Fintech as all know stands for financial technologies. Same way regtech stands for regulation technologies. Insuretech stands for insurance technologies.
Fintech is actually quite a broad word and many activities can come under Fintech. Sometimes the activities your company is doing may not come under any of the licensing requirements. For example, you may be providing accounting software, or background check software or something similar to this. So long as your company is not directly dealing with money/ value storage or asset handling the license is generally not required.
When it comes to the organizations which provide services falling under licensing requirements, the broad types are as follows.
While this is a general classification, your fintech startup may need any licenses beyond this list (For example, even a fund management License) and may even need multiple licenses from the Monetary Authority of Singapore. It entirely depends on the case-to-case basis. So it is always advisable to check with a competent Consultant on your business model.
In reality, both these licenses are quite similar in terms of nature and requirements. The only difference is for a Major Payment institution, there is no threshold for remittance or for deposit holding. Also the base capital requirements for a Major payment Institution is higher and the compliance requirements are stringent.
Following payment services are regulated under payment of Services act.
Account issuance service The service of issuing a payment account or any service relating to any operation required for operating a payment account, such as an e-wallet (including certain multi-purpose stored value cards) or a non-bank issued credit card.
Domestic money transfer service Providing local funds transfer service in Singapore. This includes payment gateway services and payment kiosk services.
Cross-border money transfer service Providing inbound or outbound remittance service in Singapore.
Merchant acquisition service Providing merchant acquisition service in Singapore where the service provider processes payment transactions from the merchant and processes payment receipts on behalf of the merchant. Usually the service includes providing a point-of sale terminal or online payment gateway.
E-money issuance service Issuing e-money to allow the user to pay merchants or transfer to another individual.
Digital payment token service Buying or selling digital payment tokens (“DPTs”) (commonly known as cryptocurrencies), or providing a platform to allow persons to exchange DPTs.
Money-changing service Buying or selling foreign currency notes
If your business is dealing with any of the above activities, then it will have to apply for a payment institution license under Payment Services Act.
Unlike Standard payment institutions the Major Payment institutions do not have specified thresholds.
The thresholds for Standard Payment Institution are set out in section 6(5) of the PS Act. In summary, these are:
In case the transactions handled by your company are likely to cross this limit then you will need to apply for major payment institution license.
The applicant must satisfy MAS that its sole-proprietor, partners, or directors and CEO, shareholders and employees, as well as the applicant itself, are fit and proper, in accordance with the Guidelines on Fit and Proper Criteria [FSG-G01]. The entity and group should not have any adverse reputation, particularly with regard to financial crimes.
The applicant must ensure that its sole proprietor, partners, or executive directors and CEO have sufficient experience in operating a business in the payment services industry or related areas in the financial services industry.
Where the individual will be managing a sizeable team, the sole-proprietor, partners, or executive directors and CEO should also have the relevant experience, competencies and influence, to allow them to exercise effective oversight and control over the business activities and staff.
The applicant should also consider the educational qualifications and professional certification of its key individuals.
The applicant must have a permanent place of business or registered office. It must be an office area where the applicant’s books and records can be securely held. The applicant must also appoint at least one person to be present to address any queries or complaints from customers.
An SPI or MPI licence applicant must satisfy MAS how it will meet the base capital requirements set out in the PSR4 , upon obtaining its license. In view of this obligation, the applicant must ensure that it maintains sufficient capital buffer in excess of the base capital requirement, bearing in mind the scale and scope of its operations and the potential for profit and losses.
The minimum base capital for a major payment institution is 250,000 SGD.
An MPI licence applicant must provide the required security, in the form of a cash deposit with MAS or a bank guarantee in the prescribed format. Standard Payment institution does not have this requirement as of now. The amount of bank guarantee is 100,000 SGD if any one of the remittance service does not exceed 6 Million SGD in a month, in any other case its 200,000 SGD. Depending on your company profile or background you may be able to buy an insurance policy instead of a bank guarantee deposit.
The applicant must have in place plans for compliance arrangements that are commensurate with the nature, scale and complexity of its business. Regardless of the setup of the compliance arrangements, the ultimate responsibility and accountability for ensuring compliance with applicable laws and regulations will still rest with the applicant’s sole-proprietor, partners, or directors and CEO, and compliance officer.
