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FUND MANAGEMENT

A Beginner's Guide to MAS License Applications in Singapore

July 2022

Andrew Macintosh

Many fund management companies and fund managers choose Singapore as an ideal location to store their wealth and conduct business due to its clear regulation and stable government. The high level of trust and confidence can be seen via Singapore’s assets under management (AUM) that keep increasing. In 2019, its AUM grew 15.7% to S$4.0 trillion. That figure ballooned to S$4.7 trillion a year later, signalling a 17% increase year on year. 


With no signs of slowing down, Singapore is a fertile ground for fund management to flourish. However, establishing a presence in the Merlion city is not as simple as one may think. A company must be incorporated to be able to conduct business there. 


Companies providing financial products and services must also obtain a licence from the Monetary Authority of Singapore (MAS) to be operational. Doing so means complying with the latest Payment Services Act (PSA), which was released in 2020.

Read our guide on the Singapore MAS here.


Under the PSA, there are currently seven activity types covered, meaning that if you carry out one or all of these activities, you should be a licensed entity. The seven activities are as follows:


  1. Account issuance services: Issuing, maintaining or operating a payment account in Singapore. 

  2. Domestic money transfer services: Payment transactions executed through a payment account in Singapore

  3. Cross-border money transfer services: Providing services that facilitate inbound and outbound money transfer.

  4. Merchant acquisition services: Supplying point-of-sale terminals or online payment gateways for merchants to accept and process payments.

  5. E-money issuance: Services that enable the storing of digital money in any currency for payment and transfer purposes.

  6. Digital payment token (DPT) services: Services that facilitate the exchange and payment of digital payment tokens.

  7. Money changing service: Buying or selling of foreign currency notes in Singapore.


Types of licences under the Payments Services Act

 

There are three types of licences to choose from. Each of which has its own criteria and requirements. This article will discuss each licence in detail to help you decide which is right for your company.


1. Money-changing licence


This licence is for those who only conduct money-changing services, the service of buying and selling foreign currency notes. Individuals and corporations can obtain it, whether locally or foreignly owned. 


2. Standard payment institution licence


This licence is issued to companies with approximately S$3 million in monthly transactions for any payment service, aside from e-money account issuance and money-changing services. Moreover, they need to have an estimated S$5 million in daily outstanding e-money. 


3. Major payment institution licence


This licence is issued to companies with more than S$3 million in monthly transactions for any payment service, aside from e-money account issuance and money-changing services. Additionally, they need to have exceeded S$5 million in daily outstanding e-money.


Who can apply?


1. Money-changing licence

Any applicant for this licence should have a minimum of 1 year's relevant working or business experience full-time. They also need to decide what structure the business would be in, whether it is individually-owned, a partnership or limited liability partnership (LLP), Singapore-owned, or a foreign-owned company. The type of business chosen will impact the governance requirements:

- Individuals: The applicant must be a Singapore citizen for a sole proprietorship.

- Partnership or LLP: The majority of its partners should be Singaporean citizens. In the case of a partnership formed between two people, only one needs to be a Singaporean citizen.

- Singapore-owned company: Most of its shareholders and Board of Directors must be Singaporean citizens. If there are only two directors, only one must be a Singaporean citizen.

- Foreign-owned company: The parent company of a subsidiary incorporated in Singapore must have a significant size, meaning it ranks as one of the top banks in the place of origin. Moreover, the parent company must possess a good track record and reputation, and be regulated and supervised by its home authority regarding Anti-Money Laundering and Combatting the Financing of Terrorism (AML/CFT) practices.


2. Standard payment institution licence and major payment institution licence

The criteria to obtain either licence are the same; the only difference is the minimum capital needed. The applicant must have a minimum capital  of S$100,000 for a standard payment institution licence and a S$250,000 minimum capital for a major payment institution licence:

- The applicant must be a Singapore-incorporated company or a foreign corporation registered in Singapore.

- The applicant must have a permanent place of business or a registered office.

- The applicant's board of directors should have either:

- At least one executive director who is a Singapore citizen or Singapore permanent resident.

- At least one non-executive director must be a Singapore citizen or permanent resident, and at least one executive director must hold a valid employment pass.


What are the admission criteria?


1. Money-changing licence


When assessing an application for a licence, MAS takes several factors into consideration such as the following:


- The applicant's fitness and propriety. Meanwhile, in the case of a corporation, partnership, or limited liability partnership, the fitness and propriety of its management.

- The applicant's financial condition; if the applicant happens to be a company, partnership, or limited liability partnership, its track record and financial performance in previous years.

- The ownership and shareholding structure.

- The qualifications and experience, particularly in operating AML/CFT practices.

- The business plan and model, including AML/CFT policies and procedures.

- Whether the public interest will be served by granting a licence.


2. Standard payment institution licence and major payment institution licence


It can be said that getting a money-changing licence is easier than getting either of these licences as there are nine admission criteria, three more than for a money-changing licence. Regardless, they both share the same admission criteria as follows:

- The fitness and propriety of the controllers and directors.

- The governance structure.

- The qualifications and experience, particularly in operating a payment services business and compliance with regulatory requirements.

- The financial condition and track record.

- The business plan and model, including operational readiness.

- The ability to comply with obligations under the PS Act, including compliance, safeguarding, technology risk management, and audit arrangements.

- The regulatory status in other jurisdictions, where applicable.

- For applicants with a holding company, a commitment to operations in Singapore.

- Whether the public interest will be served by granting a licence.


How to apply


As a region that prides itself on being technology-savvy, MAS licence applications are done online via the MAS website. Applicants must fill in and submit Form 1 – Application for a Payment Service Provider Licence by logging in with their corporate SingPass. 


You can access the site here.


How much are the licence fees?


All applicants are required to pay a non-refundable application fee. The applicable fees depend on the licence type and payment services applied for. The most affordable is surely the money-changing licence with S$500. Meanwhile, the fee breakdown for standard payment institution licence and major payment institution licence can be seen on the table below.


Activity Type                                                                   

Standard Payment Institution                       

Major Payment Institution                                           

Account issuance service

S$0

S$0

Domestic money transfer service

S$1,000

S$1,500

Cross-border money transfer service

S$1,000

S$1,500

Merchant acquisition service

S$1,000

S$1,500

E-money issuance service

S$1,000

S$1,500

Digital payment token service

S$1,000

S$1,500

Money-changing service

S$500

S$500


Validity and renewal


Once a licence is obtained, it will remain valid until one of the following:


- The licence is revoked by MAS due to issues such as not complying with the AML/CFT standards

- The licence lapses in accordance with section 11(1) of the PS Act and regulation 10 of the Payment Services Regulations

- The holder surrenders its licence.


All entities that cease to hold a licence will be removed from the Financial Institutions Directory.

Singapore is an attractive place for the fund management and financial services industry to conduct business, but remember that to be operational here, all economic entities must have a valid licence. We hope this article will help you decide which licence is suitable for your business and help you understand the criteria and requirements needed, easing the process for you.

If you want a hassle-free experience, contact Lanturn to assist you. We have a proven track record in answering every business need, including getting the required licence so that financial institutions can conduct their business legally and smoothly in Singapore. Lanturn can make fundraising easier.

You can also read our guide on Fund Administration in Singapore for 2022.

Contact Lanturn now.


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