SINGAPORE Trends and Developments Contributed by: Adrian Ang and Benjamin Samynathan, Allen & Gledhill LLP
ent forms of settlement assets” (such as wholesale CBDCs, tokenised commercial bank money and regu - lated stablecoins), introduce programmable controls to enhance and automate compliance checks, and explore “agentic payments”, where AI agents can automatically execute payments upon the fulfilment of smart contract conditions. This integration of AI and DLT is a frontier area for Singapore’s fintech strategy. Project Nexus is an initiative to enhance cross-border payments. Led by the Bank for International Settle - ments’ Innovation Hub Centre in Singapore, Nexus aims to connect domestic Instant Payment Systems globally through a standardised multilateral network. Following a successful proofs-of-concept connecting Singapore’s FAST, Malaysia’s RPP and the Eurosys - tem’s TIPS, the project has moved to the implementa - tion phase. Notably, in April 2025, the central banks of Singapore, Malaysia, Thailand, the Philippines and India incorporated Nexus Global Payments (NGP) in Singapore. NGP is a not-for-profit organisation incor - porated in Singapore, which is dedicated to managing the Nexus scheme. Once operational, Nexus should reduce the cost taken to effect cross-border remit - tances across connected payment systems, as well as the time taken to effect such a remittance to under 60 seconds (in most cases). Consumer Protection The rapid digitalisation of finance has been accompa - nied by a sophisticated wave of digital scams. In 2024 alone, scam losses in Singapore reached a record SGD1.1 billion. In 2025, victims lost over SGD840.3 million to scams as of November 2025. In response, the regulatory focus has shifted heavily towards con - sumer protection and scam mitigation. For example, the Shared Responsibility Framework (SRF), which began implementation on 16 December 2024, implements a model of shared accountability involving FIs, telecommunications companies (telcos), and account holders. The SRF operates on a “water - fall” approach to liability. • Financial institutions (first line) – FIs are the first point of assessment. They must fulfil specific anti- scam duties, such as imposing a 12-hour cooling- off period for high-risk activities and providing real-
time notification alerts. If an FI fails in these duties, it must reimburse the account holder. • Telcos (second line) – if the FI has met its obliga - tions, the telco is assessed for scams perpetrated by SMS. Telcos must block certain SMS messages and implement anti-scam filters for malicious URLs. If the scam originated from a failure in these telco duties, the telco bears the liability. • Consumers (final line): if both the FI and telco have fulfilled their duties, the loss falls on the account holder. This design maintains the incentive for indi - vidual vigilance while ensuring systemic safeguards are in place. The SRF also requires FIs to implement real-time fraud surveillance directed at detecting unauthorised transactions in a phishing scam. In a scenario where a protected account is rapidly drained of a material sum to a scammer (this is currently defined in footnote 8 of the SRF Guidelines to mean more than 50% of a minimum balance of SGD50,000 being transferred out within 24 hours), the responsible FI must either block or hold certain transactions that would result in the stipulated threshold being crossed, and obtain verification from the account holder or send a notifica - tion to the account holder. MAS granted a transition period until 16 June 2025 for FIs to fully operationalise this specific capability. In conjunction with the SRF, major retail banks imple - mented “ Enhanced Fraud Surveillance” measures on 15 October 2025. These measures apply to bank accounts with balances of SGD50,000 or more. If a transaction (or series of transactions) results in more than 50% of the account balance being transferred out within 24 hours, the transfer is automatically blocked or subjected to a mandatory 24-hour holding period. This “friction by design” is intended to buy time for customers to realise they are being scammed and to intervene. Banks also continue to offer the “Money Lock” feature, allowing customers to ringfence a por - tion of their funds that cannot be transferred digitally. This feature has seen high adoption rates among risk- averse demographics. As of 30 June 2025, at least SGD30 billion has been locked under this feature. For Digital Payment Token Service Providers (DPT - SPs), stringent consumer protection rules came into
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