In support of its objective to transform Singapore into a smart financial centre, the Monetary Authority of Singapore (MAS) offers a regulatory sandbox (the Sandbox)to encourage financial services providers adopt innovative but safe financial technology. The Sandbox enables companies to experiment in a live market environment under relaxed legal and regulatory requirements for a limited time.

Overview of Various Sandbox Programmes

Original Sandbox

MAS launched the Sandbox in late 2016. (Please see our article providing an overview of the Sandbox.) The original Sandbox is designed to provide bespoke regulatory support for companies operating in all financial services sectors that employ technology not then in use in Singapore (i.e., first movers).

Sandbox Express

To provide faster support for companies operating lower risk financial services, MAS released Sandbox Express in 2019. (Please see our article on Sandbox Express.) MAS aims to respond to Sandbox Express applicants in 21 days, and approval allows participants to conduct market testing experiments for up to 9 months. Sandbox Express is available to insurance brokers and recognised market operators. (The availability of the Sandbox Express to remittance businesses was ceased in January 2020 due to the commencement of the Payment Services Act 2019.)

Sandbox Plus

Beginning1 January 2022, MAS will make the Sandbox available to a wider spectrum of companies and will provide financial support to qualified participants. Unlike the original Sandbox and Sandbox Express, which are limited to first movers, the new Sandbox Plus programme expands eligibility to include companies that are among the first, but not necessarily the first, to employ a financial technology in Singapore (i.e., early adopters).

The Sandbox Plus programme also offers new financial incentives to first movers applying for the original Sandbox. Successful applicants can receive up toS$500,000 to cover 50% of eligible expenses, including base salaries for personnel, professional services, hardware and software infrastructure and licences, equipment and IP rights, and certain training costs.

Applying to Join the Sandbox

The Sandbox is an attractive option for companies developing financial technologies and business models that are promising but unproven or not widely adopted.

In addition to basic information about the applicant, the Sandbox application requires the applicant to provide information in five areas:

• The applicant’s service
• The legal and regulatory requirements that apply to the applicant’s service and the specific requirements the applicant wishes MAS to relax
• The applicant’s fitness and financial standing
• The details of the experiments the applicant proposes to conduct in the Sandbox
• Basic financial information

The remainder of this article provides guidance and tips for companies applying to join the Sandbox.

Readiness

As a preliminary matter, the applicant must consider whether its service is ready for experimentation in the Sandbox. For example, has the applicant successfully completed development and laboratory testing? The purpose of the Sandbox is to enable participants to test a version of their service that is almost ready for full commercial release, not as a way to incorporate live customers into their product definition and development processes.

The Service

The application requests information about the applicant’s service in four dimensions:

• the position of the service in the market: What new or differentiated benefits does the service provide to customers, and how does the applicant’s technology contribute to the realisation of those benefits?
• the business model for the service: Who are the target customers? What is the service delivery model? How will customer monies be held and safeguarded?
• the technical architecture of the service: What aspects of the technical architecture are ‘smart’, leading edge or innovative and not already widely in use in Singapore?
• the state of development of the service: When will the service be ready (a) for demonstrate to MAS, (b) for experimentation in the Sandbox, and (c) to exit the Sandbox and enter full production?

Legal and Regulatory Requirements

Under the Sandbox, MAS grants participants relief from certain legal and regulatory requirements while they conduct their Sandbox experiments. However, it is important to note that MAS will not relax requirements related to customer safety, such as protections for customer information and funds, or those related to anti-money laundering and countering the financing of terrorism (AML/CFT).

Fitness and Financial Standing

The profile of the applicant, including its financial health and track record, and of the applicant’s key stakeholders – the directors, the CEO and other senior leaders critical to the success of the applicant’s business – are focus areas in MAS’s evaluation of a Sandbox application.

The applicant must also consider whether the applicant itself or any of its key stakeholders meet MAS’s fit and proper guidelines, especially those related to honesty and integrity.

The Sandbox Experiments

In its Sandbox documentation, MAS refers to participants’ ‘experiments’ during their Sandbox periods, i.e., a test to determine whether a hypothesis is true where the outcome is uncertain. The Sandbox application contemplates that the applicant will conduct multiple experiments during the Sandbox period.

Finally, the applicant must carefully consider and describe how it will manage its exit from the Sandbox. If its Sandbox experiments are successful and it will launch a full commercial version of its service, what does that full commercial version look like and how will customers be transitioned to that version?

For More Information

OrionW regularly advises clients on financial technology matters.  For more information about financial technology regulations, or if you have questions about this article, please contact us at fintech@orionw.com.

Disclaimer: This article is for general information only and does not constitute legal advice.

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