The Monetary Authority of Singapore (MAS) implemented the crypto travel rule in Singapore through Notice PSN02 Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service, published on December 5, 2019, and in effect since January 28, 2020. Notice PSN02 requires VASPs to implement the travel rule for all transaction sizes, although wider PII sharing requirements apply to transfers of value above SGD 1,500. The travel rule is further regulated through MAS' Guidelines to Notice PSN02, which most relevantly clarifies that transactions with non-custodial wallets are not subject to travel rule requirements but should be perceived and treated as carrying higher ML/TF risks.
1. Is cryptocurrency legal in Singapore?
Yes. It is legal to both own and trade cryptocurrencies in Singapore. Singapore has been at the forefront of embracing and implementing blockchain and DLT alongside countries like Switzerland and Estonia.
2. Are there any AML crypto regulations in Singapore?
Yes. In Singapore, crypto-related AML regulations are outlined in Notice PSN02 issued by the Monetary Authority of Singapore (MAS) and further specified by MAS' Guidelines to Notice PSN02. The Notice introduces a framework for the prevention of money laundering and countering the financing of terrorism for digital payment token service providers. According to the Payment Services Act (2019) (First Schedule, Part 3), a digital payment token service is any service dealing or facilitating the exchange of digital payment tokens.
3. Who regulates cryptocurrency in Singapore?
The Monetary Authority of Singapore (MAS) is Singapore's central bank and integrated financial regulator. It is responsible for supervising all financial institutions in Singapore and for regulating the financial services sector. This includes regulation of digital payment token services and oversight of providers of such services.
4. Who is the Crypto Travel Rule Regulator in Singapore?
The Monetary Authority of Singapore (MAS) is the entity that issued a regulation implementing the crypto travel rule in Singapore (MAS' Notice PSN02 and Guidelines to Notice PSN02). It is responsible for supervising compliance with the enacted crypto travel rule requirements.
5. Are there licensing or registration requirements for VASPs in Singapore?
In Singapore, VASPs are subject to the licensing requirements outlined in the Payment Services Act (2019) (PSA). Providers of digital payment token services (i.e., service dealing or facilitating the exchange of digital payment tokens) are prohibited from carrying out their businesses except if they hold the required license (PSA, section 5/(1) in combination with First Schedule, Part 1). To obtain the required license, VASPs must apply with the Monetary Authority of Singapore (MAS) (PSA, section 6/(1)).
FATF Travel Rule requirements in Singapore
1. Is the Crypto Travel Rule mandated in Singapore?
Yes, the crypto travel rule is implemented in Singapore through Notice PSN02 issued by the Monetary Authority of Singapore (MAS). The Notice has been in effect since January 28, 2020, and was further specified by MAS' Guidelines to Notice PSN02, issued on March 16, 2020. Section 13 of the Notice sets forth the obligations of VASPs when sending or receiving digital payment tokens on account of an originator or a beneficiary.
2. When does the Crypto Travel Rule go into effect in Singapore?
The crypto travel rule entered into force in Singapore on January 28, 2020 (Notice PSN02, ****section 1.2).
3. Does Singapore permit a grace period to comply with the Crypto Travel Rule?
The Monetary Authority of Singapore (MAS) did not grant a grace period specifically for compliance with the travel rule. However, under the Payment Services (Exemption for Specified Period) Regulations 2019 (Exemption Regulations), MAS allows digital payment token service providers to operate in Singapore without a license (and, therefore, without an attestation of compliance with the travel rule from the regulator) throughout a specific exemption period.
Only entities that were already providing digital payment token services before January 28, 2020, qualified for the exemption and provided that they notified MAS of such fact within 30 days of that date. These entities are granted a period of 6 months counted from January 28, 2020 (i.e., until July 28, 2020) to apply for a license for providing digital payment token services in Singapore. If the license application was submitted in time, the exemption is extended until the application is approved, rejected, or withdrawn (Exemption Regulations, section 7).
Complying with the FATF Crypto Travel Rule in Singapore
1. What is the minimum threshold for the Crypto Travel Rule in Singapore?
In Singapore, the ordering VASP is required to submit originator and beneficiary information to the beneficiary VASP regardless of the transaction amount (Notice PSN02, section 13.4). However, the Notice foresees a threshold of SGD 1,500 above which a wider scope of information needs to be shared (Notice PSN02, section 13.6).
2. What personally identifiable information is required to be shared for the Crypto Travel Rule in Singapore?
In Singapore, the personally identifiable information (PII) that ordering VASPs are required to share with the beneficiary VASPs for compliance with the crypto travel rule varies depending on the transaction amount, as follows:
Originator Customer PII:
→ Always required
- Account number, or unique transaction reference number (Notice PSN02, section 13.4)
→ One of the following is required if the transaction value is higher than SGD 1,500
- Residential / business address
- Unique identification number (e.g., ID card number)
- Date of birth + Place of birth (Notice PSN02, section 13.6)
Beneficiary Customer PII:
- Account number, or unique transaction reference number
3. Are there differences in customer PII requirements for cross-border transfers versus transfers within Singapore?
Notice PSN02 foresees a narrower scope of personal identifiable information (PII) that ordering VASPs are required to share with intermediary institutions in Singapore immediately.
In these cases ordering VASPs are allowed to share only the following information (Notice PSN02, section 13.5 and 13.8)
- Unique transaction reference number that allows the transaction to be traced back to the originator and to the beneficiary
- Beneficiary name;
- Beneficiary account number or unique transaction reference number.
However, it is relevant to note that even in these cases, VASPs are still required to be able to share the full scope of PII (which varies depending on whether or not the transaction amount is higher than SGD 1,500) at the request of the intermediary institution, MAS or other relevant authorities in Singapore (Notice PSN02, section 13.5 / (b) and section 13.8 / (b)).
4. What are the non-custodial or self-hosted wallet requirements in Singapore?
In Singapore, transactions between VASPs and non-custodial or self-hosted wallets are not subject to travel rule requirements (Guidelines to Notice PSN02, section 13-7). However, VASPs should recognize that such transactions may entail a higher risk of money laundering or terrorism financing and enforce appropriate enhanced due diligence measures, such as:
- When funds are sent to or received from a wallet that the customer identifies as their own, verify that the wallet address is effectively controlled by the customer;
- When funds are sent to or received from a wallet that the customer identifies as belonging to a third party, verify the identity of that third party.
Why choose Notabene for Crypto Travel Rule Compliance in Singapore?
Notabene has a live end-to-end Travel Rule compliance solution ready to enable Singapore VASPs to comply with MAS' travel rule requirements. In particular, VASPs are able to verify whether a non-custodial wallet address effectively belongs to their customer. Our solution is trusted by several VASPs in Singapore (such as Luno and crypto.com) and is continuously tested in the monthly Singapore Testnet hosted by Notabene. The Singapore testnet is a simulated environment where participating VASPs can test compliance with the travel rule using our solution.
- MAS | Notice PSN02 Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service
- MAS | Strengthening AML/CFT Controls of Digital Payment Token Service Providers [March 2021]
- MAS (MAS) | Strengthening AML/CFT Controls of Digital Payment Token Service Providers [March 2021]
- MAS | Payment Services Act 2019
- MAS | Guidelines to Notice PSN02 on Prevention of Money Laundering and Countering the Financing of Terrorism – Holders of Payment Service Licence (Digital Payment Token Service)