Singapore's June 30 Hard Deadline for Crypto Firms Serving Overseas Customers

Giving one-month’s notice, the Monetary Authority of Singapore (MAS) announced that from 30 June 2025, Singapore-based firms and individuals providing digital token (DT) services solely to customers overseas would need to cease operations unless they have a digital token services licence under the Financial Services and Markets Act 2022 (FSMA). On 6 June 2025, the MAS further stressed that it will generally not issue such licences and expects affected persons to cease operations in Singapore.  

While recent news headlines suggest this presents a change or even U-turn in regulatory policy, this comes as no surprise. Legislation was passed in Parliament back in 2022 with different parts of FSMA implemented in different phases. Part 9 of FSMA which contains the licensing framework for DT service providers (DTSP) will come into force on 30 June 2025. This comes after initial public consultation issued in February 2022, a subsequent public consultation in October 2024 and finally MAS’ response to feedback from the consultation on 30 May 2025. That said, the MAS’ recent clarifications on what constitutes “outside of Singapore” and its position on Singapore-based employees of foreign companies highlight some delicate nuances the market is still reacting to.

We breakdown some key points to note:

Who is affected?

Singapore-incorporated companies, partnerships or individuals who “from a place of business in Singapore” provide “DT services” “outside of Singapore”.

However, if you are already licensed or exempt for: (a) providing digital payment token (DPT) services under the Payment Services Act 2019 (PSA); (b) carrying on a business in capital markets product regulated activity under the Securities and Futures Act 2001 (SFA); or (c) providing financial advisory services under the Financial Advisers Act 2001 (FAA), this will not apply to you. There are other limited exemptions. 

Key questions to determine whether FSMA licensing is engaged:

What is the asset your activity relates to?

DT covers both DPTs regulated under the PSA (e.g. BTC, ETH, USDC, USDT) and tokens of capital markets products (e.g. tokenised units of funds, tokenised debentures) regulated under the SFA and FAA. However, there are certain types of tokens which may not be covered, e.g. NFTs, utility or governance tokens which do not satisfy the definition of DPT or capital markets products under SFA.

What activities are you carrying out in relation to the DT?

Generally, licensable activities under the PSA, SFA and FAA, e.g. facilitating an exchange, brokering, custodial services and transmission of DPTs are similarly licensable under FSMA. However, there are certain instances where the scope under FSMA is broader, specifically, providing advice in relation to the offer and sale of a DPT is not regulated under the PSA but is licensable under FSMA.

Whether your activities are “outside of Singapore”?   

Singapore firms serving customers in and outside of Singapore would typically be under the PSA, SFA or FAA and there is no change to this position. The FSMA licensing regime is not intended for these persons but aims to address a regulatory gap. It targets the AML/CFT risk presented by unlicensed Singapore-based persons who purportedly offer regulated services overseas given the internet-based and cross-border nature of such services specifically where they serve “solely customers outside Singapore”. However, recognising difficulty in regulating such persons given their substantive regulated activity is overseas, the MAS’ approach is that these licences will only be issued under “extremely limited circumstances”. Instead, affected firms are encouraged to restructure and cease Singapore operations.

MAS has clarified that Singapore residents employed by foreign companies and carrying out DT services outside of Singapore within the scope of their employment should not trigger the FSMA licensing requirements. However, we would need to consider if having employees based in Singapore would engage licensing under the SFA, FAA and PSA for the foreign company.