Understanding the regulatory requirements of the MAS Payment Services Act
Wong Nai Seng, Southeast Asia Leader, Deloitte Asia Pacific Centre for Regulatory Strategy

Agenda1. Introduction
2. key regulatory requirements
3. Requirements that apply generally to all licensees
4. Requirements that apply to account issuers, e-money issuers and digital payment token service providers© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 20192

Introduction© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 20193

Technology is transforming Singapore’s payments landscapeTechnology has lowered the barriers to entry to running a payments business. This,
coupled with the high penetration of smart phones, has made it easier to acquire
customers digitally.

Transformation ofPayments
Technologies

Proliferation of
Mobile Phones

Addition of New
Payments Services

Industry
Changes

1

More Non-bank Players /FinTechs providing financial services

2

Lower Cost of Customer Acquisition

3

Better Customer Experience and Access

Boom for Online ECommerce
including Cross
BorderConvergenceacross Payments
Activities

References - https://www.mas.gov.sg/news/speeches/2018/epayments-in-asia© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 20194

E-payments are gaining traction, supported by public/private sector initiatives

2014

FAST

Electronic funds transfer service enables realtime transfer of SGD funds between
participating banks (open and accessible, 24/7)
2017

PAYNOW

B2C

Peer-to-peer fund transfer service throughmobile using NRIC/ FIN / UEN

B2B

C2C
C2B

2018

Single and standardised QR code for e-payments

SGQR
2019?

2019
Payments
Services Act

Non Bank
FAST AccessNon-bank players to have direct access to FAST toenable them to bring greater convenience to consumers

The Payment Services Act (“PSA”) provides a forward-looking and flexible framework for the
regulation of payment systems and payment service providers in Singapore. (PSA has not come into
effect. MAS is consulting on related regulations and guidelines.)
References - https://www.mas.gov.sg/news/speeches/2018/completing-the-e-payment-jigsaw© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 20195

Payment Services Act (“PSA”) aims to promote broader adoption of e-payments

Why?
The PSA empowers
MAS to regulate
payment services andmitigate key risks

Safeguard Funds owed toConsumers / Merchants

Strengthen Key
Technology andCyber Standards

Reduce Fragmentationand Limitations toInteroperability

Build Adequate Controls
against Moneylaundering and Terrorism
Financing*

Key Implications
1. Broaden scope of regulated activities to a wider range of payment services and activities - domestic money transfers, inward
remittances, merchant acquisition, and digital payment token services
2. Calibrate regulations to specific risks posed by activities through a new modular approach
3. Increase competition by preventing formation of walled gardens
4. Bring digital payment tokens into mainstream; regulation may promote greater use of payment tokens which can reduce settlement
time and costs© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 20196

New regime lays down a risk-focused designation and modular licensing frameworkA

Designation Framework for Significant Payment Systems (Retained from prior regime)
MAS can designate significant payment systems and regulate operators, settlement institutions and participants of these
designated payment systems, to ensure financial stability and to promote efficiency and competition

B

Licensing Framework for Payment Service Providers (New requirement)
A business must have a licence for the class of service provided in Singapore
Classes of licence

Money Changing
LicenceStandard Payment
Institution Licence

Threshold Factors

Major Payment
Institution Licence(discussed in detail in slide 5)

G
Money Changing
Service© 2019 Deloitte Southeast Asia Ltd.

A

Account Issuance Service

B

Domestic Money Transfer Service

C

Cross Border Money Transfer Service

D

Merchant Acquisition Service

E

E-Money Issuance Service

F

Digital Payment Token Dealing and Exchanges
What you need to know about the Payment Services Act 20197

Licensing regime focuses on players with a clear retail payments nexus
A

Process funds or acquires transactions for merchants

B

Deals or contracts directly with consumers or merchants

Payment instrument
aggregators

Not subject
to licensing© 2019 Deloitte Southeast Asia Ltd.

