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On-shore VASP in Singapore

Locally-incorporated VASP that operates under full local jurisdiction, holding all required licenses and registrations.

Conditional AI-Generated · Unreviewed

On-shore VASP is conditionally permitted in Singapore with a local entity, subject to AML obligations and high licensing burden.

Verdict Details

Permitted
conditional
Local entity required
Yes
Licensing burden
High
Last updated
2026-07-13

AML Obligations

  • Must comply with MAS AML/CFT Notices PSN01 and PSN02 (amendments effective July 2025)
  • Customer due diligence (CDD) and ongoing monitoring required per MAS notices
  • Travel Rule applies: must obtain, verify, and transmit originator and beneficiary information for DPT transfers of SGD 1,500 or more
  • Originator information: name, account number, physical address, national identity number (or customer ID), date and place of birth
  • Beneficiary information: name and account number
  • Information must be transmitted immediately and securely with the DPT transfer; if technically infeasible, by other means within reasonable time
  • Suspicious transaction reporting (STR) obligations to MAS
  • No specific AML/CFT threshold for general CDD — applies to all DPT service activities
  • Supervised by MAS for AML/CFT compliance

Key Restrictions

  • MAS explicitly discourages retail crypto speculation — marketing to general public prohibited (since Jan 2022)
  • No incentive programs (e.g., referral bonuses) for DPT services
  • No ATMs in public areas for DPT services
  • Must be a Singapore-incorporated entity
  • Customer asset segregation mandatory (statutory trust since 2024)
  • Security deposits of SGD 100K–200K required for custody activities
  • SPI license has transaction limits: SGD 3M single / SGD 6M aggregate monthly
  • Stablecoin issuers must maintain 100%+ reserves in cash/equivalents at SG-licensed institutions

Key Risks

  • Very low approval rate for MPI licenses (~20-30 full licenses granted from 170+ applications) — significant uncertainty of obtaining license
  • MAS active enforcement against unlicensed and non-compliant DPT service providers
  • Regulatory ambiguity around treatment of novel token types (utility tokens, NFTs) under PSA vs SFA
  • No capital gains tax for individuals, but IRAS may recharacterize frequent trading as taxable business income — tax risk for operators who also trade
  • Marketing and promotion restrictions severely limit customer acquisition strategies

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 40% confidence

MAS — All DPT service regulation, PSA licensing, AML/CFT, stablecoin framework, TRM guidelines

licensing 40% confidence

Payment Services Act 2019 (2019) — DPT service licensing — MPI/SPI licenses

licensing 40% confidence

Securities and Futures Act (2001) — Security tokens, CMS licensing

licensing 90% confidence

MAS AML/CFT Notices (PSN01, PSN02) — AML/CFT requirements for DPT service providers; amendments effective July 2025

licensing 80% confidence

MAS Technology Risk Management Guidelines (2021) — Cybersecurity, data protection, operational resilience

licensing 80% confidence

VASP: Major Payment Institution (MPI) license for DPT services. SGD 250,000 base capital (~$185K USD). 170+ applications received, only ~20-30 full MPI licenses granted. SPI option: SGD 100,000 base capital with transaction limits (SGD 3M single/SGD 6M aggregate). Must have Singapore entity, resident director, local compliance officer, physical office.

licensing 80% confidence

CUSTODY: Included under DPT MPI license. Customer asset segregation mandatory (statutory trust since 2024). Security deposits (SGD 100K-200K) required.

licensing 80% confidence

EXCHANGE: MPI license. MAS explicitly discourages retail crypto speculation — marketing to general public prohibited (Jan 2022), no incentive programs, no ATMs in public areas. Stablecoin issuers must maintain 100%+ reserves in cash/equivalents at SG-licensed institutions.

licensing 20% confidence

Monetary Authority of Singapore (MAS): This is the central bank and integrated financial regulator of Singapore. MAS is the primary body responsible for regulating all digital asset and crypto-related activities, issuing licenses, and enforcing compliance with financial regulations.

