Operating or listing on a crypto exchange

What constitutes a "digital payment token exchange"?


  • According to MAS (PS Act - First Schedule)

    last revised on 31 December 2021

    “digital payment token exchange” —
    (a)    means a place, or a facility (whether electronic or otherwise), where —
    (i)    offers or invitations to buy or sell any digital payment token in exchange for any money or any other digital payment token (whether of the same or a different type), are regularly made on a centralised basis;
    (ii)    those offers or invitations are intended, or may reasonably be expected, to result (whether directly or indirectly) in the acceptance of those offers or in the making of offers to buy or sell digital payment tokens in exchange for money or other digital payment tokens (whether of the same or a different type), as the case may be; and
    (iii)    the person making any such offer or invitation, and the person accepting that offer or making an offer in response to that invitation, are different persons; but
    (b)    does not include a place or facility (whether electronic or otherwise) that is used exclusively by one person to do only either or both of the following things:
    (i)    to make offers or invitations to buy or sell any digital payment token in exchange for any money, or any digital payment token (whether of the same or a different type);
    (ii)    to accept any offer to buy or sell any digital payment token in exchange for any money, or any digital payment token (whether of the same or a different type);

    Finreg business tip
    Operating a digital payment token (DPT) exchange will require licensing under the Payment Services Act as a major payment institution (MPI) or Standard Payment Institution (SPI) licence.

    The activities on a DPT exchange would fall under the definition of a DPT service:

    According to MAS (Payment Services Act – First Schedule),

    "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);

    "facilitating the exchange of”, in relation to any type of digital payment token, means establishing or operating a digital payment token exchange for that type of digital payment token, in a case where the person that establishes or operates that digital payment token exchange, for the purposes of an offer or invitation (made or to be made on that digital payment token exchange) to buy or sell that type of digital payment token in exchange for any money or any digital payment token (whether of that type or a different type), comes into possession of any money or any digital payment token, whether at the time that offer or invitation is made or otherwise;

    "facilitating the exchange of digital payment tokens” means establishing or operating a digital payment token exchange, in a case where the person that establishes or operates that digital payment token exchange, for the purposes of an offer or invitation (made or to be made on that digital payment token exchange) to buy or sell any digital payment token in exchange for any money or any digital payment token (whether of the same or a different type), comes into possession of any money or any digital payment token, whether at the time that offer or invitation is made or otherwise;

FinReg business tip

Operating a digital payment token (DPT) exchange will require licensing under the Payment Services Act as a major payment institution (MPI) or Standard Payment Institution (SPI) licence.