The MAS has issued a consultation paper proposing additional protections for customers of digital payment token service providers, including asset custody and segregation, disclosure and record-keeping requirements.


MAS Consults on Draft Protection Measures for DPT Service Customers

July 5, 2023

The Monetary Authority of Singapore (MAS) has issued a consultation paper proposing amendments to the Payment Services Regulations (PS Regulations) that would impose the following key requirements on digital payment token (DPT) service providers (DPTSPs) by October 2023 [Note 1]:

  • deposit customers’ money and assets (e.g., DPTs) in a separate account and hold the assets in trust for their customers’ benefit;
  • segregate customers’ money and assets from DPTSPs’ own assets (although assets of various customers may be commingled with each other);
  • provide customers with disclosures regarding the terms applicable to the safeguarding of their assets;
  • maintain separate book entries for each customer and its assets;
  • daily reconciliation of customers’ money and assets;
  • have adequate processes in place to reduce the risk of loss of customers’ assets due to fraud or negligence; and
  • have effective controls in place to mitigate potential conflicts of interests arising from the safeguarding of customers’ assets.

The proposed requirements are derived from comments to a previous MAS consultation paper on regulatory measures for protecting DPTSP customers (see our article on the previous consultation paper).  

While the PS Regulations do not apply to DPTSPs operating under a temporary exemption pursuant to the Payment Services (Exemption for Specified Period) Regulations 2019, MAS expects such temporarily exempt DPTSPs to comply with the additional protective measures, once they are in place.

The deadline for comments on the consultation paper is 3 August 2023.

For More Information

OrionW regularly advises clients on FinTech matters.  For more information about the regulation of financial technology in Singapore, or if you have questions about this article, please contact us at

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


[1] Under the Payment Services Act 2019 (PS Act), a DPT service means: (a) any service of buying or selling DPTs in exchange for money or any other DPT (subject to certain exceptions) or (b) any service of operating a DPT exchange to offer to buy or sell DPTs in exchange for money or any other DPT, where the service provider comes in to possession of any money or any DPT.  Once the amendments to the PS Act take effect, the scope of DPT services will be expanded to also include the following services: (i) transferring or arranging the transfer of DPTs; (ii) safeguarding or managing DPTs or instruments that enable control over DPTs; and (iii) facilitating the exchange of DPTs where the service provider does not come into possession of any money or any DPT.


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