Singapore Digital Token Service Providers Must Stop Offshore-Only Business by 30 June

Who is caught

Under section 137 of the FSM Act, the regime covers individuals or partnerships operating from a place of business in Singapore, and Singapore-incorporated companies wherever they operate, that carry on a business of providing digital token services outside Singapore. MAS's response to consultation feedback of 30 May 2025 explains that factors such as whether front-office functions, like sales and business development, or customers are located outside Singapore will be relevant to that test. The regime applies to services in digital payment tokens and tokens of capital markets products; services relating to other tokens, such as utility and governance tokens, are not subject to licensing under it.

Providers that serve customers in Singapore are already regulated under the Payment Services Act 2019, the Securities and Futures Act 2001 or the Financial Advisers Act 2001. MAS says nothing changes for them: they may continue their licensed business and may also serve overseas customers.

No transition and a high licensing bar

MAS has refused industry requests for a transitional period. Singapore digital token service providers that require a licence under section 137 must suspend or cease providing services outside Singapore by 30 June 2025, when Part 9 of the FSM Act and related provisions come into force. Contravening the licensing requirement is an offence carrying the penalties in section 137(6).

MAS says it will consider granting a licence only in extremely limited circumstances, for example where an applicant shows a business model that makes economic sense, valid reasons for not serving Singapore customers despite its Singapore base, and supervision against international standards in the jurisdictions it serves. The annual licence fee is S$10,000. MAS links its cautious stance to higher money laundering and terrorism financing risks in internet-based, cross-border business models and to the difficulty of supervising a provider whose substantive activity is outside Singapore.

Who is affected

Crypto exchanges, brokers and wallet providers that are incorporated or staffed in Singapore but market only to overseas users have three weeks left to wind down, restructure or relocate those activities, or to secure a licence on the narrow terms MAS has described.

Sources

• Monetary Authority of Singapore: MAS Clarifies Regulatory Regime for Digital Token Service Providers
• Monetary Authority of Singapore: Response to Feedback on the regulatory approach for Digital Token Service Providers