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In brief

On 8 May 2023, the Monetary Authority of Singapore (“MAS“) issued Consultation Paper P004-2023 proposing changes to subsidiary legislation to address, among others, the regulatory requirements applicable to payment services that will soon become licensable under the Singapore Payment Services Act 2019 (“PSA“).


Such payment services include, among others:

  1. facilitating the transmission of digital payment tokens (“DPTs“) from one account to another;
  2. custodial services for DPTs;
  3. facilitating the exchange of DPTs where the service provider does not come into possession of the money or DPTs involved;
  4. domestic money transfers where financial institutions are either the payer or the payee (which were previously carved out);
  5. cross-border money transfer services which involve the facilitation of transfers of money between persons in different jurisdictions, even where the money does not flow through Singapore (the “Newly Scoped-In Services“).

The MAS also proposes to make some technical amendments to the Payment Services Regulations 2019 (“PSR“) and Notices to the PSA which will be of general application to licensees, as well as to introduce new regulations on transitional exemptions.  

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Stephanie Magnus co-heads the Asia Pacific Financial Institutions Group and heads up the Financial Services Regulatory Practice Group in Singapore. Stephanie is ranked Band 1 for FinTech in Singapore by Chambers FinTech 2020. She is also ranked as a Leading Individual for Financial Services Regulatory: Local Firms in Singapore by Legal 500 Asia Pacific 2020. She is recognised as a leading lawyer for Banking & Finance: Regulatory in Singapore by Chambers Asia Pacific and Chambers Global 2020. Stephanie was quoted in Chambers Asia Pacific for her "timely, practical and business-oriented" advice, with a "deep understanding of the regulatory regime." She is also recognised as "very business-savvy and brilliant every time," and is admired for her "very strong grasp of the legal issues from both a technical and practical perspective."

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Eunice is a principal in the Financial Services Regulatory practice group of Baker McKenzie's Singapore office. She specialises in regulatory, legal and compliance matters in the financial services and fintech sectors. Eunice is recognised in Legal 500 Asia Pacific as the Next Generation Partner for Financial Services Regulatory, where she was "singled out for being smart and having the ability to navigate the Singapore regulatory landscape" and "is responsive, pleasant and willing to explore different parameters" and "is outstanding in that she always carefully and clearly explains the situation and background of the issue so that we can fully understand it, she always has a quick response and she has a deep understanding of the financial industry and our company." Eunice is a frequent speaker at legal and financial industry seminars and forums. She also regularly assists clients in coordinating industry responses and participate in consultation with the Monetary Authority of Singapore on policy and legislative changes.

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Ying Yi is a Local Principal in the Financial Services Practice Group of Baker McKenzie Wong & Leow in Singapore. She focuses on regulatory and compliance issues in the financial services sector. She is ranked Next Generation Partner for Fintech and Financial Services Regulatory: Local Firms by Legal 500, Up and Coming for Banking and Finance: Regulatory in Singapore by Chambers Asia Pacific and Band 3 for Fintech Legal in Singapore by Chambers Fintech.
She is described as an "outstanding lawyer" who is "praised for being in touch with market developments and going the extra mile to understand client needs" by Legal 500 Asia Pacific. Chambers Asia Pacific cites her strengths as "responsive and genuinely cares about her clients and their business goals. She is very well connected and tuned into the latest regulatory developments, especially in the fintech, digital payments and blockchain space".

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