Data
communication
platforms

Players that provide
services to otherpayment service
providers and financial
institutions

What you need to know about the Payment Services Act 20198

Size thresholds will determine licensing class and applicable requirements
A licensee must have a standard payment institution licence or a major payment
institution licence to provide any combination of the seven services

Money Changing Licence

Can only provide Money
Changing Services
Continue to be regulated
under the Bill in largely thesame way as it is underthe existing MCRBA, as
the attendant risks have notchangedStandard Payment
Institution licence

Any combination of theseven defined payment
services, but below
specified transaction flow ore-money float thresholds
Will be regulated more
lightly

Major Payment
Institution licence

Threshold
Factors
1. Transaction Value*–Average monthly
payment transactions
for any activity > $3
million (average overa calendar year)
2. E-Money Float –Average daily emoney float > $5
million (average overa calendar year)

Any combination of theseven defined payment
services, and can go above
thresholds
Subject to more regulation

A holder of a Major Payment Institution licence will be subject to additional requirements under the PSA

 Higher capital requirements on an
initial and on-going basis ($250k)
 Maintain $100k security deposit© 2019 Deloitte Southeast Asia Ltd.

 Safeguarding of funds(Undertaking / guarantee / trust
account)

 Interoperability through accessregime, common platform and/or
common standards*Monthly payment transactions exceeding $6M (for two or more licensable activities)
What you need to know about the Payment Services Act 20199

Tailored risk mitigation measures for specific risk types
Four key risks applicable to payments providers are identified in the PSA.

1 AML / CFT Appropriate AML/CFT requirements will be imposed on relevant licensees
through Notices issued under the MAS Act
 Low risk transactions are exempted from AML/CFT requirements Refer to later part of presentation for more details

2 Interoperability Imposition of Access Regime such as participation in common
platforms, use of ‘fair and reasonable’ commercial terms
 Adopt a common standard to make widely used payment
acceptance methods interoperable3

 Safeguarding money received from customers through liability,
guarantee and trust account and segregation
 Includes contractual obligations with safeguarding institution andadditional reporting and monitoring mechanisms

Loss of Funds
due toinsolvency

4 Technology Risk
© 2019 Deloitte Southeast Asia Ltd.

 Governance and implementation of adequate controls in areas such as
user authentication, data loss protection and cyber-attack
prevention and detection
 Standards and expectations will be commensurate with level oflicensing
What you need to know about the Payment Services Act 201910

Key regulatory requirements
For Account Issuance, E-money Issuanceand Digital Payment Token Service© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201911

Requirements that apply generally to all licensees
Licensing, variation of license, surrender/lapsing/revocation of license, prohibition of solicitation anduse of unlicensed agents, annual license fees
Permanent place of business in Singapore, Singapore director
Financial requirements (other than money changers)
Notifications and submission of info/regulatory returns to MAS
20% controllers, CEO and directors to be approved by MAS, subject to fit and proper requirements
Audit requirement

Inspection/investigation by MAS
Technology risk management
No provision of credit facilities to individuals© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201912

Licensing (under consultation)
License will lapse if the licensee• Does not commence business within 6 months of grant of license• Ceases to provide payment service for 6 months• Does not conduct any payment transaction for 6 months© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201913

Singapore presence• Permanent place of business or registered office in Singapore• At least 1 director is Singaporean or Singapore PR, executive director can be
employment pass holder (under consultation)© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201914

Regulatory reporting (under consultation)• Annual reporting by money-changers to include transactions above $5,000,
transactions involving high risk customers, and top 10 currencies• Monthly reporting by other licensees on account statistics, transaction volumes andvalue, e-money float, and amounts subject to safeguarding requirement (whereapplicable)• Half-yearly reporting by digital payment token service providers on type of digital
payment tokens offered and transactions involving high risk customers© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201915

Technology risk management

12

Technology risk management guidelines

Notice on cyber hygiene (PSN06)

Applies to DPS operators and all licensees• Applies to all DPS operators and all
licensees•• Requirements are basic cyber security
measures that all financial institutions (FIs)must implement© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201916

But certain requirements are tailored to the risks of each regulated activity

Activities in Focus

Account IssuanceE-money Issuance

Digital Payment Token
Service

Activity
Description

Opening or operating apayment account

Issuing e-money to allow user
to pay merchants or transfer emoney to another person

Buying / selling / facilitatingexchange of digital payment
tokensCurrent
Regulatory Regime

Newly regulated

PSOA(Limited)

Newly regulated

AML / CFT

AML/ CFT requirements forcertain providers

N/A

AML/ CFT requirements for all
providersInteroperability

Common standards, joincommon system, access regime

N/A

N/A

E-Payments user protection
guidelines

Safeguarding of float

N/A

User Protection

Transition
Arrangements© 2019 Deloitte Southeast Asia Ltd.

