Regulations for activities relating to E-money

If I am providing a money transfer service, do I attract AML/CFT measures?


Payment Service Notice 01 lays out AML and CFT requirements for providers of money transfer services.

However, a licensee does not need to comply with MAS' AML/CFT requirements if it only provides money transfer services that meet the low risk criteria for ML/TF. The low-risk criteria set out in PSN01 can be found below:

Source: MAS (PS Act Guide)

According to MAS (Notices)

last revised on 1 March 2022

(b) where the payment service provider provides a domestic money transfer service, its business only involves one or more of the following types of transactions:

(i) payment for goods or services and where such payment is funded from an identifiable source; (ii) payment for goods or services and where the transaction value does not exceed S$20,000; or (iii) payment where such payment is funded from an identifiable source and where the transaction value does not exceed S$20,000, and

(c) where the payment service provider provides a cross-border money transfer service, its business only involves transactions that are used as payment for goods or services and are funded from an identifiable source. 


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