Understanding the Consistencies of MAS Policy in Singapore

The MAS is mandating that numerous Digital Token Service Providers (DTSPs) based in Singapore obtain a license by June 30th or stop serving a broad array of clients. While news outlets have covered the announcement and policy statement, this article aims to delve deeper into the situation at hand. An additional brief statement released by the MAS is both publicly accessible and notably clear.

Some of this may be speculative. However – and this is on the public record – the author of this piece also submitted feedback to the MAS’s initial request for comments. This feedback closely aligns with the regulations the MAS announced a few days ago. While this doesn’t necessarily imply that these comments significantly influenced policy, it suggests that our perspectives are in line with those of the policymakers.

Here, we will outline our interpretations of a few of the more significant policy announcements. Additionally, we will explore what the current announcements might indicate about future decisions. It’s also valuable to consider the more alarmist responses within the web3 community regarding these announcements.

Similar to other instances, the issue here isn’t a lack of “clarity” – rather, it’s that many industry participants have chosen not to recognize what has been evident from the start.

Before diving deeper, it’s essential to clarify that we do not hold an opinion on how many weeks DTSPs require to prepare for these changes, what the appropriate amount of paid-up capital should be for a money transfer business, or any stance on staffing levels or the geographic positioning of executives beyond “whatever the company believes is best, as long as it’s legal.” We won’t address these technical yet significant questions here because, frankly, we lack substantial experience in managing such frameworks. We have been subject to, and have worked within, many compliance regimes. However, we can’t speak competently about the travel habits of William Santiago or the technical specifics necessary to create them.