MAS Notice FSM-N32 — Notice on Conduct (Holders of Digital Token Service Licence)¶

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MAS Notice FSM-N32

30 May 2025

NOTICE TO LICENSED DIGITAL TOKEN SERVICE PROVIDERS FINANCIAL SERVICES AND MARKETS ACT 2022

NOTICE ON CONDUCT

Introduction¶

This Notice is issued under section 166(1) of the Financial Services and Markets Act 2022 (the "FSM Act") and applies to a holder of a licence granted under section 138 of the FSM Act ("licensee").
This Notice takes effect from 30 June 2025.

Definitions¶

For the purpose of this Notice –

"business day" means any calendar day other than a Saturday, Sunday, public holiday, or bank holiday;

"currency" means—

(a) currency notes and coins (whether of Singapore or a foreign country or territory) which are legal tender and circulate as money in the country or territory of issue; and

(b) any electronic form of currency;

"determined exchange rate" in Annexes A1 and B1 means –

(a) the exchange rate offered by the licensee to the customer for that transaction;

(b) where an exchange rate has not been offered by the licensee to the customer, the exchange rate as published by the licensee in the course of its business; or

(c) where an exchange rate has not been offered by the licensee to the customer, and the licensee does not publish any exchange rate in the course of its business, the exchange rate that is determined by the licensee to be the applicable exchange rate on the date the transaction is entered into.

Except where defined in this Notice or if the context otherwise requires, the expressions used in this Notice have the same meanings as in section 136(1) of the FSM Act.

PROVISIONS APPLICABLE TO LICENSEES¶

Record of Transactions¶

A licensee (other than a licensee that provides the service mentioned in paragraph (j) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act) must keep a record in the English language containing all the information set out in Annex A1, of all the licensee's transactions in respect of the digital token service the licensee is in the business of providing.
A licensee that provides the service mentioned in paragraph (j) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act must keep a record in the English language containing all the information set out in Annex A2.
The licensee must keep the records referred to in paragraphs 5 and 6 respectively for a period of at least five years.

Issuance of Receipts¶

A licensee (other than a licensee that provides the service mentioned in paragraph (j) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act) must issue a receipt containing the information set out in Annex B1 for every transaction it accepts, processes or executes to a customer—

(a) where the customer is an individual or sole-proprietor; and

(b) in all other cases, where the customer requests a receipt.

A licensee that provides the service mentioned in paragraph (j) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act must issue a receipt in paper or electronic form containing the information set out in Annex B2 to a customer –

(a) where the customer is an individual or sole-proprietor; and

(b) in all other cases, where the customer requests a receipt.

For the purpose of paragraph 8, "transaction it accepts, processes or executes" in respect of any digital token service means, every transaction by which the following are carried out when providing the service:

(a) a licensee purchases or sells digital token in exchange for any money or any other digital token (whether of the same or different type);

(b) digital token is purchased or sold in exchange for any money or any other digital token (whether of the same or different type), following an offer or invitation to buy or sell made on a digital token exchange established or operated by the licensee;

(c) a licensee accepts digital tokens from one digital token account for the purposes of transmitting, or arranging for the transmission of, the digital token to another digital token account;

(d) a licensee arranges for the transmission of digital tokens from one digital token account to another digital token account, for the purposes of providing the service;

(e) a licensee induces any person to enter into or to offer to enter into any agreement for or with a view to buying or selling any digital token in exchange for any money or any other digital token (whether of the same or different type);

(f) a licensee accepts a digital token for the purposes of safeguarding the digital token, or a digital token is withdrawn from such safeguarding, where the licensee has control over the digital token;

(g) a licensee accepts a digital token for the purposes of carrying out an instruction relating to a digital token, or a digital token is withdrawn from the licensee when the licensee ceases to carry out for a customer, instructions relating to the digital token, where the licensee has control over the digital token;

(h) a licensee accepts a digital token instrument for the purposes of safeguarding the digital token instrument or a digital token instrument is withdrawn from safeguarding by the licensee, where the licensee has control over one or more digital token associated with the digital token instrument; or

(i) a licensee accepts a digital token instrument for the purposes of carrying out an instruction relating to one or more digital tokens associated with the digital token instrument, or a digital token instrument is withdrawn from the licensee when the licensee ceases to carry out for a customer's instructions relating to one or more digital tokens associated with the digital token instrument, where the licensee has control over the digital token instrument.

