SPI Licence Solutions | Pre-licensing Assessment | SPI Licence Application Management | Post-licensing Risk and Compliance Management

We offer a comprehensive set of solutions to help you obtain and maintain a Singaporean Standard Payment Institutions (SPI) licence issued by the Monetary Authority of Singapore (MAS) under the Payments Services Act 2019, tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technology resources
• Your risk appetite
• Your governance structure
• The products that you offer
• Regulated SPIs’ obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our regulatory licensing solutions to help you navigate the complexities of the Singaporean SPI licensing regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the Singaporean SPI licensing process, including but not limited to the following aspects:

• SPI Licence Guidance: Advising on a wide range of aspects associated with SPI licence as it relates to your specific situation
• Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
• Pre-licensing support:
• Drafting the necessary policies and procedures to help you comply with the SPI licence conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the Singaporean SPI licensing regime
• SPI Licence Application Support: Covering the entire licensing process
• Post-licensing Support: Covering
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• AML/CFT advice
• AML/CFT compliance management
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

 

Service Coverage

This page is about a Standard Payment Institutions Licence in Singapore. An SPI licence authorises a money transfer business to provide up to four prescribed payment services (e.g. domestic money transfers, merchant acquisition, e‑money issuance, digital payment token services). We offer comprehensive support for a wide range of SPI licence applications tailored to meet the specific needs of the following businesses:

• Peer-to-Peer Payment Services
• Domestic Money Remitters
• Consumer Money Remitters
• Commercial Money Remitters
• Mobile Payment Providers
• Cryptocurrency Remittance Platforms
• E-Wallet Providers
• Prepaid Card Issuers
• Remittance Service Providers
• Foreign Exchange Dealers
• International Money Remitters
• Digital Money Remitters

 

You can find more information about our SPI licence solutions below:

 

Singaporean SPI Licensing Preparation

Pre-licensing Compliance Assurance

Our SPI licence solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for an SPI 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 SPI 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
• SPI Licence Application Plan: We help you establish a roadmap to effectively meet the SPI licence requirements

 

SPI 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 Singaporean SPI licensing solution covers:

• Compliance Model Selection: To help you best comply with the Singaporean SPI 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 regulated MAS regulated SPIs’ obligations, keeping in mind your specific circumstances, available resources and business goals.

 

SPI Licence and Entering a Regulated Environment

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

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

Our focus areas for this service include:

• New businesses
• Existing money remitter 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 seeking to offer regulated money transfer services as a new product.

 

Multi-Jurisdictional Compliance

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 obligations of regulated money remittance businesses globally.

 

SPI Licence and Alternative Licensing Options 

Obtaining a Standard Payment Institution (SPI) licence may not always be the most suitable option for all businesses. For example, some business models may qualify for an exemption from the SPI licensing requirement under the Payment Services Act (e.g., where payment services are below regulatory thresholds, are incidental to the main business, or are intra-group).

We offer a wide range of risk and compliance management solutions to assist payment service providers that:

• Operate below the transaction and e-money thresholds for SPI licensing
• Qualify for a specific exemption under the PSA
• Hold an SPI licence but operate at a limited service scope or volume

We help these businesses comply with regulatory obligations that still apply even without an SPI licence, including:

• MAS Advertisement Guidelines
• Fair Dealing Guidelines
• Risk management controls
• Oversight of outsourced service providers
• Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) requirements
• Personal Data Protection Act (PDPA) obligations
• Record-keeping and reporting where applicable

There is also a Major Payment Institution (MPI) Licence that authorises a money service business to provide any or all of the eleven prescribed payment services, including cross‑border transfers, merchant acquisition, and e‑money issuance. An MPI requires you to meet higher capital, governance, and risk-management standards, as well as annual audits and quarterly reporting to the MAS. For more information on this option, you can visit our MPI Licensing Solutions page.

 

SPI Licence Application

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

• Document Compilation and Review: We compile and review all required supporting documents to support your SPI licence application.
• Application Form Completion: We help you complete the forms so that 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 SPI Licence Issues

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

• Remediation Solutions for SPI Licence Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with Singaporean SPI licensing regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your SPI 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 Singaporean SPI licensing process, providing you with solutions to navigate and resolve these challenges efficiently.
• For further information, please visit our Compliance Remediation Solutions page.

 

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 SPIs’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the Singaporean SPI licensing regime and other regulatory compliance obligations. For more information, please visit our Compliance Advisory page.
• 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 US-related MSBs, please visit our Compliance Management Solutions page for 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 SPIs’ 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 comprehensive 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 SPI Licence Holders

SPI 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. The list below is not exhaustive:

SPI 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 SPIs’ 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..

 

SPI Licence and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with MAS regulated SPIs’ 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 SPIs’ 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 SPIs’ obligations for senior management and key staff conduct and competence.
• Maintaining Operational Resilience: We assist in developing continuity plans to meet MAS regulated SPIs’ 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).

 

SPI 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 money remitters’ licensing standards for conduct and disclosure.
• Protection of Client Assets: We can help you comply with money remitters' 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.

 

Singaporean SPI 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.

 

SPI 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, provisions of the money remitters' licensing regime, applicable operational standards, and more.

 

Related Services

We assist in obtaining SPI licence equivalents in the following jurisdictions:

• Australia: For more information on the Australian equivalent of an SPI licence, the AUSTRAC money remitter registration, you can visit our AUSTRAC Money Remitter Registration page.
• United Kingdom: For more information on the UK equivalent of an SPI licence, the FCA payment institution authorisation, you can visit our FCA Payment Institution Authorisation page.
• United States: For more information on the United States equivalent of an SPI licence, the money transmitter license, you can visit our US Money Transmitter Licence page.
• New Zealand: For more information on the New Zealand equivalent of an SPI licence, the DIA money remitter registration, you can visit our DIA Money Remitter Registration page.
• Prominent Financial Centres and Offshore Tax Havens: We also offer licensing solutions for money remittance businesses in the prominent financial centres and offshore tax havens, including:

• Seychelles
• Cayman Islands
• British Virgin Islands (BVI)
• Belize
• Mauritius
• Gibraltar