Provider of multiple Payment Services

The payment services of domestic money transfer, cross border money transfer and merchant acquisition appear to overlap. Is that intended?

According to MAS (FAQs)
last revised on 31 March 2020

16.1 MAS recognises that there may be instances where the service of merchant acquisition overlaps with the service of domestic money transfer or cross border money transfer. For example, the merchant acquirer may provide a domestic money transfer service in the same transaction if it serves the payer as well. This is common for e-wallet (payment accounts that contain e-money) issuers. In another example, the merchant acquirer may provide a cross border money transfer service in the same transaction if it receives money from overseas on behalf of the merchant in Singapore or if it accepts money in Singapore for the purpose of transmitting, or arranging for the transmission of, the money to a merchant overseas. Please note that these examples are for illustration only and are not exhaustive. 

16.2 [But even when] a person provides more than one payment service in the course of a payment transaction, the PS Act does not impose duplicative requirements for safeguarding of the funds in transit. The obligation under section 23 for a MPI to safeguard funds in transit for all three services mentioned applies to the total sum of relevant money held by the MPI. This means that if two services are provided in the course of a single transaction, the relevant money to be safeguarded in that transaction does not double simply because two services are provided for the same transaction. Further, in respect of AML/CFT requirements, merchant acquirers that provide other payment services as part of their merchant acquisition business should note that low risk transactions set out in the relevant AML/CFT notice do not attract AML/CFT measures.

16.3 That said, a person should ensure that the person has in force a licence that entitles the person to carry on a business of providing all the payment services the person provides.

(Edits by FinReg)