Stablecoin issuer / redeemer in Singapore
Issues a fiat-pegged stablecoin to the public, operates redemption, and holds reserves backing the float.
Stablecoin issuer 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
- Full MAS AML/CFT obligations under PSN01/PSN02 (amendments effective July 2025) — including customer due diligence (CDD), ongoing monitoring, suspicious transaction reporting (STR) to MAS, and name screening against sanctions lists.
- Issuer must hold an MPI license under the PSA, which carries MAS-supervised AML/CFT compliance program obligations.
- Minimum base capital of S$1 million or 50% of annual operating expenses (whichever higher) as a financial-resource underpinning for AML compliance.
Key Restrictions
- Only SGD-pegged or G10-currency-pegged stablecoins can qualify as 'MAS-regulated stablecoins' (SCS) under the MAS Stablecoin Regulatory Framework. Non-SGD/G10 pegged, multi-asset, or foreign-issued stablecoins remain general DPTs under the PSA (or securities under SFA) and cannot use the SCS label.
- Issuers of MAS-regulated SCS must be limited to stablecoin issuance only — no lending, staking, or unrelated business activities.
- Initial issuance of MAS-regulated SCS must occur from Singapore only (geofenced issuance origination).
- Foreign-issued stablecoins (e.g., USDC, USDT) are permitted for use as general DPTs under the PSA but do not qualify for MAS-regulated SCS status or the associated regulatory trust framework.
- Marketing of digital payment tokens (including general stablecoins) to the general public is restricted — no incentive programs, no public ATMs, and MAS discourages retail speculation.
Key Risks
- SCS framework is finalized (Aug 2023) but not fully in force as of late 2025 — further details/legislation expected (e.g., Nov 2025 announcement), creating regulatory timing risk.
- Only ~20-30 full MPI licenses granted out of 170+ applications — high risk of licensing delay or denial.
- Foreign-issued stablecoins not granted SCS status may face uncertainty: treated as general DPTs, not benefiting from the statutory trust, reserve audit, and redemption-right framework of SCS.
- Algorithmic or under-collateralized stablecoins fall outside the SCS framework entirely — treated as general DPTs with no MAS-regulated status, exposing issuers to enforcement risk.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
General stablecoins are classified as DPTs under the PSA.
SCS pegged to SGD or G10 currencies, issued in Singapore, can qualify as MAS-regulated stablecoins if issuers meet strict requirements, including full reserve backing and a Major Payment Institution (MPI) license; they are distinguished from other DPTs for enhanced trust.
Non-SGD/G10 pegged, multi-asset, or foreign-issued stablecoins remain DPTs or potential securities under SFA.
Issuers of MAS-regulated SCS must maintain reserve assets equal to at least 100% of coins in circulation, using high-quality liquid assets (e.g., cash, deposits, government securities) denominated in the peg currency.
Monthly independent attestations and annual audits are required; reserves must be segregated with approved custodians.
Issuers need a Payment Services license (MPI) under the PSA to issue MAS-regulated SCS.
Minimum base capital: S$1 million or 50% of annual operating expenses, whichever higher.
Restrictions: Issuers limited to stablecoin issuance only (no lending, staking, or unrelated activities); initial issuance from Singapore only.
Holders of MAS-regulated SCS have statutory redemption rights at par value (1:1 with peg currency) within 5 business days.
Customer assets held in statutory trust for protection.
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.
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.
MAS AML/CFT Notices (PSN01, PSN02) — AML/CFT requirements for DPT service providers; amendments effective July 2025
MAS — All DPT service regulation, PSA licensing, AML/CFT, stablecoin framework, TRM guidelines
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a stablecoin issuer can operate in Singapore as a MAS-regulated SCS issuer only if it obtains an MPI license under the PSA, issues an SGD- or G10-pegged stablecoin, maintains 100% reserve backing with monthly attestations, grants par-value redemption within 5 business days, is limited to issuance-only activities, and issues from Singapore; foreign-issued stablecoins are permitted as general DPTs but do not qualify for the SCS regulatory framework.
Questions this verdict aims to answer
- What e-money or banking license is required to issue?
- What reserve composition, segregation, and audit rules apply?
- What redemption rights must be granted to holders?
- Are foreign-issued stablecoins permitted for use locally?