Singapore Crypto Exchange Licensing: Requirements, Process & Checklist

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Trying to launch a crypto exchange in Singapore? You’ll need to navigate a tight‑but‑clear licensing maze drawn by the Monetary Authority of Singapore (MAS). Since June302025 the Singapore crypto exchange license regime forces every Digital Token Service Provider (DTSP) to pick a proper payment‑service licence, prove solid AML controls and keep a bucket of capital ready. Below you’ll find everything a founder, compliance chief or legal adviser needs to get the green light - from the big‑picture framework down to the exact paperwork you’ll hand over.

Why Singapore’s Framework Matters

Singapore sits at the crossroads of Asia’s fintech boom and strict regulatory oversight. The city‑state’s approach blends the flexibility of an offshore hub with the rigor of a major financial centre. Two statutes drive the regime:

  • Payment Services Act (PSA, 2019) - the original base for payment‑service licences.
  • Financial Services and Markets Act (FSMA, 2022) - introduced the DTSP overlay in 2025.

Both laws are enforced by MAS, which issued its final DTSP response on 30May2025 and gave firms just four weeks to comply. No grace period, no “watch‑list” - you either meet the standards or you stop operating.

Who Needs a License?

If your platform lets users buy, sell, swap or store crypto tokens for any client - Singapore‑based or overseas - you fall under the DTSP definition. The key trigger is “substantive regulated activity” involving digital tokens, regardless of where your customers live. Even custodial wallets or token‑swap services count.

Exceptions are narrow: pure‑instrument‑listing sites that never handle funds, or services limited to a handful of low‑risk activities that qualify for the Exempt Payment Service Provider category.

Manga‑style compliance office with AML documents and MAS inspector.

License Categories at a Glance

Comparison of Singapore crypto licence types
License type Monthly transaction volume trigger Minimum capital (SGD) Key compliance duties Typical processing time
Standard Payment Institution ≤3million 100,000 Basic AML/KYC, quarterly reporting, annual audit 3-6months
Major Payment Institution >3million 250,000 Enhanced AML/KYC, continuous transaction monitoring, bi‑annual audit, risk‑management framework 6-12months
Exempt Payment Service Provider Very low‑risk activities only None (notification only) Strict activity limits, MAS notification, minimal reporting 1-2months

The choice hinges on projected turnover, the breadth of services and how much you’re willing to invest in compliance infrastructure.

Core Compliance Pillars

All licence holders must obey MAS Notice PSN02, the AML backbone that mirrors the standards imposed on banks. Here’s what the notice demands:

  1. Robust Customer Identification (KYC) - collect full name, residential address, government ID, and source‑of‑funds evidence for every user.
  2. Ongoing Transaction Monitoring - real‑time screening for suspicious patterns, automated triggers for large or rapid trades.
  3. Suspicious Activity Reporting - file SARs with MAS within 24hours of detection.
  4. Record‑keeping - retain all client and transaction data for at least five years.

Beyond PSN02, you’ll need:

  • Capital adequacy (SGD100k or SGD250k depending on licence).
  • Risk‑management policy covering market, liquidity, operational and cyber risks.
  • Segregated client‑fund accounts or escrow mechanisms.
  • Independent internal audit and an external audit firm approved by MAS.
  • Regular regulatory reporting - monthly transaction summaries, annual compliance statements.