All major payment institutions must maintain security deposit – $100,000 if average monthlytransaction value ≤ $6 million; $200,000 if average monthly transaction value > $6 million
12 months

12 months

6 months
What you need to know about the Payment Services Act 201917

E-money issuance – safeguard e-money float
Licensees carrying on e-money issuance must safeguard e-money float by:

1

Obtaining an undertaking from a safeguarding institution to be liable
for the float

2

Obtaining a guarantee from a safeguarding institution for the float3

Depositing the float in a segregated trust account with a safeguarding
institution•

Safeguarding institutions include banks, merchant banks, finance companies and financial guarantee insurer.

•

Licensees must periodically assess suitability of safeguarding institutions.

© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201918

E-money issuance – prohibition from carrying on certain businesses
Licensees carrying on e-money issuance are not permitted to:1
2

On-lend the moneys received from customers as payment for e-money; orUse customer moneys or any interest earned on these moneys, to finance,
wholly or to any material extent, any business© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201919

Account issuance – specific restrictions on personal payment accounts

Restrict users fromholding more than
$5,000 in their ewallets at any point intime© 2019 Deloitte Southeast Asia Ltd.

Major payment
institution licenseesthat provide accountissuance services

Prevent users fromtransferring more than
$30,000 within eachyear to accounts otherthan the user’s
previously-nominatedbank accounts

What you need to know about the Payment Services Act 201920

Account issuance – no withdrawal of e-money and exchanging for SGD
Licensees carrying on account issuance are not permitted to:Assist users in withdrawing emoney from their accounts andexchanging the e-money for
Singapore currency if the user isresident in Singapore or if e-money
is issued in Singapore and have notverified that user is not a Singapore
resident.
Enter into any agreement or
arrangement (whether oral or inwriting and whether express or
implied) with any entity that isincorporated, formed or registeredin/ carries on business in
Singapore, that would make theabove possible

1
2
3

To promote adoption of epayments rather than usageof cashCash withdrawal remains a
distinguishing feature of banking
business

Increased money laundering (“MF”)/ terrorism
funding (“TF”) risks from the relative anonymity
posed by cash-based transactions

However, the above prohibition will not be applied if the user terminates their account.
© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201921

Account issuance - certain products may be exempted from AML/CFT requirements
A licensee is not required to comply with some AML/CFT requirements if it provides
services that meet specified low risk criteria
Regulated activity

Low risk criteria

Account issuance services

Issuing payment accounts that:a. Do not allow physical cash withdrawal;
b. Do not allow physical cash refunds above S$100, unless the payment
institution performs identification and verification of sender; andc. Do not have an e-wallet capacity (i.e. load limit) that exceeds S$1,000.

The exempted requirements relate to customer due diligence, foreign currency exchange transactions,issuance of bearer negotiable instruments and cash pay-outs, agency arrangements, and wire transfers© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201922

Digital Payment Token Service – no exemption from AML/CFT requirements
All transactions under DPTS are considered by MAS to carry higher inherent ML/TF risks

Speed

Anonymity

Cross-border

In line with the international AML/CFT standards-setter, the Financial Action Task Force (“FATF”) Standards,
MAS will introduce AML/CFT requirements on licensees that are DPTS providers who:1

Deal in DPTs – includes the buying or selling of DPT. This would typically involve the exchange of DPT
for fiat currency (e.g. Bitcoin for USD, or USD for Ether) or another DPT (e.g. Bitcoin for Ether);2

Facilitate the exchange of DPTs – establishing or operating a DPT exchange which allows the buying
or selling of any DPT, in exchange for fiat currency or any DPT (whether of the same or a different
type)© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201923

Appendix: Key regulatory
requirements
Payment Services Regulations, Notices &Guidelines© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201924

Payment Services Regulations
The PS Regulations is intended to be the main regulations for licensees and other regulated persons under the PS Act.
Requirements for all licensees(a) Control of provision of payment services(b) Financial requirements(c) Business conduct requirements

Requirements for designated payment system (“DPS”)(a) Provision of information to MAS;(b) Submission of periodic reports(c) Application to MAS for appointment of CEO and directors of DPS operators;(d) Business continuity requirements; and(e) Criteria to determine whether there is failure to discharge duties or functions by the CEO or directors of DPS operators and settlement
institutions

Exemptions and other requirements(a) Exemption for hotel operators in respect of money-changing service(b) Exemption from the requirement to hold a standard payment institution licence(c) Exemption for certain domestic money transfer service providers(d) Exemption from the prohibition against solicitation© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201925

Notices and Guidelines to be Issued Under the Payment Services Act
Notice No.

