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Money-Changer's Licence




Here's some key information:


What is it?


A Money-Changer's Licence is issued by the Monetary Authority of Singapore (MAS) and allows you to legally buy and sell foreign currency notes in Singapore. It's different from other payment service licences, like Standard Payment Institution (SPI) or Major Payment Institution (MPI) which cover broader services.


Who needs it?


If you plan to operate a physical or online money-changing business in Singapore, you'll need this licence. It doesn't cover other financial services like money transfers or e-wallets.


How to apply?


The application process involves submitting documents and adhering to the regulations set by the MAS. You can find details and the application form on their website:



Key things to know:


  • There are eligibility requirements for applicants, including minimum share capital and relevant experience.

  • You'll need to submit a business plan and comply with anti-money laundering and counter-terrorism measures.

  • The application process usually takes around 3 months.

  • There's a licence fee payable upon approval.


Eligibility Criteria


Only qualifying applicants are eligible for a money-changing licence. Meet the following criteria to be considered.


Entity Type

Governance or Ownership Requirements 

A sole proprietorship 

  • You must be a Singapore citizen.

  • You must have a minimum of 1 year's relevant working or business experience on a full-time basis.

A partnership or limited liability partnership (LLP) 

  • The majority of your partners should be Singapore citizens.

  • If there are only 2 partners, only one of them needs to be a Singapore citizen.

  • Each partner must have a minimum of 1 year's relevant working or business experience on a full-time basis.

Singapore-owned company 

  • More than 50% of the equity shareholdings should be beneficially owned and effectively controlled by Singapore citizens.

  • A majority of the board of directors of the company should be Singapore citizens.

  • If there are only 2 directors, only one of them needs to be a Singapore citizen.

  • Each executive director must have a minimum of 1 year's relevant working or business experience on a full-time basis.  

Singapore incorporated wholly-owned subsidiary of a foreign bank, or a foreign company primarily engaged in money-changing 

  • The parent company must:

  • Be of significant size.

  • Possess a good track record and reputation.

  • Be adequately regulated and supervised by its home supervisory authority for anti-money laundering/combating the financing of terrorism (AML/CFT).

  • (If the entity is a foreign bank) Rank among the top banks in the country where it is incorporated.  


Assessment Criteria


To grant a money-changing licence, MAS closely examines these key factors, among others:


Factor

What it Entails


  • (If the entity is a sole proprietorship) You must satisfy MAS that you are fit and proper.

  • (If the entity is a company, partnership or LLP) You must satisfy MAS that you, your partners, executive directors and Chief Executive Officer (CEO) are fit and proper.

Competency of key individuals 

You must ensure that the entity's sole proprietor, partners, or executive directors and CEO have:

  • sufficient experience in operating a money-changing business and in AML/CFT.

  • If there is a sizeable team to be managed, the management should also have the relevant experience, competencies and influence to exercise effective oversight and control over the business activities and staff.

  • the necessary educational qualifications and professional certification.

Permanent place of business or registered office

You must have a permanent place of business or a registered office where the books and records can be securely held.


At least one person must be appointed to be present at the place of business or a registered office to address any queries or complaints from consumers.

Compliance arrangements 

You must have in place plans for compliance arrangements that correspond with the business's nature, scale and complexity.


Make sure your compliance plan matches your business size and complexity. You can choose:

  • An independent compliance team in Singapore with qualified staff. (Note: Briefly mention potential dual roles like legal counsel if necessary.)

  • Compliance support from your parent company or a related entity overseas. (Explain oversight requirements and appointment of a local compliance officer.)

  • Whichever you choose, remember: you're ultimately responsible for compliance. Your directors and compliance officer must maintain close oversight.

Audit arrangements 

You must have in place plans for adequate independent audit arrangements that correspond with the nature, scale and complexity of the business. 

Annual audit requirements

You must have in place plans to meet the annual audit requirements as mentioned in Section 37 of the PS Act.  The auditor must be appointed at your own expense to audit the entity's accounts and transactions, and compliance with the relevant regulations and requirements. 

Letter of Responsibility and Letter of Undertaking 

MAS may require you to obtain a Letter of Responsibility or a Letter of Undertaking from the entity's majority shareholders, parent company and related company, where appropriate.



