How MAS licenses crypto exchanges

You will be able to describe the Payment Services Act licensing regime for digital payment token services.

Darren has narrowed his choice to two apps. One is a big international exchange his friends use, with a slick interface and every token he has heard of. The other is smaller, and its website says it is licensed by MAS. He wonders whether that line is worth anything, or whether it is just one more badge on a homepage. It is worth quite a lot, and this lesson explains why, and how to check it yourself instead of taking the homepage's word for it.

The law that covers crypto exchanges

In Singapore, buying and selling crypto, and the firms that help you do it, fall under the Payment Services Act. The Act calls cryptocurrencies like bitcoin and ether digital payment tokens, and it treats dealing in them, or helping other people buy, sell or transfer them, as a digital payment token service.

Under the Act, a firm providing digital payment token services in Singapore must hold a licence from MAS. MAS has also tightened the rules over time for Singapore firms that serve customers only outside Singapore, so a firm cannot simply set up here, skip the licence and sell abroad. The detail of who needs what has changed more than once, so if you want the current position, read it on the MAS website.

There is more than one kind of licence. Smaller firms can hold a Standard Payment Institution licence. Once a firm's business grows past thresholds that MAS sets on things such as the value of transactions it handles, it needs a Major Payment Institution licence, which comes with heavier requirements. The thresholds are set in the regulations and can change, so look them up on the MAS website rather than relying on a figure you saw in an article. In practice, the crypto exchanges licensed in Singapore that you are likely to come across hold a Major Payment Institution licence, and the directory below lets you confirm it for any one of them.

What a licence brings

A licence is not a seal of approval for the tokens an exchange lists, and MAS says so plainly. What it brings is a set of obligations on the firm, with MAS checking it meets them.

The first group is anti-money laundering and counter-terrorism financing rules. A licensed exchange has to verify who its customers are, watch for suspicious transactions and report them. That is why opening an account takes identity checks and why large or unusual transfers can be held for questions. It is a nuisance, and it also means the firm is held to standards that a casual offshore operator is not.

The second is technology risk management. MAS expects licensed firms to protect their systems and customer data, plan for outages and report serious incidents. Exchanges are tempting targets for hackers, so this matters for you directly.

The third is ongoing supervision. A licensed firm reports to MAS, can be inspected, and can be ordered to fix problems or lose its licence. MAS has also added rules aimed at protecting retail customers, which are big enough to get their own lesson, lesson 3.2, The protections MAS requires for retail customers.

Checking the licence yourself

You do not need to trust a homepage badge. MAS publishes the Financial Institutions Directory on its website, a public, searchable list of the firms it regulates. Search for a firm and the entry shows its full legal name, the type of licence it holds and the activities it is licensed for.

Two habits make the search useful. First, search by the legal entity, not only the brand. An app might be called one thing while the company you actually sign up with has a different name, sometimes with "Pte Ltd" at the end, and sometimes a different company entirely in another country. Second, check that the licence covers digital payment token services, not some other payment activity. Lesson 3.4, Run a licence and terms check on one exchange, turns this into a full routine.

The directory reflects the current position, and firms have left Singapore or withdrawn applications in the past. Search again before you deposit, even if you checked last year.

The exchange with no Singapore licence

Now back to Darren's first option. Many large overseas exchanges are happy to accept customers from anywhere online, whether or not they hold a licence in Singapore. Some have previously been placed on the MAS Investor Alert List, which you will meet in lesson 3.3.

If you use an exchange with no MAS licence, none of what this lesson covered applies to your account. There is no Singapore regulator supervising how it holds your assets, nobody here who can order it to fix a problem, and no local framework for dealing with your claim if it fails. You would be relying on the laws of wherever it is based, which may be unclear, far away or weak. That does not guarantee anything will go wrong. It means that if something does, you will have very few options.

Darren's choice is clearer now, though he still has work to do. He wants to know the legal entity behind each app and what the directory says about it. That is exactly what you will do next, for two exchanges you have heard of.

Search the MAS Financial Institutions Directory for two exchanges you have heard of and record each one's licence type and legal entity.

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