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Stablecoins

Singapore MAS Stablecoin Framework

Singapore MAS Stablecoin Framework

What does the Singapore MAS stablecoin framework mandate?

Singapore’s Monetary Authority (MAS) stablecoin framework sets legally binding rules for single-currency stablecoins pegged to SGD or G10 currencies. It covers licensing, 100 % reserve backing, segregated custody, monthly attestations, par-value redemption within five days, AML/CFT compliance, and strict marketing controls.

The MAS stablecoin framework regulates single-currency stablecoins pegged to SGD or G10 currencies issued in Singapore. Issuers, especially non-banks above a circulation threshold, face requirements for licensing, reserve management, audits, and redemption rights.

  • Maintain reserve assets at 100 % of outstanding stablecoins.
  • Hold reserve assets in segregated accounts.
  • Obtain monthly independent attestation of reserve assets.
  • Publish monthly reserve attestations publicly.
  • Issue stablecoins exclusively from Singapore.
  • Provide holders a legal right to redeem at par value.
  • Comply with AML/CFT standards including the travel rule.
  • Publish a white paper disclosing key information.

What entity types can issue Stablecoins (Asset-Referenced Tokens) under the Singapore MAS Stablecoin Framework?

Both banks and non-bank entities can issue stablecoins under the Singapore MAS framework, subject to specific conditions and licensing requirements for non-banks.

  • Require non-banks to obtain a Major Payment Institution licence for Stablecoin Issuance Service if circulation exceeds S$5 million for recognition.
  • Permit banks to issue SCS meeting framework standards.
  • Exclude tokenised bank liabilities from the SCS framework.

What are the Exchange Listing Conditions and Requirements for stablecoins under Singapore MAS?

Entities listing MAS-regulated single-currency stablecoins must be licensed as Digital Payment Token service providers. Exchanges cannot use the “MAS-regulated stablecoin” label unless tokens meet the SCS framework criteria.

  • Be licensed as a Digital Payment Token service provider under the PS Act.
  • Prohibit using the label “MAS-regulated stablecoin” on tokens not meeting the SCS framework.

What Supervisory Intervention Powers and Authority Does MAS Hold Over Stablecoins in Singapore?

MAS holds broad powers to regulate stablecoins, including restricting business, requiring Singapore operations, ordering reserve liquidation during stress, and penalising false use of regulated terms.

  • Prohibit misuse of the “MAS-regulated stablecoin” term.
  • Order liquidation of reserves during market stress.
  • Prohibit initial multi-jurisdictional issuance.
  • Require issuers to operate exclusively from Singapore.
  • Impose business restrictions on issuers.
  • Prohibit issuers from offering non-issuance services.
  • Prohibit issuers from holding stakes in other entities.

What local presence or physical requirements apply to stablecoin issuers under the Singapore MAS stablecoin framework?

Stablecoins must be issued exclusively from Singapore to be recognised under the MAS regulatory framework. This framework covers single-currency stablecoins pegged to the Singapore dollar or G10 currencies. Multi-jurisdictional issuance is not permitted initially.

What are the Whitepaper and Prospectus Requirements for Stablecoins under Singapore MAS?

Under Singapore MAS regulations, issuers of MAS-regulated stablecoins are required to publish a white paper. This document serves to disclose key information to potential users.

  • Publish a white paper disclosing required details on issuer, operations, risks, and rights.

What are the requirements for Tokenized Asset Reserve Segregation and Custody under Singapore’s MAS stablecoin framework?

Singapore’s MAS framework requires stablecoin reserve assets to be held in segregated accounts, separate from other assets. These reserves must be held by permitted custodians licensed in Singapore or qualifying overseas custodians.

  • Hold stablecoin reserve assets in segregated accounts.
  • Separate reserve assets from the issuer’s non-reserve assets.
  • Maintain reserve assets held on trust.
  • Hold reserves with permitted custodians.
  • Use MAS-licensed financial institutions for custody in Singapore.
  • Use qualifying overseas custodians with A- rating and an MAS branch.

What custody and asset segregation requirements apply to stablecoin intermediaries under MAS regulations?

Intermediaries handling MAS-regulated stablecoins (SCS) must segregate customer SCS from their own assets, aligning with upcoming rules for Digital Payment Token (DPT) providers. They are not required to segregate customer SCS from other customer DPTs. Intermediaries may commingle customer SCS and DPTs in a pool separate from their own assets, provided they disclose associated risks and mitigation measures to customers.

What Attestation and Audit Frequency Requirements Apply to Stablecoins Under Singapore MAS?

