Application for a Licence under the Payment Services Act 2019 (“PS Act”)
Type of licence
● Money-changing licence.
● Standard payment institution licence
● Major payment institution licence
Intended payment service(s)
● Account issuance service
● Domestic money transfer service
● Cross-border money transfer service
● Merchant acquisition service
● E-money issuance service
● Digital payment token service
● Money-changing service
SECTION 1: INFORMATION ON THE APPLICANT
The applicant must provide Copy of business profile as filed with the Accounting and Corporate Regulatory Authority (“ACRA”) of Singapore, dated within 30 days of the date of application.
Source of funds
Provide a breakdown of the funds received for the applicant’s business and the source of the funds: Source of funds (name and/or description), Type of source (Loan from financial instititution / Loan/Investment from family or friends / Angel Investment/Venture Capital / Crowdfunding / Initial Public Offering / Initial Coin Offering/ Grant or government incentive)
Provide copies of the audited financial statement of the applicant for the last 3 years.
Letter of Responsibility
Provide a Letter of Responsibility (“LR”) from its parent company or related entity to the Authority accepting full responsibility for all the operations of the applicant.
Provide copies of the audited financial statements of the proposed LR provider for the past 3 years, where applicable.
SECTION 2: SHAREHOLDER INFORMATION
If the applicant has corporate entities as its shareholders, provide copy of business profile dated within 30 days of the date of application of each shareholder, and its related entity(s), subsidiary(s) and branch(es) (where applicable).
If the applicant has individuals as its shareholders, provide copy (both front and back) of NRIC/Employment Pass/Passport of each shareholder.
Provide the shareholding chart that shows how the applicant is related to each of its shareholder(s) (including individuals), and to its related entity(s), subsidiary(s) and branch(es) (where applicable). Information on other forms of controlling interests should also be included in the chart.
The chart should indicate the percentage of shareholdings or controlling interests held by each person, the date of incorporation and the place of incorporation of each entity and name(s) of the exchange(s) on which the shares of any direct or indirect shareholder(s) are listed (where applicable).
Information on Group Structure
Provide information on the group structure (including its international network of holding companies, branches, subsidiaries, representative offices and joint ventures) and attach a group structure chart, giving the percentage of equity interests held in the principal operating companies in the group and the country of incorporation of these companies.
Provide copies of the audited consolidated financial statements of the group for the last 3 years.
SECTION 3: TRACK RECORD
Where the applicant is part of a group, describe the business activities of the group (e.g. main business lines, geographical locations, customer profile).
Describe and provide details of the corporate track record, including the business activities carried out, the name of the entity carrying out the business activities, and the length of the relevant corporate track record.
SECTION 4: ORGANISATIONAL STRUCTURE, PARTNERS, DIRECTORS, CEO
Provide the organisational chart of the applicant, including the compliance function. The chart should clearly show the current and proposed staff strength, and reporting lines of all employees to the Chief Executive Officer (“CEO”), key management officers and board of directors, including functional reporting to staff who are located outside Singapore. State whether each director is executive or non-executive, and resident or non-resident in Singapore. The chart should also include the names, job functions and designations of all employees, including those in compliance and internal audit functions where applicable.
SECTION 5: PROPOSED BUSINESS PLAN
Provide business plan that illustrates its compliance with the PS Act, as well as other relevant legislation.
Clientele type that the applicant proposes to provide the payment service(s) to: Individuals? Corporates? Specify the countries.
Provide additional information where relevant on the profile of a typical customer for each payment service the applicant intends to conduct (e.g. the industry sector where the customers are from).
Description of Proposed Business
Describe the payment services and products the applicant intends to provide: Account Issuance? Domestic Money Transfer? Cross-border Money Transfer? Merchant Acquisition? E-money Issuance? Digital Payment Token? Money-changing?
Describe how the applicant intends to generate revenue from conducting each payment service: Fees? Exchange gains? Commissions? Interest? Others?
Provide an estimated revenue amount, and estimation of the proportion of revenue (%) to be generated by each payment service.
The projected total velue of all payment transactions that are accepted, processed or executed in Year 1, Year 2 and Year 3: Account Issuance, Domestic Money Transfer, Cross-border Money Transfer, Merchant Acquisition, Digital Payment Token
The projected total value of all e-money that is stored in any payment account issued to persons resident in Singapore/not resident outside Singapore (in S$) in Year 1, Year 2 and Year 3: E-money account issuance
The projected total value of all specified e-money issued (in S$) Year 1, Year 2 and Year 3: E-money Issuance
Describe how the applicant intends to deliver or distribute its products or services to customers: Mobile app? Online platform? Phone calls? Face-to-face? Others? Provide details.
Transaction or process flow
Attach a diagram to describe the beginning to end of a typical transaction of the applicant, including where the applicant’s proposed business involves the use of innovative technology (e.g. use or offering of digital tokens, distributed ledger technology) or a different manner of delivering products or services from that commonly seen in the market. The diagram should include the arrangements for customers to pay for or settle the transaction, including the payment of fees to the applicant.
Unregulated business activities
Does the applicant currently carry out or intend to carry out any unregulated business activities e.g. precious stones and precious metals dealings, offering payment token derivatives?
