THE PAYMENT SERVICES ACT – REQUIREMENT TO OBTAIN AN OPINION ON THE TOKENS YOUR PLATFORM SUPPORTS
Digital payment token (“DPT”) services (which consist of dealing in DPTs or facilitating the exchange of DPTs) are a newly regulated activity in Singapore. In Form 1, Question 7.20 requires (the “Assessment Requirement”) each applicant conducting DPT services to: “provide a list of all tokens supported and indicate the applicant’s assessment of the nature of the token. Attach a legal opinion of the applicant’s assessment”.
The legal opinion is required to include an opinion (the “Assessment”) on whether the token constitutes (1) a DPT and/or (2) a capital markets product under the Securities and Futures Act (the “SFA”). Tokens that do not constitute a DPT or a capital markets product may constitute “e-money” under the PS Act.
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