licensing 20% confidence

This is the cornerstone legislation for cryptocurrency regulation in Singapore. It regulates entities that provide services related to "Digital Payment Tokens" (DPTs), which is MAS's term for cryptocurrencies like Bitcoin and Ethereum.

licensing 20% confidence

Dealing in DPTs (e.g., buying and selling on behalf of customers).

licensing 20% confidence

Facilitating the exchange of DPTs (e.g., operating a DPT exchange).

licensing 20% confidence

Receiving or sending DPTs (e.g., cross-border DPT transfers).

licensing 20% confidence

DPT issuance (e.g., initial coin offerings where the token functions as a payment token).

licensing 20% confidence

MAS AML/CFT Notices (e.g., PSN01, PSN02 for Payment Services):

licensing 20% confidence

These notices lay out the specific Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) requirements for financial institutions, including DPT service providers.

travel-rule 80% confidence

Travel Rule adopted — threshold: SGD 1,500

travel-rule 40% confidence

Requirements: DPT service providers are required to obtain and transmit certain originator and beneficiary information for DPT transfers.

travel-rule 40% confidence

Thresholds: This applies to DPT transfers involving a value of S$1,500 or more (or its equivalent in other currencies/DPTs).

travel-rule 40% confidence

Originator Information: Name, account number used for the transaction, physical address, national identity number (or customer identification number if national ID is unavailable), and date and place of birth (if available).

travel-rule 40% confidence

Timing: This information must be obtained and transmitted immediately and securely with the DPT transfer itself. Where this is not technically feasible, the information must be sent by other means within a reasonable time.

travel-rule 40% confidence

MAS Notice PSN02 on Prevention of Money Laundering and Countering the Financing of Terrorism – DPT Service Providers (Paragraphs 6.4, 6.5, 6.6)

travel-rule 20% confidence

Adopted and Enforcement Status: The rule is mandatory for all regulated payment service providers, including VASPs offering digital payment token (DPT) services under the Payment Services Act (PSA) 2019. Compliance became a legal requirement on January 28, 2020.

travel-rule 20% confidence

Effective Date: January 28, 2020.

travel-rule 20% confidence

Threshold Amounts: Applies to virtual asset transfers ≥ S$1,500 (approximately US$1,000 equivalent), requiring VASPs to collect and share sender/recipient personally identifiable information (PII).

travel-rule 20% confidence

Covered VASPs: All licensed DPT service providers under the PSA, such as centralized crypto exchanges like Crypto.com and Gemini, which must handle incoming/outgoing transfers compliantly. Non-custodial wallets may require verification (e.g., Satoshi Test) for withdrawals exceeding S$20,000 monthly from custodied wallets.

Evidence fact sg.tax not found (may have been renamed).

tax 60% confidence

Trading of Digital Tokens: Profits derived from the trading of digital tokens (e.g., crypto exchanges, mining operations, professional traders) are treated as taxable income under the Income Tax Act.

tax 40% confidence

No capital gains tax applies to gains from selling or disposing of crypto held as a capital asset (e.g., long-term investments by individuals).

tax 100% confidence

As of 1 January 2020, DPTs that meet specific criteria (e.g., fungible, interchangeable, not pegged to any fiat currency, medium of exchange) are exempt from GST when used as a medium of exchange.

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
high

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

Conditional — an on-shore VASP in Singapore must obtain an MPI license (or SPI license with transaction limits) under the Payment Services Act 2019, be a Singapore-incorporated entity with SGD 250,000 base capital (MPI), comply with MAS AML/CFT Notices PSN01/PSN02 including Travel Rule at SGD 1,500 threshold, observe strict marketing restrictions, and face a highly competitive licensing process with low approval rates.

Questions this verdict aims to answer

  • What license(s) are required to operate locally?
  • What capital, governance, and reporting obligations apply?
  • What is the application process and timeline?