Head of International Corporate Law and Fintech Practice
Expert in fintech, crypto, and international corporate law with over 20 years of experience. Specializes in crypto licensing (VASP/CASP), iGaming business support, and international structuring, asset protection, and OSINT analytics for risk assessment and due diligence.
OBTAINING A CRYPTO LICENSE IN SINGAPORE
Today, Singapore is one of the well-known jurisdictions that has established regulation of cryptocurrency exchanges.
Legal regulation: in 2019, the new Law on Payment Services entered into force, which introduced 2 types of license: SPI (standard payment institution) and MPI (major payment institution).
Let’s take a closer look at SPI
Activities that are allowed with this license:
- activity with digital tokens;
- emission of electronic money -money transfers within the country;
- International money transfers;
- payment processing;
- Creation of electronic wallets.
It is important to remember that with such a license there are restrictions on the volume of transactions:
- S$3 million in monthly transactions for each business (excluding e-money and money exchange services)
- S$6 million in monthly transactions for two or more payment services (excluding e-money and money exchange services)
- not more than 5 million Singapore dollars for daily payments (daily money float).
Note that organizations that only provide money exchange services must have a money exchange license instead. Companies that provide payment services exceeding the specified amounts must have a license from the main payment institution.
Who can apply for such a license?
Among the main criteria:
- must be a Singapore-registered company or a Singapore-registered foreign corporation;
- presence of a permanent place of work or legal address.
It should be an office space where your documents and records can be securely stored. You must also appoint at least one person to be present to deal with any customer inquiries or complaints on at least ten days per month and for at least eight hours on each of those days during normal business hours
- The minimum initial capital is S$100,000. For MPI-250,000.
NOTE. The initial capital requirements must be met at the time of the license application. However, if the applicant has legitimate reasons why the entity cannot currently contribute such an amount and has plans to raise capital (for example through fundraising), this should be detailed in the application.
- The applicant’s board of directors must have at least 1 executive director who is a Singaporean citizen or permanent resident of Singapore at least 1 non-executive director who is a Singaporean citizen or permanent resident of Singapore and at least 1 executive director who is a Singaporean employment record holder.
The executive directors must be involved in the day-to-day management and executive decision-making on behalf of the applicant company. They may reside in Singapore to supervise the activities of the licensee. Nominee directors such as investors, legal advisors, or corporate secretaries are not executive directors. Non-executive directors exercise oversight as members of the Board of Directors but are not involved in the day-to-day operations or activities of the licensee.
When assessing the submitted application, the regulator takes into account such factors as:
- Management structure.
- Qualifications and experience, in particular in the provision of payment services, and compliance with regulatory requirements.
- Financial position.
- A clear business plan.
- Ability to comply with obligations under the Law on Payment Services including compliance, technology risk management, and audit.
License fee
- Payment institutions are required to pay an annual license fee, and the corresponding fees depend on the payment services they are licensed to provide.
- Commission according to the type of activity.
- Account service.
- Domestic money transfer service – SGD 10,000.
- Cross-border money transfer service – SGD 10,000.
- Service for the issuance of electronic money – SGD 10,000.
- Digital Payment Token Service – SGD 10,000.
- Money exchange service SGD 1500.
What services do we offer?
Legal support for company registration in Singapore
- legal assistance in obtaining a license for payment services
- legal support and opening a bank account
Our experienced team has processed a large number of licenses in Singapore and around the world. Please fill out the contact form below and a lawyer from our team will contact you.
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