For the purpose of paragraph 8 and 9—

(a) the receipt may be issued in paper or electronic form; and

(b) the receipt may be issued as a single receipt for each transaction accepted, processed or executed by the licensee or a consolidated receipt for all transactions accepted, processed or executed by the licensee over a period of not more than 90 days.

Display of Exchange Rate and Fees¶

A licensee must display prominently the following information such that a customer or potential customer would have notice of such information before using any digital token service provided by the licensee —

(a) the exchange rate (if any) which a licensee is offering or as published in the course of the licensee's business, in respect of any digital token service mentioned in paragraph (a), (b), (d) or (e) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule of the FSM Act; and

(b) any separate fee that a licensee will charge for the provision of the digital token service.

Where a licensee carrying on a business of providing digital token service mentioned in paragraphs (a), (b), (d) or (e) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule of the FSM Act does not offer or publish an exchange rate, the licensee must disclose in writing to the customer that the exchange rate will be as determined by the licensee to be the applicable exchange rate on the date the transaction is entered into.
The disclosures referred to in paragraphs 12 and 13 must –

(a) be published at least once in publicly available material issued by the licensee;

(b) be provided to a potential customer prior to the potential customer using the digital token service provided by the licensee;

(c) be provided at least once in writing to any customer where such a customer was not provided the statement in the manner set out in paragraph (b);

(d) not be obstructed or obscured, or embedded within other unrelated writing; and

(e) be of a reasonable size and typeface.

Notification of normal business hours¶

A licensee must notify all its customers and potential customers in writing of its normal business days and hours and any changes to its normal business days and hours by:

(a) publishing the notification in publicly available material; and

(b) displaying prominently the notification such that a customer or potential customer would have notice of such information prior to using the digital token service provided by the licensee.

Obligation of licensee to notify Authority of certain events¶

For the purpose of section 144(1)(f) of the FSM Act, a licensee must notify the Authority as soon as practicable after there is a change in any of the information provided by the licensee in Form 1 specified in Regulation 6 of the Financial Services and Markets Regulations 2024.

PROVISIONS APPLICABLE TO LICENSEES¶

Days and hours a place of business of a licensee must be manned¶

For the purpose of section 143(2) of the FSM Act, a licensee must appoint at least one person to be present at the licensee's permanent place of business for a minimum of 10 days a month and a minimum of eight hours on each of those days during its normal business hours, unless—

(a) the licensee has notified all its customers in writing and in advance of any planned non- operating days that will prevent the licensee from meeting the specified days and hours; or

(b) there are circumstances beyond the control of the licensee that could not reasonably have been foreseen by the licensee that prevent the licensee from meeting the specified days and hours.

The licensee must display prominently the notification in paragraph 17(a) such that the customer or potential customer would have notice of such information prior to using the digital token service provided by the licensee.

ANNEX A1 — PARTICULARS TO BE INCLUDED IN THE REGISTER¶

In respect of any transaction relating to the digital token service the licensee is in the business of providing, the following details:

(a) date of transaction;

(b) type of transaction – please select from the following[^1]:

(i) digital tokens bought or sold;

(ii) digital tokens which the licensee facilitated the exchange of;

(iii) digital tokens accepted from one digital token account, for the purposes of transmitting, or arranging for the transmission of, the digital tokens to another digital token account;

(iv) arrangement for the transmission of digital tokens from one digital token to another digital token account;

(v) inducing or attempting to induce a person to enter into or to offer to enter into any agreement for or with a view to buying or selling any digital tokens in exchange for any money or any other digital token (whether of the same or a different type)

(vi) safeguarding of digital tokens, where the licensee has control over the digital token;

(vii) carrying out for a customer an instruction relating to a digital token, where the licensee has control over the digital token;

(viii) safeguarding of digital token instruments, where the licensee has control over one or more digital tokens associated with the digital token instrument;

(ix) carrying out for a customer an instruction relating to one or more digital tokens associated with a digital token instrument, where the licensee has control over the digital token instrument.

