This update focuses particularly on the expansion of the scope to domestic money transfer (DMT) service, cross-border money transfer (CBMT) service and digital payment token (DPT) service, and examines who are the persons affected by such expansion, as well as what needs to be done by such affected persons in order to benefit from transitional arrangements and continue operations.
In summary, there are two groups of persons affected by the expanded scope, and different actions apply to each group as follows:
Persons who had started providing the expanded scope of services before 4 April 2024.These persons will be able to benefit from temporary transitional arrangements under Phase 2, which will allow them to continue providing such services. In order to so benefit, these persons would need to take the certain actions (including submission of a notification to MAS before 4 May 2024) as discussed in the update.
Persons who only started providing the expanded scope of services from 4 April 2024.These persons must immediately cease providing such services, unless they can rely on an applicable exemption or exclusion to do so.
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."
Eunice is a principal in the Financial Services Regulatory practice group of Baker McKenzie's Singapore office and a member of the Firm's Global Financial Services Regulatory Steering Committee. Eunice has extensive experience in regulatory, legal and compliance matters in the financial services and fintech sectors. Her clients include banks, investment managers, broker-dealers, payments companies and other financial institutions.
Eunice is consistently recognised as the Next Generation Partner for Financial Services Regulatory in Legal 500 Asia Pacific. Clients have described her as: “an exceptional lawyer with deep knowledge of financial services; "commercial and solutions-oriented and has an excellent relationship with the regulator which is of benefit to her clients"; "singled out for being smart and having the ability to navigate the Singapore regulatory landscape"; "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.
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".