Name of Notice or Guidelines

PSN01

Notice to payment services providers (specified payment services) on prevention of money laundering and countering the financing ofterrorism

PSN01A

Notice on AML/CFT requirements to facilitate transition of existing stored value facility holders

PSN02

Notice to payment services providers (digital payment token service) on prevention of money laundering and countering the financing ofterrorism

PSN03

Notice on reporting of suspicious activities and incidents of fraud

PSN04

Notice on submission of regulatory returns

PSN04A

Notice on submission of statement of transactions and profit/loss

PSN05

Notice on technology risk management

PSN06

Notice on cyber hygiene

PSN07

Notice on conduct

PSN08

Notice on disclosures and communications

PSN09

Notice on administrative matters
E-payments user protection guidelines (updated version to be effective on PS Act commencement date)
E-payments user protection guidelines (updated version to be effective at a later stage after PS Act commencement date)

FSG-G01

Guidelines on fit and proper criteria© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201926

AML/CFT requirements
MAS is proposing to issue two new AML/CFT notices, applicable to all classes of payment services providers, which willbring together and update existing requirements and introduce new requirements on newly regulated payment services.

PS Notice 01(“PSN01”)

PS Notice 02 (“PSN02”)••

Notice to Payment Services Providers (Specified Payment Services)
Applies to licensees which carry on business of providing Account issuance services Domestic money transfer services
 Cross-border money transfer services
 Money-changing services••

Notice to Payment Services Providers (Digital Payment Token Services)
Applies to licensees which carry on business of providing
 Digital payment token services

Key Requirements under the AML/CFT Notices:- Identify, assess and understand their ML/TF risks;- Develop and implement policies, procedures and controls for the effective management of such risks• Customer due diligence (CDD)• Transaction monitoring• Screening• Suspicious transactions reporting; and• Record keeping- Enhanced measures should be performed where higher ML/TF risks are identified- Monitor the implementation of policies, procedures and controls, and enhancing them if necessary
MAS also noted that payment services providers may conduct other non-payment services business activities that have ML/TF risks. Hence MAS is
proposing to subject such other business activities to AML/CFT requirements as well.
© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201927

AML/CFT Requirements for All Licensees (1/2)

1. Simplified Customer Due Diligence (SCDD)•

Licensees should adopt a risk-based approach to performing CDD•

Where a licensee applies SCDD measures, it continues to be required to conduct screening and ongoing
monitoring of business relations under the relevant Notice•

MAS will not require licensees to seek MAS’ approval prior to conducting SCDD•

As with the other MAS AML/CFT Notices, licensees that adopt SCDD measures into their business models should
ensure that these measures are properly documented, and that records are well-maintained. MAS reserves theright to review all relevant documentation and records as part of our supervisory process

2. Third Party Reliance•

MAS intends to permit licensees to rely on a third party to perform certain elements of the CDD measures (in relation
to on-boarding KYC) required by the PS Notices, provided that certain relevant requirements are met© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201928

AML/CFT Requirements for All Licensees (2/2)
3. Correspondent Account Services•

MAS intends to require all licensees, in addition to performing normal due diligence measures, to also perform thenecessary risk mitigation measures when providing correspondent account services to another financial institution
or when engaging another financial institution for correspondent account services, including(a) assessing the suitability of the financial institution by understanding its AML/CFT controls and that they areadequate and effective,(b) clearly understanding and documenting the respective AML/CFT responsibilities of each financial institution, and(c) obtaining approval from the licensee’s senior management before providing correspondent account or similar
services to a new financial institution or engaging a new financial institution for correspondent account services.

4. Bearer Negotiable Instruments and Cash Payouts(a) prohibit licensees who perform money-changing transactions, inward cross-border money transfers, domestic
money transfers, withdrawals from payment accounts, and the purchase or sale of foreign currency without the use offoreign currency notes (“FX transactions”), from issuing bearer negotiable instruments, e.g. cash cheques, in any
currency to their customers; and(b) require licensees who perform inward cross-border money transfers, domestic money transfers, withdrawals frompayment accounts, and FX transactions, to use non-cash settlement methods for pay-outs of S$20,000 and above(or such equivalent amount in foreign currency) to persons in Singapore.
© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201929

AML/CFT Requirements for Digital Payment Token Services (DPTS)

1. Cross-border Value Transfer• Other requirements that would apply include monitoring of the availability of information, and taking freezing action andprohibiting transactions with designated persons and entities