[^1]: Where a licensee provides more than one digital token service, the licensee should record each transaction under the relevant sub-paragraph of paragraph 6. For example, where a licensee provides the service of dealing in digital tokens and the service of safeguarding digital tokens, it should record transactions relating to dealing in digital tokens under paragraph 6(i) and transactions relating to safeguarding digital tokens under paragraph 6(iv).

(c) where the licensee is providing the digital token service described in paragraph (a) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act —

(i) total amount of money or digital tokens accepted by the licensee and where the licensee did not accept money denominated in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent, with a breakdown of the following:

A. amount of money or digital tokens received by the counterparty to the digital token purchase or sale, as the case may be (referred to as a "counterparty" for the purposes of this paragraph), in the currency or type of digital tokens received by the counterparty, and the determined exchange rate applied to convert the currency or type of digital tokens accepted by the licensee to the currency or type of digital tokens received by the counterparty;

B. amount of commission and other service charges in Singapore dollars, if any, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars determined based on the determined exchange rate;

(ii) date of receipt of money or digital tokens by the counterparty;

(d) where the licensee is providing the digital token service described in paragraph (b) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act --

(i) total amount of money or digital tokens accepted by the licensee and where the licensee did not accept money denominated in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent, with a breakdown of the following:

A. amount of money or digital tokens received by the counterparty to a digital tokens purchase or sale, as the case may be (referred to as a "counterparty" for the purposes of this paragraph), in the currency or type of digital tokens received by the counterparty, and the determined exchange rate applied to convert the currency or type of digital tokens accepted by the licensee to the currency or type of digital tokens received by the counterparty;

B. amount of commission and other service charges in Singapore dollars, if any, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars determined based on the determined exchange rate;

(ii) date of receipt of money or digital tokens by the counterparty;

(e) where the licensee is providing the digital token service described in paragraph (c) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act --

(i) total amount of money or digital tokens accepted by the licensee and the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent, with a breakdown of the following:

A. amount of digital tokens received in the digital token account to which digital tokens were transmitted;

B. amount of commission and other service charges, in Singapore dollars, if any, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars determined based on the determined exchange rate;

(ii) date of receipt of money or digital tokens in the counterparty account;

(f) where the licensee is providing the digital token service described in paragraph (d) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act --

(i) total amount of money or digital tokens that the licensee arranged for the transmission of, the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent, with a breakdown of the following:

A. amount of digital tokens received in the digital token account to which digital tokens were transmitted (referred to as a "counterparty account" for the purposes of this paragraph), and the determined exchange rate applied to convert the type of digital tokens that the licensee arranges for the transmission of, as the case may be, to the type of digital tokens received in the counterparty account, where the type of digital tokens that the licensee arranges for the transmission of is not the same as the type of digital tokens received in the counterparty account;

B. amount of commission and other service charges, in Singapore dollars, if any, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars determined based on the determined exchange rate;

(ii) date of receipt of money or digital tokens in the counterparty account;

(g) where the licensee is providing the digital token service described in paragraph (e) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act --

(i) total amount of digital tokens that the licensee arranged to be purchased or sold in exchange for any money or other digital tokens (whether of the same or of a different type), the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent, with a breakdown of the following:

A. amount of digital tokens or money received by the counterparty to a digital tokens purchase or sale, as the case may be (referred to as a "counterparty" for the purposes of this paragraph), in the currency or type of digital tokens received by the counterparty, and the determined exchange rate applied to convert the type of currency or digital tokens accepted to the type of digital tokens or currency transferred to the counterparty;

B. amount of commission and other service charges in Singapore dollars, if any, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars determined based on the determined exchange rate;

(ii) date of receipt of money or digital tokens by the counterparty.

