Regulations for E-wallets

My business involves storage of stablecoins in an e-wallet. Am I regulated?

  • Stablecoins are currently not regulated by MAS, and are neither considered "digital payment token" nor "e-money" (both regulated).

    The definition of “e-money” provides that it is an electronically stored monetary value that is, among other things, denominated or pegged to a particular fiat currency. A “stablecoin” would not amount to e-money as defined as it is backed by a basket of assets or currencies, and not a single currency.

    The definition of “digital payment tokens” states that it is a digital representation of value that, among other things, is not denominated or pegged to any currency. As “stablecoins” are backed by a basket of currencies and other assets, they would not amount to “digital payment tokens” as defined.

    Source: Allen & Overy, last revised on 20 Jan 2020