Apply for Money-Changer’s Licence


The application process for a Money-Changer's Licence in Singapore: 


Step 1: Determine Applicant Type


Are you applying individually as a sole proprietor, or on behalf of a company or corporation? This will determine the specific requirements and documents you need to submit.


Step 2: Gather Applicant Information


  • Individual: Provide your Singapore Citizen Identification Number (NRIC) and any relevant work experience in money-changing or remittance businesses.

  • Company: Submit the latest ACRA business profile and details of the directors/shareholders, including their NRICs and relevant work experience.


Step 3: Develop a Business Plan


  • Briefly outline your business plan, including:

  • Proposed location of your money-changing outlet

  • Target customers

  • Types of currencies offered

  • Planned business operations

  • Marketing and advertising strategies

  • Tip: Consider incorporating visuals like charts, graphs, or maps to enhance your plan's clarity and persuasiveness.


Step 4: Prepare Supporting Documents


Download the application form from the Monetary Authority of Singapore (MAS) website and gather the required supporting documents:


  • Completed application form

  • Proof of incorporation (for companies)

  • Educational certificates and CVs of key personnel

  • Last 3 years' audited financial statements (if applicable)

  • Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Policy & Procedures


Step 5: Submit Application


Once you have completed the application form and gathered all the necessary documents, you can submit your application to the MAS:


  • Online: Submit electronically through the MAS website.

  • Mail: Send by registered mail to the MAS address listed on the application form.


Applicants who have assessed that they are able to meet the admission criteria should refer to Appendix 3 for guidance on information required for submission of licence applications and submit an application in Form 1.


Guidance on Information required for Money-changing Service Licence Applications


The applicant should ensure that it fully meets the admission criteria, and has ensured that the application is complete, free of errors and inconsistencies, and accompanied by the requisite supporting documents stated in the application form. In particular, it should include the following information in its proposed business plan:


The applicant should provide a clear description of its business model and plans, which are supported by the professional experience and expertise of the proposed management team. The business plan should illustrate compliance with the PS Act and relevant subsidiary legislation, and include the information below:


• Jurisdictions serviced.


• Profile of target clientele.


• Proposed products and services. The applicant should indicate clearly its assessment of which payment services will be conducted at each stage of the transaction process. Where the applicant intends to provide more than one product or service, the applicant should provide a separate assessment for each product or service.


• Detailed funds flow plan and channels, including transaction and/or process flow diagrams. If there is more than one product or service, or more than one type of transaction and/or process flow, one diagram should be provided for each flow. The diagrams should:


o Describe the beginning to end of a typical transaction, starting from the sources of funds that the applicant will accept (e.g. bank transfers, cash, cards) until where the obligation to the customer is fully discharged.

o Illustrate both the interactions between the customer and the applicant and the flow of funds.

o Have timelines indicated, including service level agreements with third parties, and payment and settlement cycles, where applicable.

o Highlight where it uses innovative technology (e.g. use or offering of digital tokens, distributed ledger technology) or a different manner of delivering products or services from that commonly seen in the market.

o Include all third parties involved (e.g. other payment service providers, banking partners, intermediaries, other agents) and show their roles in the process.


• Implementation plans, including the anticipated timeline for launch, as well as systems, processes, and third parties that will perform a key role in its operations.


• Whether the payment services are incidental to, or bundled with, any other products or services offered by the applicant.


• Brief description of any other activities regulated by MAS that it conducts or intends to conduct e.g. financial advisory, dealing in securities etc.


• For applicants that are part of a global payment services group:


o Role of the applicant within the group, including the functions or services that it will receive and/or provide to related corporations within the group, if any.


o Confirmation that all its entities are adequately licensed/registered, with the licensing/registration details of each entity.


• The applicant should provide a list of the currencies that it will offer and the sources of the foreign currency notes. It should also explain how it derives the exchange rates offered.


Third parties


Where the applicant intends to engage any third parties, it should provide details on such third parties, including the name, jurisdictions that it operates in, and licensing/registration status. It should also set out its framework for assessing and maintaining oversight of third party relationships, including how it will comply with MAS Notices PSN01 and/or PSN02.