Singapore MAS requires monthly independent attestation of stablecoin reserve assets, published and submitted. Annual audits are also mandated for recovery/wind-down plans and overall compliance reports.

  • Require monthly independent attestation of reserve assets.
  • Publish monthly reserve asset attestations online.
  • Submit monthly reserve asset attestations to MAS.
  • Subject recovery/wind-down assessments to annual independent audits.
  • Submit an annual audit report to MAS.

What Usage-caps-or-systemic-risk-triggers apply under Singapore MAS stablecoin regulations?

The MAS framework for stablecoins includes thresholds for non-bank issuers. Systemic stablecoin arrangements will face higher regulatory standards. Non-bank issuers below S$5 million circulation are exempt from specific stablecoin requirements.

  • MAS exempts non-bank issuers with circulation ≤ S$5 million from SCS requirements.
  • Issuers exceeding the S$5 million threshold can apply for an MPI licence.
  • Systemic stablecoin arrangements may be designated under relevant acts.
  • Designated systemic arrangements will face higher standards.
  • MAS will regulate systemic arrangements to mitigate risks.
  • Specific requirements for systemic arrangements will be developed.

What are the Issuer AML/KYC obligations for stablecoin issuers under the Singapore MAS Stablecoin Framework?

Issuers of stablecoins regulated by MAS must comply with Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) requirements. These standards mirror those for Digital Payment Token service providers and banks.

  • Conduct customer due diligence.
  • Comply with the travel rule.
  • Perform necessary screening.

What is the Stablecoin scope under Singapore MAS’s Response to Public Consultation on Stablecoin related Activities?

The MAS framework for stablecoins applies only to single-currency stablecoins pegged to the Singapore Dollar or G10 currencies issued in Singapore. Other stablecoins are regulated under the existing Digital Payment Token framework.

  • Target single-currency stablecoins (SCS) pegged to SGD or G10 currencies.
  • Require SCS to be issued solely within Singapore.
  • Regulate other stablecoins under existing Digital Payment Token (DPT) rules.
  • Exclude tokenised bank liabilities from SCS framework scope.
  • Ensure reserve assets are denominated in the stablecoin’s pegged currency.
  • Note G10 currencies include AUD, GBP, CAD, EUR, JPY, NZD, NOK, SEK, CHF, USD.

What capital and solvency buffer rules apply to stablecoin issuers under Singapore MAS?

Under Singapore MAS rules, non-bank stablecoin issuers must meet specific capital and liquid asset requirements. These rules aim to ensure financial stability and orderly wind-down capability. Banks and non-bank issuers with stablecoin circulation below S$5 million are generally exempt.

What are the Redemption Rights/Deadlines for MAS-Regulated Stablecoins in Singapore?

Holders of MAS-regulated stablecoins in Singapore have a legal right to redeem them at par value. Issuers must process legitimate redemption requests within five business days, except in exceptional circumstances.

  • Provide holders a direct legal claim to redeem at par value.
  • Process legitimate redemption requests within five business days.
  • Process redemptions directly with the issuer within this timeframe.
  • Ensure redemption conditions are reasonable and clearly disclosed.
  • Include details on redemption rights and obligations in the white paper.
  • Redeem timely and without undue delay under normal conditions.
  • Note that MAS may direct reserve liquidation in exceptional circumstances.

What Travel Rule Coverage is Required for Stablecoin Transfers under the Singapore MAS Stablecoin Response?

Issuers of MAS-regulated stablecoins must follow existing AML/CFT standards for transfers. These requirements include the travel rule, customer due diligence, and screening.

  • Adhere to existing AML/CFT standards.
  • Implement the travel rule.
  • Conduct customer due diligence.
  • Perform customer and transaction screening.

What are the rules for Permissionless transfer allowed or peer-to-peer transfers for Stablecoins under Singapore MAS regulation?

MAS-regulated Single-Currency Stablecoins (SCS) can be transferred on a variety of blockchain infrastructures, including decentralised public blockchains that support peer-to-peer transfers. The regulatory framework does not mandate the use of closed or permissioned ledgers. Issuers must disclose the technology used.

  • Allow transfers on various types of blockchain infrastructure.
  • Utilise decentralised public blockchains supporting peer-to-peer transfers.
  • Publish details of the technology adopted in a white paper.

What are the Reserve-ratio and eligible-asset-mix requirements under the Singapore MAS framework for stablecoins?

Singapore MAS requires stablecoin issuers to maintain a low-risk reserve portfolio with a value always at least 100 % of outstanding stablecoins. Reserve assets must be highly liquid, match the pegged currency, and be valued daily using mark-to-market.

