Regulations for all Payment Services Providers
Does the transfer of crypto fall under money transfer services?
No. Regulated money transfer services involve the transfer of fiat or e-money. From MAS' regulatory standpoint, crypto is not considered e-money because:
"DPT is a concept unique to Singapore and the regulatory regime surrounding it sits alongside that for a more traditional concept of e-money, derived from and very similar to the UK/European concept. It seeks to capture crypto assets like bitcoin and ether – the "classic" virtual currencies. In defining a DPT, Singapore sought to create a mutually exclusive regime from e-money."
"As the framework of the PSA helpfully differentiates between e-money and DPTs, it is clear that any person who intends to provide the services of transferring fiat currency or e-money, or both, would require a payment service provider licence in respect of domestic money transfer services and cross-border money transfer services, as applicable."
"Furthermore, [...] the service of dealing in DPTs (buying or selling, or both) and the service of facilitating the exchange of DPTs through establishing or operating a DPT exchange would constitute DPT services, for which a licence is required under the PSA."
"While at present the transfer of DPTs is not a service for which a licence is required under the PSA, in light of forthcoming amendments to the PSA, this will change in the future."