Step‑by‑Step Application Checklist

  1. Define your business model. Draft a detailed plan covering token pairs, fee structure, target markets and projected volumes.
  2. Choose the licence tier. Use the table above to match your expected monthly turnover.
  3. Prepare capital proof. Bank statements or a letter of credit showing the required SGD100k/250k.
  4. Write AML/KYC policies. Align every procedure with MAS Notice PSN02 - include onboarding flow charts and escalation matrices.
  5. Build internal controls. Document risk‑assessment methodology, incident‑response plan, and IT security standards (ISO27001 is a good reference).
  6. Engage a compliance consultant or law firm. Most applicants hire a specialist to pre‑screen the dossier - it cuts the back‑and‑forth with MAS.
  7. Submit the application. The portal on MAS’s website accepts a single PDF bundle - business plan, capital proof, AML/KYC policies, risk‑management framework, and audit‑firm appointment letter.
  8. Undergo MAS review. Expect an on‑site inspection or a request for supplementary documents. Respond within the stipulated timeframe (usually 30days).
  9. Receive the licence. After approval, you’ll be issued a licence certificate and a unique licence number for all future filings.
  10. Maintain ongoing compliance. Schedule quarterly internal audits, file monthly transaction reports, and keep capital deposits untouched.

Tick each box and you’ll be ready to submit a complete, MAS‑acceptable package.

Manga celebration of crypto exchange launch with fireworks over Marina Bay.

Timeline, Costs & Practical Tips

From start to finish, most firms budget 6‑12months. The biggest cost drivers are legal counsel (SGD30‑50k), external audit fees (SGD10‑20k per year) and technology upgrades for AML monitoring (SGD15‑30k). Here are a few shortcuts:

  • Leverage existing AML SaaS. Platforms that already integrate with MAS’s API cut development time.
  • Start with a Standard licence. If you can keep monthly volume under SGD3million, the lower capital and reporting burden makes the first year smoother.
  • Document early. MAS often rejects applications for missing risk‑assessment details - having a polished risk matrix before you submit saves weeks.
  • Keep a compliance officer on‑board. A full‑time, MAS‑certified officer demonstrates seriousness and speeds up the review.

Common Pitfalls & How to Avoid Them

Even seasoned fintechs stumble. The most frequent mistakes are:

  • Under‑estimating AML scope. Treating KYC as a one‑time form leads to SAR rejections. Build a dynamic monitoring system that flags velocity, geolocation anomalies and sudden value jumps.
  • Mixing offshore and Singapore entities. MAS expects the licence holder to be a Singapore‑incorporated entity with clear ownership. Using a foreign holding company without proper disclosure can trigger a refusal.
  • Neglecting capital availability. Locked‑up capital in crypto assets doesn’t count - it must sit in a liquid SGD‑denominated bank account.
  • Delaying audit appointments. The first external audit must be completed within six months of licence issuance; missing that deadline forces a temporary suspension.

Address each of these ahead of time and you’ll sidestep the most painful delays.

Frequently Asked Questions

Do I need a licence if I only serve overseas users?

Yes. MAS announced that the DTSP regime applies to any platform that conducts crypto‑related activities from Singapore, even if every customer is outside the country. The goal is to stop regulatory arbitrage.

Can a crypto‑exchange operate with an Exempt Payment Service Provider licence?

Only if the service is low‑risk - for example, a pure price‑feed widget or a non‑custodial swap that never touches user funds. Most exchanges need at least a Standard licence.

What is the minimum capital requirement for a Standard licence?

SGD100,000 must be held in a Singapore‑based bank account and be readily available for regulatory inspection.

How long does the MAS review take?

A Standard licence typically takes 3‑6months, while a Major licence can stretch to 6‑12months due to deeper due‑diligence.

Are there ongoing fees after the licence is granted?

Yes. Licence holders pay an annual fee to MAS (SGD1,500 for Standard, SGD3,000 for Major) plus audit and compliance costs.

Getting a crypto exchange licence in Singapore isn’t a walk in the park, but the payoff is a trusted brand operating under a globally respected regulatory shield. Follow the checklist, invest in solid AML tech, and keep your capital liquid - and you’ll be ready to tap into Southeast Asia’s fastest‑growing crypto market.

10 Responses

Jason Clark
  • Jason Clark
  • October 14, 2025 AT 09:32

Oh, because deciphering MAS notices is everyone's weekend hobby. It’s not like the regulators enjoy simplifying things for us, right?

