Major Payment Institution license in Singapore

Major or Standard Payment Institution license in Singapore

Major Payment Institution license in Singapore

We assist in the full licensing process of obtaining a Major or Standard Payment Institution license in Singapore

If you are looking to obtain an a Major or Standard Payment Institution license in Singapore, Advapay can offer you its legal, technical and business expertise and consulting support.

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Application preparation, communication with the regulator, business services

Filling out an application form

Communication with regulatory authority during the application phase

Assistance in the development of a business plan

Assistance in the opening of safeguarding accounts

Company formation, staffing services

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Preparation of legal, financial and IT documents

Legal documents – AML, KYC, IT/Security policies, etc.

Financial documentation – 3-years financial forecast, P&L statement, the flow of funds

Company operational documentation – internal policies, risk operation policies, internal audit, etc.

IT documentation

Overview of the Singapore fintech market

Singapore was ranked 2nd in the 2021 Bloomberg Innovation index and 1st in IMD World Competitiveness Ranking 2020, and in the Singapore Exchange Limited report 2021, Singapore looked as an Asian capital of fintech with more than 750 Financial technology companies based in Singapore.

2021 has been a great year for fintechs globally, but even more so in Singapore. Funding for Singapore fintechs has grown by 2.5 times between 2020 and 2021, according to data from the BCG FinTech Control Tower.

Government provides different initiatives to promote fintech sector:
– Fintech Innovation Lab,
– Financial sector technology and Innovation proof-of-concept scheme, and
– Fintech regulatory sandbox.

Regulator and legislation

The MAS is the key regulator of the financial services industry in Singapore, and administers various legislation governing financial institutions such as banks, insurers and insurance intermediaries, capital market intermediaries, financial advisers and stock exchanges.

The Payment Services (PS) Act is a forward looking and flexible framework for the regulation of payment systems and payment service providers in Singapore. It provides for regulatory certainty and consumer safeguards, while encouraging innovation and growth of payment services and FinTech.

The Terrorism (Suppression Of Financing) Act 2002 suppresses the financing of terrorism, to give effect to the International Convention for the Suppression of the Financing of Terrorism and for matters connected therewith.

Types of Payment Services

Activity A – 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.

Activity B – Domestic money transfer service
Providing local funds transfer service in Singapore. This includes payment gateway services and payment kiosk services.

Activity C – Cross-border money transfer service
Providing inbound or outbound remittance service in Singapore.

Activity D – 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.

Activity E – E-money issuance service
Issuing e-money to allow the user to pay merchants or transfer to another individual.

Activity F – 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.

Activity G – Money-changing service
Buying or selling foreign currency notes.

Types of Payment Institution licenses in Singapore

A Money-changing (“MC”) licence

For companies if they only intend to carry out moneychanging service

A Standard Payment Institution (“SPI”) licence

For companies if they intend to conduct payment services below the specified thresholds:
• S$3m monthly transactions for any activity type
• S$6m monthly transactions for two or more activity types
• S$5m of daily outstanding e-money

A Major Payment Institution (“MPI”) licence

This type of license for companies if they intend to conduct payment services without being subject to the specified thresholds.

Applicable requirements

1 – The applicant must be a Singapore incorporated company or Singapore branch of a foreign corporation and be registered with Accounting and Corporate Regulatory Authority (ACRA).

• At least one Executive Director of the applicant is a Singapore citizen or permanent resident; or,
• At least one Executive Director of the applicant is a Singapore Employment Pass holder and at least one other director of the applicant is a Singapore citizen or permanent resident.
 
2 – Fit and Proper requirements – sole-proprietor, partners, or directors and CEO, shareholders and employees, as well as the applicant itself must be fit and proper in accordance with the Guidelines on Fit and Proper Criteria.
 
3 – Competency of Key Individuals – a sole proprietor, partners, or executive directors and CEO must have sufficient experience in operating a business in the payment services industry or related areas in the financial services industry as well as to have the educational qualifications and professional certification.
 
4 – Permanent place of business or registered office.
 
5 – Information about the business: the applicant should provide a clear description of its business model and plans –  jurisdictions serviced, profile of target clientele, proposed products and services, detailed funds flow plan and channels, implementation plans, including the anticipated timeline for launch, as well as systems, processes, and third parties that will perform a key role in its operations.
 
6 – Minimum Initial Capital requirements:
– For SPI – S$100,000
– For MPI – S$250,000
 
7 – Security in the form of a cash deposit with MAS or a bank guarantee:

– S$100,000 for all payment transactions, which the average value per one month does not exceed S$6 million for any one payment service;

– S$200,000 for all other cases.
 
8 – Plans for compliance arrangements that are commensurate with the nature, scale and complexity of the business.
 
9 – Technology Risk Management – a penetration test of its proposed online financial services that must be completed prior to the obtaining a licence.
 
10 – Plans for adequate independent audit arrangements to regularly assess the effectiveness of its procedures, controls, and its compliance with regulatory requirements.
 
11 – Annual Audit Requirements – to perform an audit of its accounts and transactions, and compliance with the relevant regulations and requirements.
 
12 – Letter of Responsibility and/or Letter of Undertaking from the applicant’s majority shareholders, parent company and/or related company (where applicable).
 
13 – Other requirements:
– track record and financial condition of the applicant, its holding company or related corporations (where applicable)
– operational readiness
– proper supervision by a competent regulatory authority (where applicable)
– commitment of the applicant’s holding company to operations in Singapore
– evaluation whether the public interest will be served by granting a licence.

Ongoing Requirements

1 – Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) requirements

2 – Periodic regulatory Returns in relation to its payment service activities

3 – Cyber Hygiene requirements and appropriate safeguards to protect customer information.

4 – Business Conduct – 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.

5 – Disclosures and Communications requirements

Fees

Licence application fee
– For a money-changing licence, S$500.
– For a standard payment institution, S$1,000-5,500.
– For a major payment institution, S$1,500-8,000.

Annual licence fee

A licensee will pay fixed annual fees that correspond to the licence type and types of payment services it conducts:
– Money-changing licensees – S$1,500.
– Standard payment institutions S$5,000-26,500
– Major payment institutions S$10,000-56,500

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