Singapore Digital Token Service Provider (DTSP) License

• Tetra Consultants start by conducting a detailed evaluation of the proposed business model to understand whether the planned activities fall under the Singapore Digital Token Service Provider (DTSP) License regime. This consists of assessing the nature of digital tokens, target markets, and service offerings under the MAS DTSP guidelines.  

• We help with the incorporation of a Singapore business entity, which includes the appointment of a nominee director for the initial setup procedure. The nominee director is used only for the company incorporation, with a structured plan to transition to a permanent local director within six months.  

• Our team then begins the recruitment process to hire a qualified local Executive Director and local Compliance Officer (management level) who fulfills the fit and proper requirements set up by the MAS. Tetra Consultants will ensure that individuals possess relevant regulatory and industry experience.  

• Our team then prepares all the mandatory documents that are needed for the MAS DTSP License. This includes all the business plan, AML/CFT framework, risk management policies, internal controls, governance structure, and compliance manuals.  

• Our team then coordinates with the MAS-approved law firm to get a formal legal opinion in order to confirm whether the proposed digital payment token service Singapore activities are controlled and fall within the DTSP licensing framework.  

• Once the documents and legal opinions are finalized, Tetra Consultants then submits a completed and well-secured Singapore Digital Token Service Provider (DTSP) License application to the MAS.  

• MAS may assign a case officer, and request clarifications or an interview with key management personnel or the Compliance Officer. Our team will provide regulatory guidance and interview preparation in order to ensure readiness.  

• Upon getting the approval, the license will be issued. Tetra Consultants will then help you with post-licensing requirements, this includes the opening of operational and segregated bank accounts, and ongoing compliance advisory.  

Documents needed for Singapore Digital Token Service Provider (DTSP) License

• In order to get a DTSP License in Singapore, the MAS usually expects a detailed application. The exact checklist of this license is set out in MAS Form 1 and related guidance. Applicants will have to prepare these documents: 

Corporate and ownership documents  

• Certificate of incorporation, constitution, and present business profile/company extract 

• Board resolution approving the application, and hiring key officers (CEO, compliance officer, MLRO, and director) 

• Detailed shareholding chart that shows ultimate beneficial owners, controllers, and any group structure. This also includes percentages and justification of each entity 

Business plan and operations

• Detailed business plan that describes all the services such as (DPT exchange, custody, transfer), along with target customers, jurisdictions served, and channel of distribution 

• Organizational chart (group-level and entity-level) showing reporting lines, risk management, IT/security, internal audit, and compliance function 

• Detailed description of business model (revenue streams, counterparties, fee structure, and on/off-ramp arrangements) 

AML/CFT, and sanctions documentation 

• Full AML/CFT policy and processes, that are aligned with the MAS notices (such as CDD, EDD for high-risk customers, ongoing monitoring, PEP handling) 

• Customer risk evaluation methods and enterprise-wide risk evaluation, which covers products, geography, delivery channels, and types of customers 

• Processes for STR filing, transaction monitoring rules and scenarios, name screening setup, and record-keeping standards 

Financial and capital documents  

• The latest audited financial statement of the applicant for the past three years 

• Financial projections along with capital adequacy evaluation that covers at least 3 years, along with assumptions regarding transaction volumes and DPT float 

• Evidence of fulfilling the capital requirements, such as bank statements, capital injection documents, and shareholder funding arrangements. 

Governance, fit and proper 

• Fit and proper declarations along with detailed CVs for directors, CEO, key executives, compliance officer, shareholders, and MLRO 

• Board and management governance framework, which consists of committees, meeting frequency, risk and compliance oversight, along with conflict-of-interest policy 

• Internal policies regarding fitness and propriety, remuneration (where relevant), and handling of conflicts of interest, related-party transactions, and whistleblowing 

Technology, cybersecurity, and DPT-specific attachments  

• Overview of technology architecture, and IT operations documentation (systems, APIs, security zones, key vendors, and hosting) 

• DPT-specific technology evaluation questionnaire, and supporting documents (wallet design, private key management, segregation of client assets, backup and recovery) 

• Framework of cybersecurity and policies (access control, encryption, key management, and incident response) 

Risk management and compliance frameworks 

• An enterprise-wide risk evaluation framework, which includes risk taxonomy and limits 

• Compliance manual that covers monitoring, internal controls, regulatory reporting, and remediation processes 

• Outsourcing policies and registers with copies of material outsourcing agreements (such as cloud, KYC providers, and custodians) and oversight mechanisms 

Regulatory forms and declarations 

• Completed MAS application form (Form 1 – Application for a DTSP License) 

• Relevant declaration, confirmation, and checklist that is embedded in the form (such as no disqualifying events, consent to checks, and accuracy of information) 

• Any legal opinions required (such as token classification, group regulatory evaluation) and external auditor confirmations where MAS expects them 

Requirements for a Singapore Digital Token Service Provider (DTSP) License

• In order to get a Singapore Digital Token Service Provider (DTSP) License, applicants are required to fulfill the regulatory, governance, financial, and operational requirements that is prescribed by the Monetary Authority of Singapore (MAS), under the Financial Services and Markets Act 2022, and related DTSP regulations: 

• The applicant should be a Singapore-incorporated company or a Singapore branch of a foreign corporation, subject to MAS evaluation 

• The applicant is expected to hire appropriate locally based senior management, which will consist of  
  • At least one executive or non-executive director who is ordinarily resident in Singapore, and  
  • An executive director or senior officer holding a valid employment pass, wherever applicable 

