According to MAS, firms that fall under Section 137 of the FSM Act are treated as operating from Singapore, even if most of their work happens overseas.
That means even if token services aren’t your main thing, you still need a license to keep going. No extra time is coming—MAS says they won’t offer any transition period. Acting after June 30, 2025 without proper approval could lead to serious trouble.
Only businesses that already have a spot under existing financial laws—like the Securities and Futures Act, the Financial Advisers Act or the Payment Services Act—can carry on without worrying about the new DTSP rules. That limits how many outfits can still serve overseas clients without significant changes.
Hagen Rooke, a partner at Gibson, Dunn & Crutcher, warned that MAS will hand out new DTSP licenses only in very rare cases. He said these kinds of services bring extra concerns around anti-money laundering and stopping terrorist financing.
That means most firms will find it hard to qualify. MAS will grant licenses under the new framework only in extremely limited circumstances, Rooke wrote on LinkedIn. He urged local outfits to look at ways to strip out their Singapore links or move parts of their operations elsewhere to avoid falling under these strict rules.
Small and mid-sized firms that built a global user base from Singapore now face a tough choice: scale back to serve local customers only, or shift their headquarters outside Singapore’s borders.
For many, it may come down to cost. The extra work needed to meet tighter checks could be more than what fledgling teams can handle. Some business owners worry this will push talent away, as engineers and compliance officers might follow jobs to friendlier crypto hubs.
Big players, including established banks or deep-pocketed startups already licensed under other Acts, are better placed to survive these changes.
Featured image from Unsplash, chart from TradingView