Where the applicant intends to provide online financial services, it must perform a penetration test of its proposed online financial services, remediate all high risk findings identified, and conduct independent validation on the effectiveness of the remediation actions. This does not need to be completed prior to application but must be completed prior to the grant of licence.
The applicant must have plans in place for adequate independent audit arrangements to regularly assess the adequacy and effectiveness of its procedures, controls, and its compliance with regulatory requirements. The audit arrangements should be commensurate with the scale, nature and complexity of its operations. The audit may be conducted by an internal audit function within the applicant, an independent internal audit team from the head office of the applicant, or outsourced to a third party service provider.
The applicant must have in place plans to meet the annual audit requirements as set out in section 37 of the PS Act. The auditor must be appointed at the applicant’s own expense to carry out an audit of its accounts and transactions, and compliance with the relevant regulations and requirements.
Where appropriate, MAS may require applicants to procure a Letter of Responsibility and/or Letter of Undertaking from the applicant’s majority shareholders, parent company and/or related company The template will be provided by MAS if the application is approved.
A licensee must comply with the AML/CFT requirements as set out in the Notices on Prevention of Money Laundering and Countering the Financing of Terrorism [PSN01 and/or PSN02] and Notice on Reporting of Suspicious Activities & Incidents of Fraud [PSN03]. A licensee should also refer to the Guidelines to Notices PSN01 and/or PSN02 for guidance on the AML/CFT requirements.
A licensee must submit periodic regulatory returns in relation to its payment service activities in accordance with the PSR.
A licensee must comply with the cyber hygiene requirements as set out in the Notice on Cyber Hygiene [PSN06] and put in place appropriate safeguards to protect customer information.
A licensee must comply with business conduct requirements in the PS Act, the PSR and the Notice on Conduct [PSN07]. These obligations include safeguarding of customers’ monies, record of transactions, issuance of receipts, adhering to the prescribed time period for transmission of money, display of exchange rate and fees, and notification of normal business hours. Licensees must also ensure that they comply with all prohibitions and restrictions, including personal payment account stock and flow restrictions, as well as prohibited business activities.
A licensee must make accurate representation on the scope of its licence and provide the disclosures set out in the Notice on Disclosures and Communications [PSN08] where applicable to its business. A licensee should also ensure that customers receive timely updates regarding any material changes to the disclosures.
The criteria are as follows:
The time for preparation of the application is approximately 4-6 weeks. The expected processing time is 4 months to review and process an application if the business model is straightforward, the applicant meets the relevant admission criteria fully, and the application is complete and clear. For more complex cases, technologically challenging cases, or cases where information is assessed to be incomplete or inaccurate, MAS will need a longer time to review the application.
It is therefore important that you use a professional firm like ours to process your application with MAS. Please ensure that your company’s application is complete, correct and accompanied by the requisite supporting documents.
Major payment institutions are required to pay an annual license fee and the applicable fees depend on the payment services that it is licensed to conduct. The fees are prescribed in the Schedule to the PSR and are, in summary, S$10,000 or the sum of the amounts below for the payment services provided, whichever is higher:
|Account issuance service||S$0|
|Domestic money transfer service||S$10,000|
|Cross-border money transfer service||S$10,000|
|Merchant acquisition service||S$10,000|
|E-money issuance service||S$10,000|
|Digital payment token service||S$10,000|
For each of the services which you provide, you are required to file a monthly return as well as half yearly return as well as annual return. (Typically, the forms used are 1A, 1B, 1C, 2A and so on). Please get in touch with our team for more details on this. It’s a bit complicated list so we preferred not to post it here.
From the above it should be clear to you that applying for a Major Payment License is not an easy task. Each case needs to be presented properly to the MAS. Many cases require technical flow diagrams as well as an explanation of technological developments. Often times MAS requires additional clarifications and if the documents provided are not clear then the process can get delayed resulting in a significant loss of time.
When you engage us we bring our expertise in this sector and ensure your application is submitted correctly with all relevant details. Moreover, we provide all the below services. So when you engage us you don’t have to worry about other services related to Compliance and AML / CFT.
Our packages are comprehensive. The price covers everything required.
Our service team has many years of experience. we will guide and assist you throughout your engagement.
We take pride in the quality of services we provide. Check our testimonial section to see what our clients speak about us.
We are very straightforward with our approach. If something in your plan is not likely to work out we will be frank to tell you so.