Technology risk management


The applicant should set out its framework for assessing and managing technology risks, and implement measures to protect customer data, transactions and systems that are commensurate with the level of risk and complexity of the financial services offered and the technologies supporting such services. The applicant should refer to the Technology Risk Management Guidelines for guidance on IT risk management principles and best practices.


Safeguarding


The applicant should provide details of the intended safeguarding arrangement, including name of safeguarding institution and draft contract if available, and systems and/or processes that will be used to comply with the timelines in section 23 of the PS Act. Where the applicant will be using more than one safeguarding measure and/or safeguarding institution, it should indicate the intended coverage of each safeguarding measure (e.g. by value at each safeguarding institution, or by each type of safeguarding measure). The applicant should also indicate in its business model description or the transaction and/or process flow diagram where it has assessed its safeguarding obligation to start and end.


If the application is approved, the applicant will be required to provide documentary evidence that the safeguarding arrangement is in place prior to commencing business. Applicants that choose to safeguard by undertaking or banker’s guarantee will also be required to provide a legal opinion that the arrangement fulfils the requirements in section 23 of the PS Act.


Compliance and audit


The applicant should provide the following information and documents that are in line with the nature of the proposed business model:


• AML/CFT policies and procedures that demonstrate compliance with MAS Notices PSN01 and/or PSN02. This should include the framework for assessing and maintaining oversight of agents.


• Enterprise-wide money-laundering/terrorism financing risk assessment.


• AML/CFT governance, escalation and reporting arrangements. This should include details of the involvement of the sole-proprietor, partners, or directors and CEO and other senior management in the oversight and resolution of AML/CFT issues that may arise in the course of the licensee’s business.


• Implementation plans of compliance management arrangements, including systems that will be used.


• Name and Curriculum Vitae (“CV”) of the compliance officer, including details of any formal compliance accreditation e.g. ACAMS, IBF accreditation. If there is/will be a separate AML/CFT compliance officer, name and CV of the AML/CFT compliance officer, including details of any formal AML/CFT accreditation.


• Staffing arrangements for the compliance function, if it is not already provided as part of the organisational chart. This should include details on all outsourced compliance functions, including where the outsourced provider and team is located, relationship between the applicant and the outsourced provider (e.g. vendor, parent company), licensing/registration status of the outsourced provider, and oversight arrangements.


• Internal and external audit arrangements.


Additional Tips:


Be prepared for the application process to take several months.


Application Fees


You are required to pay a non-refundable application fee. The amount of application fees you will have to pay depends on the payment services you are applying for. The application fees are, in summary:


  • For a money-changing licence, S$500.

  • For a standard payment institution, S$1,000 or the sum of the amounts below for the payment services applied for, whichever is higher.

  • For a major payment institution, S$1,500 or the sum of the amounts below for the payment services applied for, whichever is higher.


How Bestar can Help with your Money-Changer's Licence Application in Singapore


Expertise and Guidance:


  • Eligibility assessment: Bestar can assess your background, qualifications, and business plan to determine your eligibility for the licence.

  • Regulatory compliance: We have in-depth knowledge of the Monetary Authority of Singapore (MAS) regulations and can guide you through the application process, ensuring all requirements are met.

  • Business plan & financial projections: Bestar can help you develop a strong business plan with realistic financial projections, increasing your application's success rate.

  • Document preparation: We can assist in gathering and preparing all necessary documents, including application forms, financial statements, and AML/CFT policies.

  • Liaison with MAS: Bestar can act as your intermediary with the MAS, handling communication and addressing any queries or concerns they may have.


Additional Services:


  • Company incorporation: If applying through a company, Bestar can help with company registration and setup.

  • Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) training: We can provide training for your staff on AML/CFT procedures to comply with regulations.

  • Post-licence support: Bestar can offer ongoing support with compliance, accounting, and financial management once you obtain the licence.


Benefits of using Bestar:


  • Increased success rate: Our expertise can significantly increase your chances of getting the licence approved.

  • Time-saving: We can handle the complex application process, freeing up your time to focus on your business.

  • Reduced risk: Our guidance helps ensure you comply with all regulations, minimizing potential legal or financial risks.

  • Peace of mind: You can have confidence knowing your application is in good hands.


Remember, choosing the right professional can make a significant difference in the success of your application. Contact Bestar today!

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