(h) where the licensee is providing the digital token service described in paragraph (f) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act --

(i) total amount of digital tokens accepted for the purposes of safeguarding, the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent;

(ii) total amount of digital tokens withdrawn from safeguarding, the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent;

(iii) amount of commission and other service charges received by the licensee in Singapore dollars, if any, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars determined based on the determined exchange rate;

(iv) date of receipt of digital tokens by the intended recipient of digital tokens, where digital tokens are withdrawn from safeguarding;

(i) where the licensee is providing the digital token service described in paragraph (g) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act --

(i) total amount of digital tokens accepted for the purposes of carrying out for a customer's instructions relating to the digital tokens, the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent;

(ii) total amount of digital tokens withdrawn from the licensee, when the licensee ceases the carrying out of instructions relating to the digital tokens for a customer, the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent;

(iii) amount of commission and other service charges received by the licensee in Singapore dollars, if any, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars determined based on the determined exchange rate;

(iv) date of receipt of digital tokens by the intended recipient of digital tokens, where digital tokens are withdrawn from the licensee;

(j) where the licensee is providing the digital token service described in paragraph (h) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act --

(i) the digital token instrument accepted for the purposes of safeguarding, the total amount of the digital tokens associated with the digital token instrument accepted for safeguarding and the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent;

(ii) the digital token instrument withdrawn from safeguarding, the total amount of digital tokens associated with the digital token instrument withdrawn from safeguarding and the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent;

(iii) total amount of commission and other service charges received by the licensee in Singapore dollars, if any, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars determined based on the determined exchange rate;

(iv) date of receipt of the digital token instrument by the intended recipient of the digital token instrument, where the digital token instrument is withdrawn from safeguarding;

(k) where the licensee is providing the digital token service described in paragraph (i) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act --

(i) if a digital token instrument is accepted for the purposes of carrying out for a customer an instruction relating to one or more digital tokens associated with the digital token instrument, the total amount of the digital tokens associated with the digital token instrument accepted and the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent;

(ii) if a digital token instrument is withdrawn from the licensee, when the licensee ceases the carrying out of instructions relating to one or more digital tokens associated with the digital token instrument for a customer, the total amount of digital tokens associated with the digital token instrument withdrawn, the equivalent amount in Singapore dollars, and the determined exchange rate applied to determine the Singapore dollar equivalent;

(iii) total amount of commission and other service charges received by the licensee in Singapore dollars, if any, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars determined based on the determined exchange rate;

(iv) date of receipt of the digital token instrument by the intended recipient of the digital token instrument, where the digital token instrument is withdrawn from the licensee.

ANNEX A2 — PARTICULARS TO BE INCLUDED IN THE REGISTER¶

Where a licensee is in the business of providing the service mentioned in paragraph (j) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the following details:

(a) date(s) on which the service was provided by the licensee;

(b) type of service – sale or offer for sale of digital tokens which involves —

(i) providing advice, either directly or through publications or writings, and whether in electronic, print or other form, relating to any digital tokens; or

(ii) providing advice by issuing or promulgating research analyses or research reports, whether in electronic, print or other form, relating to any digital tokens;

(c) total amount of commission and other service charges in Singapore dollars, if any, accepted by the licensee for the purposes of providing advice[^2], relating to the sale or offer for sale of digital tokens, and where the licensee did not accept commission and other service charges in Singapore dollars, or accepted digital tokens, the equivalent amount in Singapore dollars based on the exchange rate that is determined by the licensee to be the applicable exchange rate; and

(d) date of receipt of money or digital tokens.

[^2]: The advice may be provided i) either directly or through publications or writings, and whether in electronic, print or other form, relating to any digital tokens or ii) by issuing or promulgating research analyses or research reports, whether in electronic, print or other form, relating to any digital tokens.

