Singapore: Crypto Licensing

A second and more recent development concerns activity outside Singapore rather than within it. The Financial Services and Markets Act 2022's Part 9 Digital Token Service Provider regime came into force on 30 June 2025, requiring Singapore-incorporated entities that provide digital token services exclusively to overseas customers to hold a DTSP licence. MAS's accompanying clarification signalled that such licences will generally not be granted, given the elevated money-laundering supervision risk MAS associates with firms whose customer base and activity sit entirely outside Singapore's own AML/CFT reach -- a materially different posture from the domestic DPT regime, which is permissive of licensed operation once conduct and prudential requirements are met. The same clarification carved out an exemption: providers whose services relate only to utility or governance tokens fall outside both the DTSP and domestic DPT licensing perimeters, consistent with MAS's broader substance-over-form approach to token classification.

Taken together, the licensing architecture functions as two distinct regimes under two different statutes, administered by the same regulator, with materially different postures toward the activity each is designed to capture: an open, mature domestic regime for businesses actually serving the Singapore market, and a closed-in-practice extraterritorial regime aimed at discouraging Singapore incorporation as a jurisdiction of convenience for offshore-only crypto activity.

Outlook

The domestic PS Act licensing track is unlikely to see structural change in the near term; its next points of evolution are more likely to be incremental guidance updates than fresh primary legislation. The DTSP track is the more active watch item: whether MAS has granted any DTSP licences since the regime's June 2025 commencement, and what enforcement posture it adopts toward Singapore-incorporated firms that continue overseas-only activity without a licence, remain open questions for the next research cycle. Any move by MAS to publish DTSP licensing statistics or enforcement notices would materially sharpen the current assessment of how restrictive this regime is in practice, as distinct from how restrictive it is on paper.