implementation for overseas customers.
- Prepare the technology risk and cyber hygiene documentation.
- Prepare the governance and fit-and-proper documentation.
- Budget for the annual fee and the ongoing obligations, which mirror those of an MPI.
Notes
- Financial Services and Markets Act 2022, ss. 136–141; MAS, Response to Feedback Received, 30 May 2025, paras 2.1–2.6; see Part K, Chapter V. ↩
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.