Fintech Regulation in Singapore — What you need to know, simplified

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WanHsi Yeong

Yeong WanHsi practices at ArrowGates LLC. She has extensive corporate experience including multi-jurisdictional mergers and acquisitions, venture capital, initial public offerings, private equity investments, regulatory compliance, financial markets, corporate restructuring and general corporate work. Always seeking to be at the forefront of evolving markets, WanHsi has continually expanded her capabilities to cater to the emerging start-up and Fintech markets. WanHsi is also the founder and benefactor of the Love Changes Nations charity which has done voluntary work over the last 8 years in disaster stricken countries all over the world, including Philippines, Mozambique, Pakistan, Nepal, and Brazil.

Comments (6)
  1. Craig Broomfield says:

    You refer to there being no Digital Only Startup Banks such and Tandem and ATOM from the UK – who have secured licenses (somewhat due to the relaxed licensing provision for new banks in the UK)
    What about true Neo-Banks – operating with their own brand and offering but under the license (sponsorship) of an existing licensed bank (ie: Siimple, Moven, Number26, etc) – how does this operating model / construct fit in to the Singapore regulatory environment for would be Fintechs

  2. WanHsi Yeong says:

    Tandem and atom banks are considered to be neobanks. As an example of a fintech in the payment space, Fastacash (which does payments) teamed up with DBS. for their DBS PayLah app. Fastacash in itself is not licensed. Compare with MatchMove Pay which is also in the mobile payment space. But MatchMove Pay applied and was granted a remittance licence. It would depend on the business model of the Fintech as well.

  3. Siim says:

    I can’t seem to pinpoint where the “51% equity controlled by a Singaporean citizen” is from in the Act…?

  4. Terence Chia says:

    Hi WanHsi,

    few quick questions on CMS license for crowdfunding/crowdinvesting platform

    you stated – CEO or director must be Singaporean – this is mandatory ? if none of the founders are Singaporean, one Singaporean must be hired as CEO or director ?

    – At least 2 full-time employees for each regulated activity that the corporation is seeking licence for — if we are applying for the CMS license, we have to hire 2 full time employees for the sole purpose of compliance ?? it doesnt make any sense for a startup

    – Each of said employees to have a representative’s licence for activity — does it mean other than the company need a CMS license, said employees need a CMS license individually ?

    thank you

    1. WanHsi Yeong says:

      In relation to your queries:
      1. With regards to Directors, the company’s board of directors should comprise a minimum of 2 members, at least one of whom is a Singapore Resident. Further, the CEO has to be Singapore Resident as well. A Singapore Resident refers to a Singapore Citizen or a Singaporean Permanent Resident.
      2. Yes, you will require at least 2 full time employees in respect of each regulated activity for which the company is seeking to be licensed to conduct. It is one the requirements of the Monetary Authority of Singapore (“MAS”) for the grant of a Capital Market License (“CMS”).
      3. Yes, individuals will be required to acquire a CMS Representative’s License in order to act as a representative of the company (the CMS License holder) in conducting the regulated activities.

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