REGULATIONS

Crypto Travel Rule
in

Singapore

🇸🇬
Regulator
Travel Rule required from
Travel Rule regulation still pending
January 28, 2020

The Monetary Authority of Singapore (MAS) introduced guidance for the crypto industry covering the Travel Rule on December 5, 2019, called Notice PSN02 Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service, which went into effect on January 28, 2020. Notice PSN02 requires VASPs to implement the travel rule for all transaction sizes and prove ownership of non-custodial wallets. The MAS goes a bit further than other jurisdictions; for transfers exceeding SGD 2000 (USD ~1500), the originator VASP should also add a physical address, along with the customer’s place and date of birth. PII records are required to be stored for at least five years.

Is cryptocurrency legal in Singapore?

Yes. It is legal to both own and to trade cryptocurrencies in Singapore. Singapore has been at the forefront of embracing and implementing blockchain and DLT alongside countries like Switzerland and Estonia. 

Are there any AML crypto regulations in Singapore?

Yes. On December 5, 2019, the MAS released the notice entitled “Prevention of Money Laundering and Countering the Financing of Terrorism - Holders of Payment Service License (Digital Payment Token Service), which mandated the Crypto Travel Rule in Singapore.

Is the Crypto Travel Rule mandated in Singapore?

Yes. On December 5, 2019, The Monetary Authority of Singapore (MAS) introduced guidance Notice PSN02 - Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service. MAS covers the Travel Rule in paragraph 13 of Notice PSN02:

13.1 Paragraph 13 shall apply to a payment service provider when it effects the sending of one or more digital payment tokens by value transfer or when it receives one or more digital payment tokens by value transfer on the account of the value transfer originator or the value transfer beneficiary but shall not apply to a transfer and settlement between the payment service provider and another financial institution where the payment service provider and the other financial institution are acting on their own behalf as the value transfer originator and the value transfer beneficiary.

It requires VASPs to prove ownership of non-custodial wallets.

Who regulates cryptocurrency in Singapore?

The Monetary Authority of Singapore(MAS) regulates cryptocurrency in Singapore.

FATF Travel Rule requirements in Singapore

Are there licensing or registration requirements for VASPs in Singapore?

Yes. In addition to guidance on the Travel Rule, Singapore introduced a new law, the Payment Services Act, requiring crypto businesses operating in Singapore to be registered and licensed. The Act came into effect on January 28, 2020. Crypto firms and exchanges fall under the definition “digital payment token services” and will now have to comply with anti-money laundering (AML) and counter financing of terrorism (CFT) requirements. As of August 2021, crypto companies are starting to receive their licenses.

When does the Crypto Travel Rule go into effect in Singapore?  

The Crypto Travel Rule went into effect on January 28, 2020. 

Does Singapore permit a grace period to comply with the Crypto Travel Rule?

MAS has provided an exemption period, during which entities who fall under this definition and want to continue operating in Singapore need to notify MAS and apply for a license. As of June 21, 2020, 195 entities identified themselves as providing “digital payment token services” and had notified MAS (see link). 

This exemption period expires on July 28, 2020, for crypto firms, after which all registered crypto firms in Singapore will need to be compliant with local MAS regulations on AML/CFT, including the Travel Rule.

Complying with the FATF Crypto Travel Rule in Singapore

What is the minimum threshold for the Crypto Travel Rule in Singapore?

The crypto Travel Rule threshold is set at S$1500, which is roughly USD 1100.

For transactions below S$1,500, only the following information is required to be shared:

  • Originating customer’s name and account number
  • Beneficiary’s name and account number (in receiving institution)

It’s interesting to note that to be covered by this simplification, the following rules apply:

  • KYC and complete originating customer information need to be provided by the originating institution on request within three business days to either the beneficiaries, the MAS itself, or law enforcement authorities in Singapore.
  • The originating institution is required to fulfill this even if they are not in Singapore.

What personally identifiable information is required to be shared for the Crypto Travel Rule in Singapore?

