Introduction
Navigating the regulatory landscape for digital assets requires a proactive, governance-led stance. The Payment Services Act establishes the licensing framework for digital payment services, and the regulatory perimeter continues to expand to capture transfer, arranging and custody-style activities wherever control over assets exists. Alongside licensing, anti-money laundering and countering the financing of terrorism (AML/CFT) remains a continuous area of supervisory focus.
We support payment institutions, fintechs, and digital asset service providers across the licensing lifecycle, from regulatory assessments and licence applications to establishing governance, risk and control frameworks, including AML/CFT, that support a credible and sustainable licence to operate.
Our solutions
How we help
- Post-Licensing Supervisory Readiness: Support for licensed Digital Payment Token (DPT) firms to maintain ongoing compliance with MAS. Assessment of supervisory readiness across governance, AML/CFT, outsourcing, and operational controls, identification of priority areas for attention, and preparation for supervisory engagements, inspections and periodic reviews.
- Initial Set-Up and Structuring Support: Advisory on structuring regulated entities and group arrangements, so you understand the initial and ongoing complexities of your business model from the outset.
- Licensing and MAS Regulatory Compliance: Advisory on licensing requirements under the Payment Services Act (PSA) for Digital Payment Token (DPT) service providers, readiness assessments, gap analyses and practical recommendations, and support for application materials and regulatory responses across Major Payment Institution (MPI) and Standard Payment Institution (SPI) applications.
- Governance, Risk, and Internal Controls (GRC): Advisory and establishment of governance frameworks for digital asset operations, enterprise risk assessments covering market, operational, legal, and compliance risks, and board training on digital asset risk oversight and governance duties.
- Documentation: Codification of internal policies, procedures, and risk management frameworks aligned with MAS PSA expectations, so your team can operate with clear guidance.
- Regulatory Monitoring and Reporting: Ongoing strategic, compliance, and operational support, including management of periodic regulatory returns, mandatory disclosures, and record-keeping obligations.
- AML/CFT Compliance: Development of AML/CFT policies and procedures, Customer Due Diligence (CDD) and Know Your Customer (KYC) frameworks, risk assessments tailored to digital asset exposure, staff training programmes, and advisory on suspicious transaction reporting (STR) and regulatory filings.
- Transaction Screening and Monitoring: Integration of blockchain analytics for automated wallet screening, transaction tracing, and ongoing AML/CFT monitoring across your financial ecosystem.
Learn more about our related Business Risk Consulting services.
Frequently Asked Questions
The first step is usually a regulatory perimeter assessment. This confirms whether your activities require a licence under the Payment Services Act and, if so, which licence class applies, giving you a clear starting point before you prepare an application or commit capital.
Yes. We help licensed firms maintain and strengthen their compliance frameworks over time, including AML/CFT, governance, regulatory reporting, and internal controls, so their governance and control environment continues to evolve alongside the business.
We tailor AML/CFT frameworks to your specific digital asset exposure, combining policy and procedure design, CDD and KYC frameworks, blockchain analytics for transaction monitoring, and staff training, so your controls are aligned with how your business operates, transacts and safeguards digital assets.
Timelines vary with your business model, structure, and level of readiness. We can help assess your current state against MAS expectations, identify priority gaps, and support the preparation of application materials, providing management with a clearer understanding of the work required before submission.
Yes. We support clients by helping to draft, review and refine clear, accurate, and well-substantiated responses to MAS queries. We help ensure responses and supporting materials are consistent, robust, and aligned to MAS expectations across governance, outsourcing, risk, and operational controls.
Yes. We help establish governance frameworks, define roles and accountability, and provide board training on digital asset risk oversight, supporting directors and senior management in fulfilling their governance responsibilities effectively.