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Safeguarding of customer monies for MPIs is achieved via a bank/financial-institution undertaking or guarantee, a trust account deposit, or other MAS-prescribed means. MPIs face base-capital and security-deposit obligations, fit-and-proper criteria, and ongoing MAS supervision via on-site and off-site reviews. Conduct standards include the E-Payments User Protection Guidelines (EUPG), amended December 2024 alongside the Shared Responsibility Framework.
This safeguarding rule sits alongside, and reinforces, the licensing tightening tracked separately under Licensing, Authorisation & Market Access: a firm can now be brought inside the regulated perimeter under the expanded Payment Services Act scope, and once inside, is subject to a concrete customer-asset-protection obligation rather than a general conduct expectation. No further conduct, safeguarding, or financial-promotions deltas beyond the trust-account segregation requirement were sourced for Singapore this cycle.
Outlook
The trust-account segregation requirement has now been in force for close to two years, so the near-term interest for this module shifts to compliance and supervisory follow-through: whether the Bsquared Technology licence revocation reflects, in part, a segregation or conduct failing, or is attributable to some other licence condition, was not specified in the sourcing available this cycle.
Conduct, Safeguarding & Financial Promotions
Amended Payment Services Regulations requiring digital-payment-token service providers to segregate customer assets into trust accounts, and to maintain proper books, records and systems controls, took full effect six months after their 4 April 2024 introduction -- that is, from 4 October 2024. This safeguarding requirement is confirmed and sits within this cycle's recency-relevant standing baseline for nonbank payment institutions and e-money issuers handling DPT customer assets.
The safeguarding mechanism operates through mandated trust-account segregation, meaning DPT customer funds must be held separately from a provider's own operating funds, with accompanying books-and-records and systems-controls obligations layered on top. This is materially distinct from the safeguarding regimes that apply to bank-operated payment services, where prudential capital and deposit-insurance frameworks already provide a different form of customer-asset protection; the trust-account mechanism is specifically calibrated to the nonbank PI/EMI segment operating in the DPT space, where no equivalent prudential backstop exists.
Outlook
With this safeguarding requirement now over a year into full effect, the item to track is whether MAS surfaces any enforcement action against a provider for a safeguarding-obligation breach, which would be the first real test of the trust-account mechanism's practical enforceability.
1 earlier distinct update(s)
Conduct, Safeguarding & Financial Promotions
MAS' Guidelines for financial institutions' digital advertising took effect on 25 March 2026, extending regulatory oversight to content creators operating as partners of financial institutions. The guidelines establish five safeguards: channel-appropriateness, platform-limitation awareness, accuracy and fairness compliance, monitoring and oversight, and disclosure obligations, and apply across both bank and non-bank financial institutions. Tied to this rollout, MAS has said it will issue advisory letters to five content creators who may have provided financial advice without a licence, an enforcement-policy signal rather than a formal enforcement action.
Outlook
Whether the advisory letters escalate into formal enforcement, and how the five-safeguard framework is applied to platform-specific content formats, are the near-term conduct-side questions for this module.
Sources and findings (4)
- T3https://rsmstoneforest.sg/accreditations/payment-services-act [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
- T1MAS Payment Services Act 2019 — MPI/SPI authorisation (mas.gov.sg)
- T1https://www.mas.gov.sg/contact-us/faqs/payments-faqs/payments-service-licensing-faqsretrieved
- T3https://www.aoshearman.com/en/insights/ao-shearman-on-fintech-and-digital-assets/combatting-payment-account-fraud-singapores-shared-responsibility-framework [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]