Jim Greene
  • Jim Greene
  • October 16, 2025 AT 17:05

Sounds like a solid plan 👍

Marques Validus
  • Marques Validus
  • October 19, 2025 AT 14:32

The labyrinthine checklist that MAS hands you feels more like an epic saga than a regulatory hurdle. First, you draft a business model that reads like a startup manifesto, complete with tokenomics and projected volume graphs that could rival a Fortune 500 forecast. Then you hop onto the capital proof dance, producing bank statements that scream liquidity while the auditors whisper “are you sure this isn’t crypto‑wrapped?”

Next, you wade into AML/KYC policy creation, which is basically a masterclass in never‑ending documentation – every customer onboarding flow must be mapped, every source‑of‑funds narrative must be cross‑checked against a blacklist that updates faster than your coffee order.

After that, you construct an internal risk‑assessment matrix that looks like a war‑room strategy board, citing ISO‑27001 compliance, cyber‑incident response playbooks, and a liquidity stress‑test that would make a hedge fund blush. The compliance consultant you hire will likely charge you a small fortune, but they’ll also spot the tiny “missing risk‑assessment detail” that MAS loves to flag.

Once the dossier is compiled, you upload a single PDF to the MAS portal, praying that none of the required signatures are missing, because a single omitted page can add months to the review timeline. The MAS reviewers then conduct a site inspection, a process that feels like a CIA background check for fintech, demanding access to servers, employee handbooks, and even the coffee machine maintenance log.

Assuming you survive the inspection, you’ll wait 3‑6 months for a Standard licence or 6‑12 months for a Major licence, all the while maintaining a liquid SGD‑denominated capital reserve that cannot be tied up in volatile crypto assets.

Post‑approval, the real work begins: ongoing monthly transaction reports, annual audit submissions, and a compliance officer who must be MAS‑certified and present at every board meeting. Miss a deadline, and you risk a temporary suspension that could cripple your operations overnight.

In short, the process is a marathon of paperwork, capital deployment, and regulatory tango, but crossing the finish line grants you a badge of trust that opens doors across Southeast Asia’s crypto‑hungry markets.

Michael Bagryantsev
  • Michael Bagryantsev
  • October 21, 2025 AT 16:32

I hear you on the marathon part – the checklist can feel endless. One tip that helped me: start the AML/KYC docs early and treat them as living documents, not a one‑off submission. It saves weeks when MAS asks for a clarification.

Lesley DeBow
  • Lesley DeBow
  • October 24, 2025 AT 02:52

In the grand theater of regulation, each requirement is a lesson in humility. We learn that transparency isn’t optional; it’s the very language of trust. When the paperwork finally aligns, the sense of accomplishment is profound.

Hari Chamlagai
  • Hari Chamlagai
  • October 26, 2025 AT 07:39

Let’s cut the fluff: if you think you can wing the capital proof, you’re dreaming. MAS will demand a clean, liquid SGD account, not a stash of crypto that looks good on paper. Also, mixing offshore entities without full disclosure is a fast track to denial.

Ben Johnson
  • Ben Johnson
  • October 28, 2025 AT 06:52

Sure, because ignoring the capital requirement is a brilliant way to impress regulators.

Shane Lunan
  • Shane Lunan
  • October 30, 2025 AT 19:59

Looks like a lot of work, dunno if I’d bother.

Maria Rita
  • Maria Rita
  • November 1, 2025 AT 13:39

Hey, don’t sell yourself short! Every big player started with a mountain of paperwork and a dream. Keep the momentum, and you’ll turn that mountain into a stepping stone.

Jordann Vierii
  • Jordann Vierii
  • November 3, 2025 AT 23:59

All right, folks – if you’re ready to dive into Singapore’s crypto scene, remember that a solid licence is your passport. Gather your capital, lock down AML controls, and let the regulator see you mean business.

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