Obtain an Electronic Money Institution (EMI) License in Singapore | Law&Trust International

Singapore: EMI license

Electronic money (e-money) institution (or EMI) is a licensed financial institution which engages in e-money related and payment services (as would be described in details in this article). The full license for e-money is not restricted to either time or area of activities.

Law and Trust International proposes obtaining an e-money service license in Singapore. It is a simple process; you will need to meet the requirements set out by Monetary Authority of Singapore (MAS). It is important to note that the Singaporean authorities make revisions to their regulations in respective of e-money issuers, MAS have yet to publish a timeline for the implementation of these changes. However, it is important that your business prepare and attend the initial pre-engagement meeting with MAS.

We provide complete support throughout your application to the MAS. The documentation processes from the project could be used as a basis for your application to the MAS should this is required, in order to reduce the cost of project.

Details of obtaining a license for electronic money Singapore.
Details of obtaining a license for electronic money Singapore.

Advantages of obtaining a license for e-money in Singapore

This financial structure provides solutions to current world economic situations for large transactional business - banking services and international transfers (especially in USD currency).

Certain distinguishing features of this financial structure includes

  • Remote (via the Internet) account openings, both for individuals and legal entities;
  • Issuance of Visa or MasterCard linked to the customer's account;
  • Authorized payments to banks around the world in USD/EUR/GBP and other currencies;
  • The ability to accept payments from any international account in the SWIFT;
  • Independent decision-making on payments and account opening;
  • Possibility of opening correspondent accounts around the world.

Allowed Activities with e-money license in Singapore

  • Services enabling cash to be deposited or withdrawn into a payment account for operations, which are required for operating a payment account;
  • Completion of payment transactions, including transfers of funds on a payment account with the user’s payment service provider;
  • Direct debits, including one-off direct debits;
  • Payment transactions through a payment card or a similar device;
  • Credit transfers, including standing orders;
  • Completion of payment transactions where the funds are covered by a credit line for a payment service user;
  • Issuing of payment instruments and/or acquiring of transactions’ payment;
  • The remittance of money;
  • Payment initiation and account information services;
  • Provision of operational services, which are related to ancillary services involved in the issuing or provision of e-money;
  • Operation of payment systems;
  • Business activities with electronic money conforming to the current local and international law, etc.

Licensing of electronic money institution in Singapore: Requirements

Licensing process involves a lot of requirements for approval, despite the fact, the process is straightforward in Hong Kong with regards to EMI activities.

At the initial stage, the future owner of the EMI license should:

  • Be at least 18 years old;
  • An initial capital of not less than 260 000 (two hundred and sixty thousand) US dollars for the EMI license type;
  • To have the reliable documents confirming the level of income (tax declaration or certificate from tax control authorities);
  • Do not have restrictions or prohibitions from the Singapore officials;
  • Acquisition (or long-term lease) of real estate (building or office) for the company.

Other tasks relating to the licensing of e-money institution which may require additional time include

  • Preparation of business model and business plan;
  • Corporate structure, Corporate management and Reporting arrangements;
  • Compliance, risk and anti-financial crime framework;
  • Filling in the management positions (certain qualification and experience requirements are applicable);
  • Background of any Directors and anyone who will be responsible for the management of the provision of e-money and SVF services;
  • Preparing description of IT system (and other planned technical solutions);
  • Preparing the accountancy system description;
  • Contracting the counterparties (e.g. auditing company).

Documents for licensing electronic money services in Singapore

Main list of documents to be submitted alongside the application includes

  • Articles of association;
  • A program of operations;
  • A business plan, including a forecast budget for the first three financial years which demonstrates that the EMI is able to operate and employs the appropriate internal control systems, procedures and resources;
  • A description of the measures taken for safeguarding e-money holders’ funds, where payment services are not relating to issuance of electronic money, are to be provided, also a description of the measures taken (to be taken) for safeguarding users’ funds;
  • A description of the management and internal control mechanisms, including administrative, risk management and accounting procedures;
  • A description of the internal control mechanisms established in order to comply with obligations in relation to prevention of money laundering and terrorist financing;
  • A description of the structural organization, including the intended use of branches, agents, natural or legal persons through which the electronic money institution intends to distribute or redeem electronic money or other entities to which activities will be outsourced, and a description of participation in payment systems;

  • The data on the identity of persons holding qualifying holdings in the authorized capital and/or voting rights of the electronic money institution, the size of their holdings in the authorized capital and/or voting rights, also evidence of the suitability of these persons taking into account the need to ensure the sound and prudent management of an electronic money institution;

  • The identity of directors, including the persons responsible for the management of the electronic money issuance activities of the electronic money institution as well as evidence that they are of good repute and meet the requirements set forth by the legislation;

  • The address of the residential office.

Details of obtaining a license

Stages of obtaining an electronic license - Singapore.
Stages of obtaining an electronic license - Singapore.

Process of obtaining a license for electronic money in Singapore

On receiving the decisions by the regulator, the MAS representatives will review all the required components of the project to ensure that it has been fully completed and that you are confident in your on-going regulatory obligations and compliance framework. Usually, it takes from 4 to 6 weeks.

Also, all the activity would pass the next three phases for obtaining an EMI license. They are:

Phase 1: Pre-application

  1. Analysis (Gap Analysis and Planning);
  2. Business Summary Development;
  3. Pre-Application Engagement.

Phase 2: Documentation

  1. Regulatory Business Plan Adaptation;
  2. Risk Management and Controls Framework Adaptation.

Phase 3: Application

  1. Application completion and submission;
  2. MAS Liaison and Decision.

Cost of Electronic Money Institution License in Singapore

The cost of EMI license in Singapore is about 26 000 Euro.

Why Licensing with Law&Trust International?

Law and Trust International proposes obtaining a necessary Singaporean EMI license with all requirements and laws. We give a high specter of opportunities for every interested person. Law and Trust gives:

  1. Well-Qualified law assistance;
  2. Submitting the documents and liaising with MAS;
  3. Filling the required papers and applications;
  4. Legal support and representation of your interests in the Monetary Authority of Singapore, drafting the agreements with third parties (audit companies, service providers);
  5. Registration of companies, TMs, services and intellectual property; Opening bank accounts;
  6. Creating a legal opinion for the payment system, working with cryptocurrencies, banking systems.

After the process of obtaining the necessary license, we would deliver it personally or via courier services. If you are interested in getting your EMI license in Singapore, please contact our lawyers for free consultation.

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