The capital markets services licence and the Part 9 licence

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The process for a CMS licence under the SFA follows the same stages with different content. The application form is the SFA form for the regulated activities sought. The base capital and risk-based capital requirements are higher. The management must include persons who meet the experience requirements for the regulated activity, and representatives who deal with customers must be notified under the representative notification framework. The review concentrates on the conduct of business rules, customer asset segregation and, for fund management, the investment process and the valuation of assets. For tokenised capital markets products the review adds the custody and settlement questions discussed in Chapter VII. Timelines are comparable. The sandbox route under the MAS FinTech Regulatory Sandbox is available for novel models that do not fit the existing requirements.¹

The Part 9 licence under the FSMA follows the same stages in form, but the practical reality described in Chapter V is that MAS will grant it in extremely limited circumstances. An applicant that falls within Part 9 and does not qualify for a main Act licence should assume that the application will be refused and should plan to restructure instead.

Notes

MAS, FinTech Regulatory Sandbox Guidelines, November 2016 as revised, and the Sandbox Express and Sandbox Plus variants introduced in 2019 and 2022. ↩

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.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

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