SINGAPORE Law and Practice Contributed by: Kenneth Pereire and Lin YingXin, KGP Legal LLC
InsurTech Insurance-focused fintechs like Singlife with Aviva leverage AI and big data to provide affordable, cus - tomisable policies. Embedded insurance solutions integrated into e-commerce platforms and ride-hailing apps are also gaining traction. Crypto and Digital Assets Singapore remains a hub for cryptocurrency and blockchain-based businesses. Established players like Crypto.com and new platforms continue to offer services such as digital asset trading, tokenised secu - rities and custody solutions. MAS’s regulatory frame - work ensures market stability while fostering innova - tion in decentralised finance (DeFi). Regtech Regulatory technology solutions have gained impor - tance, helping financial institutions automate compli - ance processes. Companies like Tookitaki offer AI- powered solutions for anti-money laundering (AML) and risk management, addressing stricter regulatory requirements. Green and ESG Fintech Sustainability-focused fintechs, such as GreenArc Capital, support green finance by providing tools to track ESG metrics, enabling businesses and investors BaaS platforms allow businesses to integrate bank - ing services into their offerings. Fintechs like Nium enable non-financial companies to provide payment, credit and remittance services, creating new revenue streams. 2.2 Regulatory Regime Digital payment providers are regulated under the PSA for services like e-money issuance and digital payment token services. Licensing options include Money-Changing Licence, SPI or MPI. Providers must comply with AML/CFT rules (MAS Notice PSN02) and TRM Guidelines for cybersecurity. Following amend - ments introduced in 2024, the scope of regulated payment services was expanded and additional user protection requirements for digital payment token ser - vice providers were implemented in phases, includ - to meet sustainability goals. Banking as a Service (BaaS)
ing enhanced safeguarding and operational resilience measures. Crypto exchanges may be regulated under the PSA for digital payment tokens and under the SFA where the platform deals in tokenised capital markets prod - ucts. Depending on the activities conducted, such platforms may be licensed under the PSA and/or sub - ject to licensing or recognition requirements under the SFA. Digital token service providers (DTSPs) that are incor - porated in Singapore and provide digital token ser - vices to customers outside Singapore are regulated under the Financial Services and Markets Act 2022 (FSMA 2022). Such entities are required to be licensed by the MAS, notwithstanding that their services are provided exclusively to overseas customers. This regime reflects MAS’s approach to mitigating money laundering and terrorism financing risks associated with cross-border digital asset activities and repre - sents an extension of Singapore’s regulatory perim - eter beyond services offered to persons in Singapore. Insurtech providers are regulated under the Insurance Act and FAA for licensing as insurers, intermediaries or financial advisers. They must follow MAS insurance disclosure guidelines and PDPA for data protection. Digital lending platforms may be governed by the Moneylenders Act for consumer lending and by the SFA where lending activities involve capital markets products or investment-based structures. They may require a Capital Markets Services Licence and must meet MAS disclosure and risk management stand - ards. Embedded finance (BaaS) is regulated under the Banking Act and PSA. Providers must comply with MAS TRM Guidelines and outsourcing standards for cybersecurity and data protection. Green and ESG fintech is subject to MAS Environmen - tal Risk Management Guidelines and must align with frameworks like TCFD, report ESG data and follow PDPA when handling sensitive information.
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