  • Maintain reserve value at least 100 % of stablecoins.
  • Maintain a portfolio of very low-risk reserve assets.
  • Implement a robust risk management policy for assets.
  • Demonstrate reserve buffer methodology to MAS.
  • Denominate reserve assets in the stablecoin’s pegged currency.
  • Hold eligible assets: cash, equivalents, or short-term AA- rated debt.
  • Value reserve assets daily using mark-to-market.

What are the Public-reserve-composition-disclosure and transparency requirements for stablecoins under Singapore MAS?

MAS requires issuers of regulated stablecoins to ensure transparency regarding their reserve assets. This involves monthly independent attestations of reserves and public disclosure on the issuer’s website. Issuers must also detail their reserve composition policy in a white paper.

  • Obtain monthly independent attestations of reserve assets.
  • Publish monthly reserve attestations on the issuer’s website.
  • Submit monthly reserve attestations to MAS.
  • Publish a white paper detailing stablecoin operations.
  • Disclose reserve asset composition policy in the white paper.

What are the Holder Identity Requirement and AML/CFT Obligations for Stablecoins under Singapore MAS Regulation?

Issuers and service providers handling MAS-regulated stablecoins must follow existing Anti-Money Laundering and Countering the Financing of Terrorism rules. This ensures proper checks are done on users and transactions.

  • Adhere to existing AML/CFT standards.
  • Perform customer due diligence.
  • Comply with the travel rule.
  • Conduct screening.

What rules govern stablecoin retail availability and public access under Singapore MAS?

Singapore’s approach generally permits stablecoins, including MAS-regulated ones, for retail users. Non-SCS stablecoins fall under the existing DPT regime. MAS-regulated stablecoins are designed for public access, and holders have redemption rights.

  • Allow stablecoins outside the SCS framework subject to the DPT regime.
  • Design MAS-regulated stablecoins for public interaction.
  • Redeem at par value for holders/users within five business days.

What are the Licensing and Supervisory Authority requirements for stablecoins under Singapore MAS Regulations?

The Monetary Authority of Singapore (MAS) is the primary licensing and supervisory authority for stablecoin activities. MAS establishes the regulatory framework, defines regulated services like “Stablecoin Issuance Service,” and requires applicable issuers to obtain a Major Payment Institution licence.

  • Apply to MAS for a Major Payment Institution licence for stablecoin issuance.
  • Demonstrate processes for maintaining reserve asset valuation to MAS.
  • Meet MAS conditions for custodians of reserve assets.
  • Submit monthly independent attestation reports on reserves to MAS.
  • Operate solely from Singapore to be recognised as an MAS-regulated stablecoin.
  • Be subject to MAS’s power to direct liquidation of reserve assets.
  • Adhere to MAS’s regulation of systemic stablecoin arrangements.

What are the Failure/Resolution Regime and wind-down requirements for stablecoins under Singapore MAS?

Singapore’s MAS requires stablecoin issuers to maintain segregated reserve assets and hold liquid funds sufficient for recovery or orderly wind-down. These measures aim to protect stablecoin holders and facilitate failure management. Stablecoins are not covered by deposit insurance.

  • Maintain reserve assets in segregated accounts.
  • Ensure reserve assets are custodied with permitted financial institutions.
  • Maintain liquid assets for solvency based on operating expenses or wind-down needs.
  • Assess necessary liquid assets for recovery or orderly wind-down annually.
  • Ensure liquid asset assessment is independently audited at least annually.
  • Liquidate reserve assets upon MAS instruction under exceptional conditions.
  • Note that MAS-regulated stablecoins are not covered by the Deposit Insurance Scheme.

What are the idiosyncratic details and notes for stablecoins under the Singapore MAS Framework?

The Singapore MAS stablecoin framework has specific details. It covers only single-currency stablecoins pegged to SGD or G10 currencies. It excludes tokenised bank liabilities but allows voluntary compliance for small non-bank issuers. Only compliant stablecoins can be labelled “MAS-regulated”.

  • Limit issuance to single-currency stablecoins pegged to SGD or G10 currencies.
  • Label stablecoins as “MAS-regulated” only if compliant with the framework.
  • Custody reserve assets with A-rated overseas custodians having a Singapore branch, if applicable.
  • Subject liquid asset assessments for recovery/wind-down to annual independent audits.
  • Issue stablecoins solely out of Singapore initially.
  • Refrain from offering services like staking or lending alongside stablecoin issuance.
  • Acknowledge MAS-regulated stablecoins are not covered by deposit insurance.

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