Regulations for E-wallets

Why is it necessary to regulate the provision of an e-wallet as a separate activity from the issuance of e-money? Are they not the same?

According to MAS (FAQ)
last revised on 31 Mar 2021

20.1 The e-wallet is a payment account from which the customer pays. A consumer purchases e-money from a business to enable him to make money transfers or purchase goods or services from participating individuals and merchants which accept such e-money. Often, the entity operating the e-wallet also issues the e-money. However, there is also a possibility that the e-wallet is provided by an entity that is separate from the issuer of the e-money.

20.2 The service provider that provides and maintains this e-wallet performs an account issuance service, which poses all four key risks and concerns that need to be addressed: ML/TF risks, technology risk, user protection and interoperability concerns. The activity of e-money issuance however only carries user protection risks. The PS Act obliges MPIs that issue e-money to safeguard customer money from their own insolvency.