Overview of Crypto cards

Cryptocurrencies in Singapore typically fall under the definition of “digital payment token” under the PS Act, which regulates intermediaries of digital payment token services. 

Crypto card providers that are providing any credit facilities will need to be licensed under the Banking Act. 

Note that crypto card providers are not subject to duplicative requirements under both Acts. If they are already licenced under the Banking Act they will not need a an additional licence under the PS Act, but they will have to comply with the additional requirements.

According to MAS (FAQs)

last revised 31 March 2021

In order to avoid double regulation of the same activity, banks, merchant banks and finance companies are exempted from holding a licence, and from complying with requirements that these DTIs (Deposit Taking Institutions) are already subject to under the Banking Act, MAS Act, and FCA. Bank-issued credit cards are also regulated under the Banking Act. DTIs are subject to the same requirements as non-DTIs for payments-related activities. For example, DTIs are not exempted from requirements in the PS Act relating to e-money issuance services, and DPT services. They are therefore treated in the same manner as other licensees in order to maintain a level playing field.

Non-bank credit cards or charge cards issuers are also exempted from holding a licence and complying with licensing-related requirements. Non-bank credit card or charge card issuers are already required to hold a licence under the Banking Act for the provision of credit facilities. Non-bank credit card issuers however need to comply with the other requirements in the PS Act, that do not overlap with those in the Banking Act.

⋮

MAS has carved out from regulation any payment service mentioned in Part 1 of the First Schedule to the PS Act, that is provided by any person licensed, approved, registered or regulated or exempt from being licensed, approved, registered or regulated under the SFA, FAA, TCA and Insurance Act where the payment service is solely incidental to or necessary solely for that person to carry on that person’s business in any regulated activity for which that person is so licensed, approved, registered, regulated or exempted from being licensed, approved, registered or regulated to provide under those Acts. This is to facilitate the provision of financial services under these Acts and to avoid double regulation.