MAS in Singapore Comprehensive Payments Framework

MAS in Singapore has started an open consultation process on establishing a new regulatory regime for payments. The intention is to consolidate separate licensing regimes into one overall scheme.

MAS states that a “calibrated regulatory regime, applied on an activity basis to payment service providers, rather than specific payment systems” is the framework that they want to adopt. This framework is referred to by MAS as the Proposed Payments Framework (PPF).

This would mean that entities would seek one licence from MAS but select varying permissions depending on the activities that business conducts.

Here is the suggested list of activities (emphasis added):

Activity 1: Issuing and maintaining payment instruments, such as payment cards, payment accounts, electronic wallets, and cheques1; 

Activity 2: Acquiring payment transactions, such as physical and online merchant acquisition services, merchant aggregators, and master merchants; 

Activity 3: Providing money transmission and conversion services, such as domestic and in-bound/out-bound cross-border remittance services, currency-conversion services, and virtual currency intermediation services; 

Activity 4: Operating payments communication platforms, such as payment gateways, payment processors, and kiosks; 

Activity 5: Providing payment instrument aggregation services, such as payment card aggregation and bank transaction account aggregation;

Activity 6: Operating payment systems which facilitate the transfer of funds through processing, switching, clearing, and/or settlement of payment transactions; and, 

Activity 7: Holding stored value facilities (“SVFs”), such as prepaid cards and prefunded electronic wallets.

MAS is proposing to including ‘virtual currency intermediation services’ as a regulated activity. It is not clear how many different types of blockchain companies this definition will include but of importance is that there would not be a separate licence for a virtual currency operator.