Regulations for custodian wallets

As a custodian wallet service, must I hold a payment service provider licence?

If a custodian wallet service provides any of the activities currently regulated under DPT service provider, it will need to be licensed.

According to MAS (Consultation – Response Paper)
last revised on 4 November 2020

If a wallet is able to hold both moneys and DPTs, and the payment service provider carries on a business of providing DPT services, account issuance services and e-money issuance services, the payment service provider will need to be licensed to provide any of those services.