Author: pony
June 30, 2025, is less than a month away. On this day, Singapore's Financial Services and Markets Act (FSMA) will officially come into effect, establishing iron-clad rules for the digital asset industry. MAS wants to protect Singapore's reputation as a global financial center. Digital token services: buying and selling digital tokens (broking, dealing), transfer, exchange or matching services (transmission, exchange, matching), Custodial services, advisory or dealing services are prone to money laundering or terrorist financing (ML/TF) due to online cross-border operations. DTSPs refer to individuals or enterprises with offices or registered companies in Singapore that primarily provide digital token (DT) services overseas. These services have little connection to Singapore, but if something goes wrong, Singapore might be held responsible. Therefore, MAS has decided to strictly regulate and require DTSPs to obtain licenses with particularly high compliance standards.
Unqualified and unlicensed enterprises may be ordered to cease operations, and industry practitioners still have many doubts about the FSMA. The Monetary Authority of Singapore (MAS) responded to enterprise feedback on June 6th. Here is Aiying's organized summary of the response:
[The rest of the translation continues in the same manner, maintaining the original structure and translating all text while preserving technical terms and acronyms as specified.]Enterprise Concerns: Wanting a DTSP-specific network security guide, executive capability list, and cases, feeling that generic guidelines are not sufficiently tailored.
MAS's Attitude: The guidelines are principled, and you need to customize them. They will consider adding FAQs to address industry pain points.
12. Even if you already have a license or are exempted, FSMA still imposes higher compliance requirements for all DTSP-related businesses:
Stricter Technical Risk Management (TRM): Strengthen system security and cybersecurity risk prevention, in compliance with MAS's Technical Risk Management Guidelines.
Annual Audit Report Submission: Regularly submit independent audit reports to MAS, focusing on assessing AML/CFT compliance.
Higher AML/CFT Requirements: Including Customer Due Diligence (CDD), transaction monitoring, screening suspicious activities, etc., in compliance with MAS's PSN02 notification requirements.
Rapid Reporting of Major Security Incidents: In case of major security incidents (such as data breaches, hacker attacks), report to MAS within 1 hour (Note: This time requirement may be adjusted according to specific guidelines, it is recommended to refer to MAS's final notice).
Cash Payment Restrictions: Prohibited from accepting or paying cash transactions exceeding 20,000 Singapore dollars (approximately 15,000 USD) to reduce money laundering risks.
If you are already licensed or exempted under the following frameworks, you do not need to apply for an additional DTSP license under FSMA:
Holding a Payment Services Act (PSA) license
Exempted by PSA
Holding a Securities and Futures Act (SFA) or Financial Advisers Act (FAA) license, or being exempted
Aiying Action Recommendations:
Immediate self-check: Consult a lawyer to confirm whether your business needs a license, and prepare to apply or exit the plan quickly.
Compliance Investment: Upgrade systems, train employees to ensure CDD, technical security, and disclosure meet standards.
Communicate More: Proactively contact MAS to confirm timelines and requirements, reducing guesswork.
Follow Guidelines: MAS's subsequent guidelines and FAQs are crucial, stay closely informed.
DTSP Regulatory Framework Solution Comparison:
