Singapore MAS DTSP Licensing Regime: What does it mean for Crypto projects?

On 30 May 2025, the Monetary Authority of Singapore released its final framework for Digital Token Service Providers (DTSPs) under Part 9 of the Financial Services and Markets Act 2022. This requires any individual, partnership, or Singapore-incorporated entity that provides digital token services to overseas clients to obtain a DTSP licence by 30 June 2025, or cease operations.

• Source: Reed Smith – MAS finalises and clarifies regulatory regime for DTSPs “licences will be granted only in exceptional cases, with no transitional period – unlicensed providers must stop operations by 30 June 2025.”

Who Is Affected?

1. Singapore-incorporated entities or those operating from Singapore offering digital payment tokens or tokenised capital market products to overseas users must apply for a DTSP licence—unless they already hold licences under the PSA, SFA, or FAA.
   • Source: Duane Morris & Selvam – MAS Issues Clarification on the Regulatory Regime for DTSPs
2. Those dealing only in utility tokens, governance tokens, or NFTs are not covered by the regime.
   • Source: Fintech News Singapore – Singapore Gets Tough on Offshore Crypto Operators
   • Source: Allen & Gledhill – Regulatory framework for DTSPs under FSMA
3. Entities already licensed under PSA, SFA, or FAA are exempt—even if serving overseas clients.
   • Source: Reed Smith
   • Source: Straits Times – MAS clarifies position on regulation of DTSPs

Key Requirements and Deadline

• No grace period: Unlicensed providers must stop overseas operations by 30 June 2025.
  • Source: Reed Smith
  • Source: Blockhead – MAS sets hard June 30 deadline
• Licences limited to exceptional cases, requiring strong AML/CFT compliance, robust governance, and justification for no Singapore services.
  • Source: Duane Morris & Selvam
  • Source: 99Bitcoins – Deadline for DTSPs
• Ongoing obligations include:
  • Minimum S$250,000 base capital, plus a S$10,000 annual licence fee
  • Appointment of a full-time compliance officer in Singapore
  • Annual independent audits, AML/CFT processes, technology risk controls (≤4 hours downtime), and physical office presence ≥10 days/month
  • Sources: Duane Morris & Selvam; Fintech News; Reedsmith; Reed Smith; Straits Times; Ingenia Consultants

Strategic Scenarios: Your Next Steps

Situation	Requirement
Singapore-based, offering payment or capital‑market tokens overseas	Must get DTSP licence by 30 Jun 2025
Already licensed under PSA/SFA/FAA	Exempt from DTSP requirement
Only issuing utility/governance tokens	Regime does not apply
Fully offshore, no Singapore presence	Regime does not apply
Singapore-incorporated but serving overseas users	Must be licensed unless exempt

What You Should Do Now

1. Classify your tokens – Determine if they are payment or tokenised capital‑market tokens.
2. Check your licences – PSA/SFA/FAA licences = exemption.
3. If in scope:
   • Prepare application now
   • Appoint a Singapore-based full-time compliance officer
   • Draft AML/CFT, risk, cyber, and audit frameworks
   • Secure S$250,000 capital and budget for S$10,000 yearly fees
4. If not applying: plan service cessation by 30 June 2025
5. Contact MAS: email AMLCFT@mas.gov.sg for clarifications
   • Source: Straits Times; Duane Morris & Selvam
6. Consult legal advisors: Reed Smith, Duane Morris & Selvam, Allen & Gledhill, Resource Law, etc.

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Final Thoughts

With the DTSP framework, MAS is clearly extending its reach to eliminate regulatory loopholes for Singapore-based crypto services. Only well‑compliant, materially present operators will be granted licences. Smaller or utility‑focused projects have more operational freedom.

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