The code is the product.
Cash flow - license.

01

We define a service by facts, not by the name of the application

MAS evaluates who accepts the instruction, holds or controls the money/token, issues an account or e-money, performs a transfer, attracts a merchant, and bears contractual responsibility. Outsourcing technology to a bank or processor does not always take the platform out of the regulated perimeter.

02

Seven main regulated payment services

Account issuance

Payment account, wallet or stored-value functionality

Domestic transfer

Transfers within Singapore

Cross-border transfer

Remittance and international transfer flows

Merchant acquisition

Acceptance and processing of payments merchants

E-money issuance

Storing monetary value for payments

Digital payment token

Dealing/facilitating DPT services in an adjustable volume

Money-changing

Buying and selling foreign currency notes

03

License class follows services and scale

If scale exceeds the established thresholds, the Standard Payment Institution does not remain a suitable final model. DPT service has independent AML and conduct expectations, regardless of the everyday word “crypto”.

04

Regulatory architecture before incorporation

Legal entity

Singapore applicant, ownership and group structure

Customer

Retail/business, countries, industries and risk appetite

Funds flow

Collection, safeguarding, settlement and refunds

Partners

Sponsor bank, acquiring, correspondent, processor and custodian

Economics

Fees, FX spread, float, credit and reserves

Governance

Board, CEO, compliance, MLRO, risk and technology

05

The application proves readiness to do business

1. 01
   Perimeter memorandum

   Services, exclusions, license class and legal analysis.

2. 02
   Business plan

   Markets, customers, volumes, revenue and three-year model.

3. 03
   People and governance

   Controllers, directors, key executives, compliance and competence.

4. 04
   Control framework

   AML, safeguarding, risk, technology, complaints and outsourcing.

5. 05
   MAS process

   Application, questions, remediation, approval and launch conditions.

06

AML/CFT is built into the customer journey

Risk assessment connects products, customers, countries, delivery channels and transactions. Before launch, CDD/EDD, UBO identification, sanctions/PEP screening, transaction monitoring, suspicious transaction escalation, record keeping, correspondent/agent controls and periodic review work.

07

Customer money is separated from operating cash

For applicable MPI activities, safeguards are designed through permitted structure, segregation, reconciliation, access controls and insolvency analysis. User terms should not promise deposit protection or banking features that the legal model does not provide.

08

Technology risk - part of the license

Architecture covers privileged access, encryption, secure development, vulnerability management, logging, incident response, availability, recovery, third-party/cloud risk and change management. A material outage or cyber incident simultaneously becomes an operational, regulatory and customer-communications event.

09

DPT requires separate product and custody analysis

Exchange, brokerage, transfer, custody/control, staking, stablecoin or token settlement cannot be combined in one word. For each feature, an asset, counterparty, wallet control, travel-rule/data flow, market conduct, customer access and permitted licensed activity are determined; The current provider status is checked in the MAS directory.

10

Pre-launch checklist

1. 01

   Funds flow and regulated services coincide with contracts and UI.

2. 02

   License class and MAS-authorized activities confirmed.

3. 03

   Banking, safeguarding and settlement partners are ready.

4. 04

   AML, complaints, technology and incident procedures tested.

5. 05

   Marketing is not ahead of approval and legal product scope.