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MAS Notice FSM-N33 — Disclosures and Communications

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Notice Overview

  • Notice ID: FSM-N33
  • Full Title: Notice on Disclosures and Communications (Notice to licensed digital token service providers)
  • Issuing Authority: Monetary Authority of Singapore
  • Issued under: Section 166(1) of the Financial Services and Markets Act 2022 (FSM Act)
  • Published: 30 May 2025
  • Effective Date: 30 June 2025
  • Applies to: Holders of a licence granted under section 138 of the FSM Act (Digital Token Service Licence)

Purpose

MAS Notice FSM-N33 sets out requirements for licensed DTSPs to provide certain disclosures to customers and potential customers, and to accurately represent the scope of their regulation to the public. The notice aims to ensure consumers understand the risks of digital token services and that DTSPs do not make misleading claims about their regulatory status.

Key Requirements (Reconstructed from WebSearch — includes verbatim content)

1. Risk Warning Statement

  • A licensee must provide all customers and potential customers with the risk warning statement set out in Annex A of the Notice
  • The warning must be provided in the manner specified in paragraph 5 of the Notice (visible risk disclosures required)

2. Accurate Representation of Regulatory Scope

  • DTSPs must accurately represent the scope of regulation of the DTSP under the FSMA
  • Representations must not misrepresent the scope of activities that the DTSP is licensed to carry out

3. False or Misleading Statements

  • DTSPs must request correction of any false or misleading statement by a third party about the scope of their regulation, where MAS alerts the DTSP that such a statement has been made
  • Prohibition on misleading group-level claims (e.g., claiming broader regulatory coverage than what the licence grants)

4. Public Communications

  • Visible risk disclosures required in all customer-facing communications
  • All communications must comply with the disclosure standards in the Notice

Consultation Draft

The consultation draft was published as Annex J to the 2024 Consultation Paper: https://www.mas.gov.sg/-/media/mas-media-library/publications/consultations/amld/2024/annex-j---fsm-n33---notice-on-disclosures-and-communications.pdf

Regulatory Context

FSM-N33 is the seventh and final substantive conduct notice in the DTSP framework (FSM-N27 through FSM-N33, plus FSM-N34 for forms). It sits alongside FSM-N32 (Business Conduct) to complete the consumer protection requirements for the DTSP licensing regime.


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