Where the applicant is applying for a major payment institution licence, provide security in the form of a cash deposit or bank guarantee in the prescribed form.
The prescribed amount of security is —
a) $100,000, if the monthly average of payment transactions for any one payment service does not exceed S$6 million; and
b) $200,000, in all other cases.
Where the applicant is applying for a major payment institution licence, provide safeguarding arrangement by: an undertaking, from a safeguarding institution, to be fully liable to the customer for the relevant money? a guarantee given by a safeguarding institution for the amount of relevant money? depositing the relevant money in a trust account maintained with a safeguarding institution?
Technology risk management
If the applicant intends to provide online financial services, it must perform a penetration test of its proposed online financial services, remediate all high risk findings identified, and conduct independent validation on the effectiveness of the remediation actions taken prior to the commencement of business.
Where the applicant is applying for a standard payment institution licence, describe the intended monitoring measures to comply with the thresholds for standard payment institutions.
E-money account issuance service
Provide the details for for each type of e-money account issuance services that the applicant intends to provide: Name of account, Load limit, Redemption limit, Indicate if it is incidental to any services, Channels for loading (Cash, Bank transfer, Credit/Debit card transfer, Transfer from other wallets, Others), Channels for redemption and spending (Cash withdrawal, Transfer to bank account, Transfer to debit/credit card, Transfer to other wallets, Payment to merchants, Transfer to other persons).
Describe the intended monitoring measures to comply with the thresholds on personal payment accounts that contain e-money.
Domestic and cross-border money transfer
Provide a description of the remedial measures in the event that the payment does not reach the beneficiary within the prescribed period.
Digital payment token service
Indicate which digital payment token services the applicant will provide: Digital payment token exchange, Digital payment token broker, Digital payment token custody.
Provide a list of all tokens supported and indicate the applicant’s assessment of the nature of the token. Attach a legal opinion of the applicant’s assessment for all tokens, except Bitcoin, Bitcoin Cash, Bitcoin Gold, Bitcoin SV, Ethereum, Ethereum Classic, Litecoin and Ripple.
Name of token: Digital payment token under the PS Act? Capital market product under the Securities and Futures Act?
If the applicant intends to provide digital payment token wallet services, provide a list of wallets offered and indicate whether these are hot or cold wallets. Describe the security measures employed for wallets.
Provide the Project revenue, Projected profit after tax figures on the applicant in Year 1, Year 2 and Year 3 in Singapore dollars (S$) .
If there are any losses projected, explain how the losses would be funded.
Conflicts of Interest
Identify areas of potential conflicts of interest that may arise from the provision of payment service(s) by the applicant.
Explain the measures in place to mitigate the potential and all known conflicts of interest.
Systems and Controls
Provide Anti-Money Laundering and Countering the Financing of Terrorism Policies & Procedures, enterprise-wide risk assessment and implementation plans that illustrate the applicant’s compliance with the relevant Notices on Prevention of Money Laundering and Countering the Financing of Terrorism [PSN01 and/or PSN02], including the name and CV of the AML/CFT compliance officer (if different from the designated compliance officer).
Provide policies, procedures and systems for the following areas:
● Anti-money laundering and countering the financing of terrorism, taking into account, where applicable, the requirements and guidance under the MAS Notices PSN01, PSN02, PSN03 and their accompanying Guidelines.
● Compliance with the basic cyber security requirements under MAS Notice PSN06 Notice on Cyber Hygiene.
● Implementation of security measures to protect customer information in transmission and storage.
● Penetration testing of online financial services, including remediation of all high risk findings identified, and independent validation on the effectiveness of the remediation actions taken at least annually.
● The management of technology risk as set out in the Guidelines on Technology Risk Management, which is commensurate with the level of risk and complexity of the financial services offered and the technologies supporting such services.
● Complaints handling and other conduct requirements, including, where applicable, the requirements under the MAS Notices PSN07 Notice on Conduct and PSN08 Notice on Disclosures and Communications.
● Regulatory reporting, including, where applicable, the requirements under the MAS Notice PSN04 Notice on Submission of Regulatory Returns.
Provide the name of designated compliance officer.
Set out the employment history of the designated compliance officer during the last 10 years (including periods of part-time employment, unemployment or self-employment), starting from the most recent record: Period of employment (MM/YYYY) From To, Employer, Nature of business, Position held, Job description, Years of relevant experience.
Set out the academic and professional qualifications of the designated compliance officer, starting from the most recent record: Period (YYYY) From To, Name of institution, Location of institution, Qualification awarded.
Provide details of the compliance arrangement.
Independent and dedicated in-house compliance function? Provide the size of the compliance team, which is responsible for the applicant’s business operations.
Compliance function is outsourced to applicant’s head office/related entity with an independent and dedicated compliance function? Provide the details on the compliance team, which is responsible for the applicant’s business operations: Name of entity providing the compliance function, Country where compliance staff are based, Size of team
Internal audit arrangement
Provide details of the internal audit arrangement.
Independent and dedicated in-house internal audit function? Outsourced to applicant’s head office/related entity with an independent and dedicated internal audit function? Name of the entity, Country where audit staff are based, Size of team
Outsourced to an independent third party service provider? Name of service provider
If you would like to know more, please contact Bestar.