Singapore

Singapore is the jurisdiction US counsel most often treats as “the well-regulated alternative.” That is true for payments and for DPT intermediaries. It is not true as a translation of Regulation Crypto Assets. The Payment Services Act licences dealing in, facilitating exchange of, and related DPT services. The SFA licences capital-markets products. The 15 August 2023 SCS framework adds a voluntary “MAS-regulated stablecoin” label for Singapore-issued SGD or G10 single-currency coins above S$5 million in circulation, with 100% reserves, par redemption within five business days, and a ring-fence against unrelated business.

• Licence class (major payment institution, standard payment institution, exemption) is the public evidence of payments-perimeter status. Look at the MAS Financial Institutions Directory, not at a press release.
• PSA amendments to hard-wire the SCS framework have lagged the 2023 policy. Until they are fully in force, some redemption and labelling features are supervisory expectations rather than holder-enforceable statutory rights. Cite the media release as policy, not as a private right of action.
• Travel Rule expectations apply to in-scope VASPs. FATF implementation is a separate grade from DPT licensing.

• RFC 82 (U.S. issuer): if the stack is a Singapore Pte. Ltd. issuing a DPT with a US CIC wrapper, say whether you can satisfy the four-part US-issuer test. If you cannot, you are a MiCA/MAS issuer, not a Rule 300 issuer.
• Do not offer MAS SCS as a model for Rule 200. Offer it as a model for whatever US stablecoin statute sits beside RCA.