Facilitating Crypto Trading

Yes, providing any platform to facilitate OTC crypto trading will likely be considered providing a digital payment token (DPT) service regulated under the Payment Services Act.

"The PSA now regulates entities offering any of the following DPT-related services as digital payment token service providers:

• Buying or selling DPTs;
• Establishing or operating a DPT exchange; and
• Participating in and offering financial services related to the offer and/or sale of a DPT by an issuer.
• Transfer or transmittal of DPTs from one DPT address to another
• Inducing (or attempting to induce) any person to buy or sell DPTs (without the DPT service provider actually accessing any money or DPTs)"

Source: Sygna

According to MAS (Payment Services Act – First Schedule),
last revised 31 December 2021

“digital payment token service” means any of the following services:

(a) any service of dealing in digital payment tokens (other than any such service that the Authority may prescribe);
(b) any service of facilitating the exchange of digital payment tokens (other than any such service that the Authority may prescribe);

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"dealing in”, in relation to any digital payment token, means the buying or selling of that digital payment token in exchange for any money or any other digital payment token (whether of the same or a different type), but does not include any of the following:

(a) facilitating the exchange of digital payment tokens;
(b) accepting any digital payment token as a means of payment for the provision of goods or services;
(c) using any digital payment token as a means of payment for the provision of goods or services;