[TRM] The Journey to a Crypto License in Singapore

1. Evolution of Crypto Licensing in Singapore

Regulatory Progress: Since the introduction of the Digital Payment Token Service Provider (DPTSP) license under the Payment Services Act (PSA), MAS has gained a deeper understanding of the industry and its regulatory needs.
More Rigorous Process: MAS now conducts more detailed stress testing of applications early in the process, offering clarity upfront but demanding comprehensive preparation from applicants.
Preparation Time: Preparing for the application can take 6 months or more, with significant planning and resource allocation needed to ensure everything is in place before submission.

2. Substance Over Form in the Application

Mindset Shift: The licensing process should not be seen as just checking boxes but as a chance to demonstrate a commitment to compliance and risk management.
Understanding MAS Guidelines: While the MAS Guidelines are a good starting point, they must be tailored to each company’s specific business model and operations.
Key Success Factors:
- Deep understanding of AML/CFT obligations (MAS Notice PSN02).
- Strong governance frameworks and internal controls.
- A skilled compliance team.
- Sufficient financial and operational resources for long-term compliance.

3. Significance of a Singapore License

Regarded as a Benchmark: A DPTSP license is viewed as a mark of regulatory compliance in the crypto space and can lead to:
- Stronger relationships with banks and financial institutions.
- Enhanced credibility with institutional investors.
- A strategic advantage for expanding into other regulated markets.