Webinar Recap: The Journey to a Crypto License in Singapore

Last week, TRM Labs’ Angela Ang (Head of Policy and Strategic Partnerships, APAC) was joined by Grace Chong (Head, Financial Services Regulation, Drew & Napier), Rajiv Premkumar (CEO/Founder, Curia Regis), and Chun Hou Kok (Head of Legal and Compliance, HashKey Singapore) to discuss the journey of applying for a digital payment token service provider (DPTSP) license from the Monetary Authority of Singapore (MAS) under the Payment Services Act. 

The panel reflected on their first-hand experiences around: 

• How the licensing process in Singapore has evolved (and what lies ahead)
• Navigating the license application and regulatory engagements
• Compliance and risk management as a regulated crypto business in Singapore

Read on for highlights and key takeaways from the session, or watch the full recording below.

Evolution of crypto licensing in Singapore

The panel noted that, in the five years since the implementation of the DPTSP licensing regime, MAS has gained a deeper understanding of the industry and how it wants DPTSPs to implement its regulatory requirements. Consequently, the regulators are stress testing many more aspects of the application early on in the licensing process. This means that applicants receive a lot more clarity upfront, but also requires that applicants are fully prepared to address every aspect of their application in-depth from day one. 

The panel highlighted that preparing for the application alone was a significant time investment, which could stretch over six months or more. Chun Hou emphasized that “a lot of planning, resource allocation, and work has to be put in place before you submit the application.” However, this upfront investment would equip businesses to better navigate the actual application process, as they would have “everything in substance ready to go.”

Substance over form

The panelists emphasized the importance of having the right mindset and expectations toward the licensing process. Most crucially, they noted that the licensing process shouldn’t be treated as a checkbox exercise, where businesses focus on checking off a list of documents or requirements for their application, but rather as an opportunity to demonstrate the business’ commitment to compliance and risk management.

Angela noted that understanding MAS’ Guidelines on Licensing for Payment Service Providers was important, but emphasized that the guidelines are just a starting point. MAS’ expectations for how the guidelines are implemented differ based on the size, scale, and nature of each business — and it’s vital that applicants apply them to their organizations’ specific business models. 

Specifically, key success factors include:

• A deep understanding of anti-money laundering (AML) and counter-terrorist financing (CFT) obligations for DPTSPs, as detailed in MAS Notice PSN02 and other related documents
• Robust governance frameworks with strong internal controls
• An experienced compliance team capable of managing regulatory expectations
• Sufficient financial and operational resources to support long-term compliance

Notably, an underqualified compliance officer is one of the most common reasons for application rejection. Beyond qualifications, the panel emphasized that compliance officers must have a clear understanding of the company’s risk profile and business model, and demonstrate the ability to contextualize MAS’ regulatory requirements to the business. 

Grace shared that, during the application interview, MAS now expects compliance to be able to independently address queries on the business, and vice versa. While challenging, this helps determine if the business model has been internalized by compliance, and reflects if the business understands its compliance obligations. 

Rajiv also emphasized the importance of authenticity in both the licensing and supervisory journey, noting that meeting expectations is “a lot more difficult if you're putting on a show and tell, [...] acting like you're someone that you're not.” Conversely, if compliance is deeply embedded in a company’s operations and culture, it will show naturally. 

The significance of a Singapore license

While seeking a license in Singapore is a significant investment, a DPTSP license is also regarded by many as a benchmark for crypto regulatory compliance. Therefore, securing the license often leads to:

• Stronger banking and financial relationships
• Enhanced credibility with institutional investors
• A strategic advantage when expanding into other regulated markets

That said, the right jurisdictions to seek licensing can vary depending on business objectives. Panelists advised businesses to align their licensing strategy with their broader operational and regulatory goals before pursuing an application. 

Wrapping up the discussion, the panellists emphasized the importance of having a strong compliance culture and understanding that there is not one set formula for success.  

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For more on how crypto businesses can strengthen their compliance programs, download our crypto compliance white paper here.