MAS Licensing Solutions for Singaporean Financial Institutions | Pre-licensing Assessment | MAS Licence Application Management | Post-licensing Risk and Compliance Support tailored to the MAS licensing regime

MAS Licensing Preparation

Pre-licensing Compliance Assurance

Our MAS licence solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for an MAS licence
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the money transfer businesses' licensing process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your MAS licence, tailored to suit your:

• business objectives,
• operational capacity,
• client base,
• markets of operations,
• and other relevant factors

• Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
• MAS Licence Application Plan: We help you establish a roadmap to effectively meet the MAS licence requirements

 

MAS Licence Guidance 

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our MAS licensing solution covers:

• Compliance Model Selection: To help you best comply with the MAS licensing regime and related risk and compliance obligations.
• Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
• Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the licensing requirements for money transfer businesses and other applicable MAS regulated entities’ obligations, keeping in mind your specific circumstances, available resources and business goals.

 

MAS Licence and Entering Regulated Environment

We help businesses transition from an unregulated environment to operating under the MAS licensing regime, helping them meet their obligations as a MAS licence holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the MAS licensing regime requirements.

Our focus areas for this service include:

• New businesses
• Existing money remittance providers operating in unregulated markets
• Regulated money transfer businesses expanding into foreign jurisdictions
• Financial institutions and/or service providers with established risk and compliance frameworks that seek to offer regulated money transfer and e-money issuance as new products.

 

MAS Licence Application

We assist with your licence application through ongoing engagement in the MAS licensing process:

• Document Compilation and Review: We compile and review all required supporting documents to support your MAS licence application.
• Application Form Completion: We assist you in completing the forms to ensure all material information is accurate and complete.
• Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Money Transfer Businesses' Licensing Process and Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the licensing process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving MAS Licence Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our MAS licence solutions include a range of services to address and resolve these issues effectively:

• Remediation Solutions for MAS Licence Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with MAS licensing regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your MAS licence, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.
• Licensing Issues Handling: We address common licensing issues encountered during the MAS licensing process, providing you with solutions to navigate and resolve these challenges efficiently.
• Further Information: You can visit our Compliance Remediation Solutions page for more information.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for regulated money transfer businesses. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• Regulated MAS Regulated Entities’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the MAS licensing regime and other regulatory compliance obligations. You can visit our Compliance Advisory page for more information.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our global Compliance Management Solutions page for Money Transfer Businesses. For the US-related MSBs, you can visit our Compliance Management Solutions page for the US Money Transmitters.
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:

• Regulated MAS regulated entities’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• Regulated money transfer businesses’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.

• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for money transfer businesses. For more information, visit our Specialised AML/CFT Solutions page for Money Transfer Businesses.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (e.g., your banking partners, insurance companies, and liquidity providers).

 

 

Risk and Compliance Obligations for MAS Licence Holders

MAS licence holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices. We can help you address these obligations and expectations through comprehensive support in the different areas. We can help you address these obligations and expectations through comprehensive support in the different areas.

 

MAS Licence and Regulatory Compliance Obligations

• Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more (as required under the Payment Services Act 2019).
• Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil MAS regulated entities’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks.
• Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the money remitters’ licensing requirements.
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the money remitters’ licensing regime.
• Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
• Financial Auditing Standards: We can assist in establishing procedures to help you comply with the audit and assurance requirements under the money remitters’ licensing regime.
• Digital Payment Token Services: If your MSB supports digital assets or stablecoin-based transfers, we can help you develop controls to meet AML/CFT requirements and applicable licensing conditions for digital payment token services, including transaction monitoring, wallet screening, and Travel Rule compliance..

 

MAS Licence and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with MAS regulated entities’ obligations for overseeing outsourced services, also covering related obligations under AML/CFT compliance, ISO requirements, and more.
• Structures for Governance: We can help you establish effective governance structures to comply with MAS regulated entities’ obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
• Senior Management Accountability: We can help you comply with MAS regulated entities’ obligations for senior management and key staff conduct and competence.
• Maintaining Operational Resilience: We assist in developing continuity plans to meet MAS regulated entities’ obligations for operational resilience and transaction flow continuity, helping critical business services withstand disruptions.
• Managing Technology Risks: We provide guidance on technology risk management obligations under the money remitters’ licensing regime (as required under the MAS TRM Guidelines).

 

MAS Licence and Market Integrity/Transparency Requirements

• Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients.
• Standards for Conduct and Disclosure: We can help you comply with MAS licensing standards for conduct and disclosure.
• Protection of Client Assets: We can help you comply with MAS licensing obligations to protect and segregate client assets.
• Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients.

 

 MAS Licensing Regime and Resource Management Obligations

We can help you comply with the following requirements of the money remitters’ licensing regime:

• Adequacy of Resources: Covering financial, technological, human and other resources.
• Competence of Professionals: Covering key personnel, their necessary skills, knowledge, and professional competence.
• Our focus areas include:

• Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the licensing regime.
• Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
• Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
• Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
• Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, and money transfer regulations.
• Representative Vetting: We can help establish a framework for assessing the competence and suitability of advisors and representatives before appointment.
• Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
• Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.
• Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.

 

MAS Licence and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • Money transfer businesses’ licensing obligations
  • Money transfer businesses’ AML/CFT obligations (SMRs, STRs, SARs, cross-border transaction reports, cash transaction reports, and other reporting obligations)
• Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
• Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, the provisions of the money remitters' licensing regime, and applicable operational standards.

Related Licensing Solutions 

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with the financial licensing obligations globally. We assist in obtaining MAS licence equivalents in the following jurisdictions:

• Australia: For more information on the Australian MAS licence equivalent – AFS Licence, you can visit our AFLS Solutions page.
• United Kingdom: For more information on the United Kingdom equivalent of the MAS licence– FCA Authorisation, you can visit our FCA Authorisation page.
• New Zealand: For more information on the New Zealand equivalent of the MAS licence– FMA Licence, as well as Financial Service Provider (FSP) registration for non-retail offerings, you can visit our FMA Licensing Page or our FSP registration page.
• Other Jurisdictions: We also offer licensing solutions for prominent financial centres and offshore tax havens, including but not limited to:

• British Virgin Islands
• Cayman Islands:
• Seychelles
• Mauritius
  
• Gibraltar
• Belize
• Malta
• Vanuatu