2. Occasional Transaction Thresholds• With respect to DPT transactions, the FATF recently clarified in a Public Statement on its proposed Interpretive Note to
Recommendation 15 that the occasional transactions designated threshold above which DPTS providers are required to
conduct CDD is lowered to USD/EUR 1,000, from USD/EUR 15,000 for other types of FATF-covered activities, in view ofthe ML/TF risks associated with such activities• Where occasional transactions occur (e.g. where DPTs are sold through ATM machines), MAS proposes to require CDD to
be conducted from the first dollar, i.e. there is no threshold for such transactions, below which CDD need not apply
3. Collection of CDD Information• Notice 1 and Notice 2 will require the collection of certain customer-specific information, including at least the following—(i) full name, (ii) Unique Identification Number (e.g. customer NRIC or passport number), (iii) residential address (orregistered or business address), (iv) date of birth (or establishment, incorporation, or registration), (v) nationality (orplace of incorporation or place of registration). Additional identification is required for legal arrangements• However, MAS is seeking feedback on whether other customer-specific information may be more appropriate© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201930

Offering of Exempted Products (1/2)

A licensee is not required to comply with MAS’ AML/CFT Notices if it provides only services that meet certain low risk
criteria for ML/TF (“MAS defined low risk activities”).
Regulated activity

Low risk criteria

Account issuance services

Issuing payment accounts that:a. Do not allow physical cash withdrawal;
b. Do not allow physical cash refunds above S$100, unless the payment institution
performs identification and verification of sender; andc. Do not have an e-wallet capacity (i.e. load limit) that exceeds S$1,000.

Domestic money transfer
services

Services that only allow the user to perform the following transactions:a. Payment for goods or services and where payment is funded from an identifiable
source (being an account with a financial institution regulated for AML/CFT);
b. Payment for goods or services and where the transaction is under S$20,000; or
c. Payment is funded from an identifiable source and where the transaction is under
S$20,000.

Cross-border money transfer
services

Services where the user is only allowed to pay for goods or services and where thatpayment is funded from an identifiable source.

© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201931

Offering of Exempted Products (2/2)

Where a licensee provides payment services regulated for AML/CFT, and offers a product which meets the criteria of
Exempted Product(s), then the payment services provider must:(a) be subject to all AML/CFT requirements in relation to its regulated activities generally;(b) be subject to the AML/CFT requirements except that it need not comply with AML/CFT measures relating to customer
due diligence, foreign currency exchange transactions, issuance of bearer negotiable instruments and cash payouts,
agency arrangements, and wire transfers in relation to the Exempted Product(s) only;(c) apply its AML/CFT risk mitigation measures on an enterprise-wide basis. This includes developing and implementing
policies, procedures and controls to ensure that any low-risk payment activities it may conduct are kept within the low-risk
parameters; and(d) continue to ensure that appropriate records are maintained in order to demonstrate that all low risk activities comply
with the aforementioned criteria.
There are no low risk exemptions in respect of DPTs, and a DPTs provider is subject to all the AML/CFT requirements
found in Notice 2.

© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201932

Notice on conduct

PSN07 sets out conduct requirements for payment service providers, in respect of relevant payment services.
Conduct requirements adapted from MCRBA notices

1

MCRBA Notice 3002 – Record of transactions

2

MCRBA Notice 3004 – Issuance of receipts

3

MCRBA Notice 3202 – Transmission of money

4

MCRBA Notice 3101 – Display of exchange rates

New conduct requirements

1

Determining Singapore residency of customer

2

Specifying the days and hours that a place of business must be manned

3

Determining the exchange rate to be applied for the purposes of safeguarding© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201933

Speaker profile© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201934

Speaker profile

Wong Nai SengSoutheast Asia Leader, Deloitte Asia Pacific Centre for Regulatory Strategy
nawong@deloitte.com
Nai Seng heads the Regulatory Risk service line in Southeast Asia, with a focus on
helping financial institutions operating in Southeast Asia develop and execute strategies
related to regulatory risk. He is also the Southeast Asia Lead Partner for Deloitte’s Asia
Pacific Centre for Regulatory Strategy. Nai Seng has more than 20 years’ experience infinancial policy, surveillance and supervision, covering banks and capital markets. Prior
to joining Deloitte, he was with the MAS where he was responsible for prudential policy,
macro prudential surveillance, data governance and analytics, and supervision of
payment systems and technology risk.

© 2019 Deloitte Southeast Asia Ltd.

What you need to know about the Payment Services Act 201935

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What you need to know about the Payment Services Act 201936