Payment Services Act - draft AML Notices published for consultation

The Payment Services Act (“PS Act”) was passed by the Singapore Parliament on 14 January 2019 and, since that date, the MAS has issued three consultation papers on subsidiary legislation and regulatory instruments (the most recent of which was issued on 5 July 2019). In this client alert, we are focusing on the consultations, published on 6 June, that seek feedback on two draft Notices that will impose anti-money laundering and countering the financing of terrorism (“AML/CFT”) obligations on PS Act licensees (the “AML Notices”).

The AML Notices consist of: 

  • AML Notice applicable to specified payment services (the “SPS Notice”); and
  • AML Notice applicable to digital payment token (“DPT”) services (the “DPT Notice”). Certain features of the DPT Notice are unique, due to the unique characteristics of digital payment tokens, and the recommendations made by the Financial Action Task Force (“FATF”) in its Guidance on Virtual Assets and Virtual Asset Service Providers (“VASPs”) (the “FATF Guidance”) that was published publicly on 21 June 2019, which the MAS has broadly applied, with certain adjustments where it deems appropriate.   

In this client alert, we will provide a brief overview of the AML Notices, and highlight the key issues in connection with them.