• The applicant will have to maintain a permanent place of business or a registered office in Singapore, where all the books, records, and regulatory information will be properly maintained 

• The applicant should showcase adequate staffing arrangements in order to handle regulatory communications, customer inquiries, and complaints  

• The minimum base capital is S$250,000 along with an annual license fee of S$10,000 regardless of business size. There is no application fee 

• The applicant will have to submit forward-looking financial projections, along with evidence of the ability to meet the ongoing solvency and liquidity expectations 

• All controllers, directors, senior management, and key officers should satisfy the fit and proper criteria of MAS. This includes integrity, competence, and financial soundness 

• The board and senior management should exercise effective oversight, with clearly defined responsibilities for compliance, risk management, and AML/CFT 

• The applicant will have to establish a strong AML/CFT framework that is aligned with the applicable MAS notices (including FSM-N27), incorporating: 
  • Risk-based customer due diligence (CDD) and enhanced due diligence (EDD) 
  • Ongoing transaction monitoring 
  • Timely suspicious transaction reporting  
  • Sanctions and adverse media screening  

• Adequate technology risk management and cybersecurity controls, this includes access controls, incident response procedures, penetration testing, system resilience, and recovery planning  

• The applicant will have to show the adoption of customer protection measures, this includes appropriate disclosure of risks that is associated with digital payment tokens and safeguards in order to prevent misuse of customer assets  

• A legal opinion from a Singapore-based law firm that is experienced in MAS-regulated financial services, evaluating the business model, and confirms the regulatory status of the proposed digital token services 

• Compliance with ongoing regulatory reporting obligations to MAS, which includes finance, compliance, and operational reporting 

• Maintenance of an internal audit function or an independent review mechanism to periodically evaluate the effectiveness of the key controls, especially AML/CFT and technology risk 

• Prompt notification to the MAS regarding material changes (business model, control changes, key officers, and cyber incidents), and continued compliance to all guidelines on DPT positions, and conduct  

Common challenges in obtaining Singapore Digital Token Service Provider (DTSP) License

Strong documentation  

• MAS demands an endless list of documents and submissions, which consists of legal opinion on token classification, independent auditor reports on AML/CFT controls, a detailed 3-year business plan with revenue models, and risk evaluations. If you submit incomplete or misaligned packages, it will trigger multiple revision rounds, delaying approvals for months.  

• At Tetra Consultants, our team will collect all the documents, this includes indexed folders, explanatory memos, a financial model stress-tested for DPT volatility, and Singapore lawyer opinions.  

Local presence and governance gaps 

• MAS has made it compulsory for the business to have a Singapore-resident director, physical office, and robust board oversight, which is a challenge for foreign firms. Providing “fitness and propriety” for controllers and key personnel is usually a difficult task for foreign entrepreneurs.  

• At Tetra Consultants, our team assists you in hiring a local executive director and ensures that all the key personnel are fulfilling the “fit and proper” criteria set by the MAS to ensure that the application process is going smoothly.  

Ongoing compliance obligations 

• MAS has stringent compliance obligations that the business has to follow. This includes regulatory reporting, which consists of financial, transaction, and compliance-related information. Regular maintenance of internal audit or equivalent independent review of the key controls, especially AML/CFT and technology.  

• At Tetra Consultants, we provide regulatory compliance consulting and corporate bank account opening services in order to ensure that your business is fulfilling all the compliance obligations and is easily surviving in the strong regulatory environment of Singapore.   

Cost of getting a Singapore Digital Token Service Provider (DTSP) License

• The cost of getting a Singapore Digital Token Service Provider (DTSP) License differs on the basis of the nature and complexity of the proposed digital token business activities. The regulatory scope needed, and the level of compliance infrastructure needed by the MAS, also impact the costs. The major cost components usually include Singapore company registration, nominee director arrangements, recruitment of a qualified local executive director and compliance officer (management level), and preparation of detailed compliance and AML/CFT documentation. At Tetra Consultants, our team clearly communicates all the costs to you during the initial consultation, so that you know for exactly what services you are paying for.  

How can Tetra Consultants help with Singapore Digital Token Service Provider (DTSP) License

• Tetra Consultants provides end-to-end professional assistance for businesses looking to get a Singapore Digital Token Service Provider (DTSP) License. Our team ensures full compliance with the MAS and DTSP regulatory framework. This is why our global clients choose us: 

• Regulatory feasibility evaluation– Our team evaluates whether the proposed activities fall within the MAS licensing requirements 

• Preparation of completed licensing documents– Our team prepares all the documents that are needed by the MAS. This includes business plan, risk management frameworks, internal control, and AML/CFT policies 

• Post-licensing support- Our team provides post-licensing support, which includes assistance with opening corporate bank accounts and ongoing compliance advisory 

• End-to-end services- From company incorporation to post-license compliance obligations, our team helps you at every step 

Looking to obtain Singapore Digital Token Service Provider (DTSP) License

• If you are looking to get a Singapore Digital Token Service Provider (DTSP) License, then it is necessary to work with a regulatory advisor who will understand both the commercial realities of the digital asset business and the strict expectations of the MAS. The licensing framework is created to give this license to only well-governed, well-capitalized, and compliant entities, which makes the need for professional support even more significant. At Tetra Consultants, we offer end-to-end support to help you get this license, from evaluating business feasibility and company set-up to regulatory engagement and post-license compliance. Our team helps your business to secure this license effectively while also creating a strong foundation for long-term success and sustainable operations in Singapore.  

• Contact us, and our team will get back to you within 24 hours.  

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