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MAS Notice PSN02 requires travel-rule-compliant transmission of originator/beneficiary information for cross-border DPT transfers, refreshed via June 2025 AMLD-amended guidelines, alongside sanctions and counter-terrorism-financing obligations. The 2024 PS Act amendments extended licensing to cross-border transfer facilitation, including facilitation where funds are not received in Singapore, without imposing any outbound capital-control restriction.
The 2024 amendments to the Payment Services Act materially reshaped the scope of cross-border regulation without imposing any new restriction on outbound transfers themselves. Rather than a capital-control mechanism, the amendments extended PS Act licensing to the facilitation of cross-border money transfers between other countries, including facilitation arrangements where funds are never received in Singapore -- bringing a category of activity that previously sat outside the licensing perimeter within MAS's licensing and reporting remit. The practical effect is a broader population of firms now subject to cross-border-specific obligations, rather than any narrowing of the transfers Singapore-regulated firms are permitted to execute.
Outlook
The travel-rule and sanctions-nexus components of this module are settled and unlikely to change materially in the near term; they are core, long-standing AML/CFT-adjacent obligations. The more active area is scope: having only recently extended licensing to a wider population of cross-border facilitation activity, the next research cycle should watch for MAS guidance clarifying how the newly captured facilitation-only firms are expected to apply the existing PSN02 travel-rule and enhanced-due-diligence requirements in practice.
Cross-Border Transfer
MAS Consultation Paper P015-2026 proposes a significant liberalisation of Singapore's cross-border stablecoin policy, reversing the Singapore-only-issuance position MAS set in 2023. Under the proposal, MAS would recognise a limited number of well-regulated foreign stablecoins for use or acceptance in Singapore, and would permit the same fungible stablecoin to be issued simultaneously from Singapore and one or more foreign jurisdictions. This is a notable policy reversal: the 2023 non-statutory SCS policy had confined MAS's "regulated stablecoin" label to Singapore-only issuance, and the new proposal would open that label to multi-jurisdiction issuance structures provided the foreign regulatory regime meets MAS's recognition standard.
This liberalising cross-border proposal runs in parallel with the tightening reserve, redemption and systemic-designation provisions described under the stablecoin-regime reading of this same consultation paper, illustrating that CP P015-2026 is not a uniformly tightening instrument: it simultaneously raises the prudential bar for regulated stablecoin issuers while opening the regulated-stablecoin label to cross-border issuance structures that were previously excluded.
Outlook
The criteria MAS will use to determine which foreign jurisdictions and stablecoin regimes qualify as "well-regulated" for recognition purposes have not yet been specified, and are expected to be addressed in subsidiary legislation following the 16 October 2026 consultation close. How many foreign stablecoins are ultimately recognised, and which jurisdictions' regimes MAS treats as meeting its standard, will be a key indicator of how open the eventual cross-border regime becomes in practice.
Sources and findings (5)
- T2 · Monetary Authority of SingaporeMAS Notice PSN02 — DPT service providers effecting cross-border DPT value transfers to transmit originator and beneficiary information to the beneficiary VASP immediately and securely, consistent with FATF Recommendation 16 (travel rule)retrieved M5bindingin forcenew
- T2 · Monetary Authority of SingaporeMAS Notice PSN02 — Enhanced risk-mitigating measures, such as additional counterparty due diligence, for DPT transfers to private or unregulated walletsretrieved M4bindingin forcenew
- T1 · Monetary Authority of SingaporeFSM Sanctions Regulations / Terrorism (Suppression of Financing) Act — Payment service providers, including DPT service providers, to comply with targeted financial sanctions (currently covering DPRK and Iran) and TSOFA counter-terrorism-financing obligationsretrieved M5bindingin forcenew
- T1 · Monetary Authority of SingaporePayment Services Act 2019 (2024 amendments) — A general outbound capital-control restriction on cross-border DPT transfers by licensed providers; the 2024 amendments extended licensing to cross-border transfer facilitation rather than restricting such transfers outrightretrieved M3bindingin forcenew
- T1 · Monetary Authority of SingaporePayment Services Act 2019 (2024 amendments) — Cross-border money transfer service regulation to facilitation of transfers between other countries even where funds are not received in Singapore, bringing such facilitation within PS Act licensing and reporting obligationsretrieved M3bindingin forcenew