On 19 April 2024, the Monetary Authority of Singapore (MAS) issued the updated Frequently Asked Questions (FAQs)on the Payment Services Act (PS Act) (PS Act FAQs). The revisions to the PS Act FAQs reflect recent regulatory updates on the expanded scope of regulated payment services, the finalised MAS-regulated stable coin framework and the increased stock and flow caps for personal payment accounts holding e-money.
The table below summarises the key changes to the PS Act FAQs:
| Required Disclosures |
Clarifies that cross-border money transfer services now include a person in Singapore carrying on the business of arranging to transmit money from one country to another country, regardless of whether the person accepts or receives money in Singapore. (See our article on the expanded scope of regulated payment services.)
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| Expanded Scope of Digital Payment Token Services |
Explains when a licence is required for:
- Transmitting digital payment tokens (DPTs) from one DPT account to another DPT account;
- Inducing a person to enter into an agreement for or with a view to buying or selling DPT for money or another DPT; and
- Safeguarding, or carrying out instructions relating to, a DPT or a DPT instrument.
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| New Protections for Customers of Digital Payment Token Services |
Reiterates the obligations of DPT service providers to safeguard customers' assets. (See our article on the MAS protection guidelines for DPT customers and MAS consultation paper on draft protection measures for DPT customers.)
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| Regulation of Stablecoins |
Clarifies that single-currency stablecoins issued in Singapore and pegged to the Singapore Dollar or any G10 currency will be regulated under the new stablecoin framework which is still to be rolled-out. (See our article on the new stablecoin regulatory framework.)
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| Raised Stock and Flow Caps |
Reflects the new stock cap of S$20,000 (from S$5,000) and the new flow cap of S$100,000 (from S$30,000) for personal payment accounts holding e-money that are issued to persons in Singapore (personal e-wallet). The stock cap is the amount of money that a personal e-wallet can hold at any time, while the flow cap is the maximum total outflow from a personal e-wallet over a rolling 12-month period.
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Conclusion
The PS Act FAQs are helpful in guiding payment service providers in understanding the payment services regulatory framework in Singapore. Service providers, particularly those providing previously unregulated payment services, should therefore familiarise themselves with the PS Act FAQs to aide them in complying with the Payment Services Act 2019 and its related regulations.
For More Information
OrionW regularly advises clients on FinTech matters. For more information about the Payment Services Act 2019 and the regulation of payment services in Singapore, or if you have questions about this article, please contact us at fintech@orionw.com.
Disclaimer: This article is for general information only and does not constitute legal advice.