Notice PSN02 Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service Section 13.4:

(II) Value Transfers Below or Equal To S$1,500

13.4
(a) the name of the value transfer originator;
(b) the value transfer originator’s account number (or unique transaction reference
number where no account number exists);
(c) the name of the value transfer beneficiary; and
(d) the value transfer beneficiary’s account number (or unique transaction reference number where no account number exists).

For value transfers below or equal to S$1,500

13.5
In a value transfer where the amount to be transferred is below or equal to S$1,500, every
payment service provider which is an ordering institution may, in the message or payment
instruction that accompanies or relates to the value transfer to an intermediary institution
in Singapore, include only the unique transaction reference number and the value transfer
beneficiary information set out in paragraph 13.4(c) and (d), provided that
(a) the unique transaction reference number will permit the transaction to be traced
back to the value transfer originator and value transfer beneficiary;
(b) the ordering institution shall provide the value transfer originator information and
value transfer beneficiary information set out in paragraph 13.4(a) to (d) within 3
business days of a request for such information by the intermediary institution in
Singapore, the Authority or other relevant authorities in Singapore;
(c) the ordering institution shall provide the value transfer originator information and
value transfer beneficiary information set out in paragraph 13.4(a) to (d)
immediately upon request for such information by law enforcement authorities in
Singapore; and
(d) the ordering institution shall provide the value transfer originator information and
value transfer beneficiary information set out in paragraph 13.4(a) to (d) to the
beneficiary institution.

For value transfers exceeding S$1,500 (approximately USD 1500), the originating VASP should also add a physical address, along with the place and date of birth, of the customer. Records are required to be kept for at least five years.

13.6
Subject to paragraph 13.8, in a value transfer where the amount to be transferred exceeds
S$1,500, every payment service provider which is an ordering institution shall identify the
value transfer originator and verify his or its identity, and include in the message or
payment instruction that accompanies or relates to the value transfer the information
required by paragraph 13.4(a) to 13.4(d) and any of the following:
(a) the value transfer originator’s
(i) residential address, or
(ii) registered or business address, and if different, principal place of business,
as may be appropriate;
(b) the value transfer originator’s unique identification number (such as an identity
card number, birth certificate number or passport number, or where the value
transfer originator is not a natural person, the incorporation number or business registration number); or
(c) the date and place of birth, incorporation or registration of the value transfer
originator (as may be appropriate).


Records are required to be kept for at least five years.

Are there differences in customer PII requirements for cross-border transfers versus transfers within Singapore?

The Notice PSN02 did not mention a difference in requirements for cross-border transfers. 

What are the non-custodial or self-hosted wallet requirements in Singapore?

The MAS provided further guidance in their Guidelines about AML for Digital Payment Token Services from March 16, 2020. In particular, of interest is their recommendation on how VASPs should handle their interactions with non-custodial wallets.

13-7
For the avoidance of doubt, paragraph 13 of the Notice does not apply to transfers of DPT received from or made to persons who do not fall within the definition of an “ordering institution” or a “beneficiary institution,” respectively. A payment service provider may therefore choose to engage in such transactions without applying the requirements set out in paragraph 13. However, as required under paragraph 6.27 of the Notice, the payment service provider should recognise that such transactions may present higher ML/TF risks, and apply appropriate enhanced risk mitigation measures, which could include but are not limited to – (a) identifying and verifying the identities of the originator and beneficiary of the transfers: (i) where the transfer of DPT has been received from or sent to the payment service provider’s own customer’s personal wallet address, requiring the customer to demonstrate control over the said wallet address, by effecting a transfer of DPT of an amount specified by the payment service provider;

In other words, this aligns with the FATF guidelines on Virtual Assets that VASPs can send funds to non-custodial wallets, but they should KYC the owner and prove they control it.

Why choose Notabene for Crypto Travel Rule Compliance in Singapore?

Notabene helps Singaporean financial institutions and VASPs comply with the FATF’s Recommendation 16 “Crypto Travel Rule” as required by the Monetary of Singapore. At Notabene, we can help Singaporean VASPs prove the ultimate beneficial ownership of their customers’ blockchain accounts for both custodial and non-custodial wallets, collect missing data, and store counterparty PII in a GDPR-compliant way. 

Last updated
August 23, 2021

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