Payment services: Cross-border money transfer service

What constitutes a "person outside Singapore" for the purposes of cross border money transfers?

According to MAS (FAQs)
last revised 31 March 2021

15.1 Where a service provider carries on a business of accepting money in Singapore for the purpose of transmitting the money to any person outside Singapore, or receiving money from outside Singapore for any person in Singapore, it would be considered to be providing a cross-border money transfer service.

15.2 [...] in considering whether or not a transfer is made to a “person outside Singapore”, the residency status of the person outside Singapore should not be a material consideration. As long as the transfer of money is made to any person (including an account) outside Singapore, it would be considered as a “person outside Singapore” for the purpose of cross-border money transfer service.