ANNEX B1 — INFORMATION TO BE SET OUT IN RECEIPTS TO CUSTOMERS¶

In respect of any transaction a licensee accepts, processes or executes for a customer, the following details:

(a) name of licensee;

(b) contact details of the licensee including address, telephone number and email address;

(c) date of transaction;

(d) in the case where the digital token service being provided is the digital token service mentioned in paragraph (a) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act — the total amount of money or digital tokens accepted by the licensee, in the currency or type of digital tokens accepted by the licensee, the amount of money or digital tokens received by the counterparty to the digital tokens purchase or sale (referred to as a "counterparty"), in the currency or type of digital tokens received by the counterparty, and the determined exchange rate applied to convert the currency or type of digital tokens accepted by the licensee, to the currency or type of digital tokens received by the counterparty to the digital tokens purchase or sale;

(e) in the case where the digital token service being provided is the digital token service mentioned in paragraph (b) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the total amount of money or digital tokens accepted by the licensee, in the currency or type of digital tokens accepted by the licensee, the amount of money or digital tokens received by the counterparty to the purchase or sale of digital tokens (referred to as a "counterparty"), in the currency or type of digital tokens received by the counterparty, and the determined exchange rate applied to convert the currency or type of digital tokens accepted by the licensee to the currency or type of digital tokens received by the counterparty to the digital tokens purchase or sale;

(f) in the case where the digital token service being provided is the digital token service mentioned in paragraph (c) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the total amount of digital tokens accepted by the licensee, the amount of digital tokens received in the digital token account to which the digital tokens were transmitted (referred to as a "counterparty account"), in the type of digital tokens received in the counterparty account;

(g) in the case where the digital token service being provided is the digital token service mentioned in paragraph (d) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the total amount of digital tokens that the licensee arranges for the transmission of in the type of digital tokens that the licensee arranges for the transmission of, the total amount of digital tokens received in the digital token account to which the digital tokens were transmitted (referred to as a "counterparty account"), in the type of digital tokens received in the counterparty account, and the determined exchange rate applied to convert the type of digital tokens that the licensee arranges for the transmission of to the type of digital tokens received in the counterparty account;

(h) in the case where the digital token service being provided is the digital token service mentioned in paragraph (e) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the total amount of digital tokens that the licensee arranged to be purchased or sold in exchange for any money or other digital tokens (whether of the same or of a different type), the amount of money or digital tokens received by the counterparty to the purchase or sale of digital tokens (referred to as a "counterparty"), in the currency or type of digital tokens received by the counterparty, and the determined exchange rate applied to convert the currency or type of digital tokens accepted to the currency or type of digital tokens received by the counterparty;

(i) in the case where the digital token service being provided is the digital token service mentioned in paragraph (f) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the total amount of digital tokens accepted by the licensee or total amount of digital tokens withdrawn from safeguarding;

(j) in the case where the digital token service being provided is the digital token service mentioned in paragraph (g) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the total amount of digital tokens accepted by the licensee or total amount of digital tokens withdrawn from the licensee;

(k) in the case where the digital token service being provided is the digital token service mentioned in paragraph (h) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the digital token instruments accepted by the licensee or the digital token instruments withdrawn from safeguarding;

(l) in the case where the digital token service being provided is the digital token service mentioned in paragraph (i) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the digital token instrument accepted by the licensee or the digital token instrument withdrawn from the licensee;

(m) amount of commission and other service charges, if any;

(n) transaction reference number, or where no transaction reference number is available, all of the following information —

(i) name of customer and contact details of the customer including address, telephone number and email address; and

(ii) name of payee and contact details of the payee including address, telephone number and email address.

ANNEX B2 — INFORMATION TO BE SET OUT IN RECEIPTS TO CUSTOMERS¶

Where a license is in the business of providing the service mentioned in paragraph (j) of the definition of "digital token service" in paragraph 1 of Part 1 of the First Schedule to the FSM Act, the following details:

(a) name of licensee;

(b) contact details of the licensee including address, telephone number and email address;

(c) date(s) on which the service was provided by the licensee;

(d) amount of commission and other service charges, if any;

(e) receipt reference number, or where no receipt reference number is available, all of the following information —

(i) name of customer and contact details of the customer including address, telephone number and email address; and

(ii) name of payee and contact details of the payee including address, telephone number and email address.

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