Singapore Launches Licencing Regime for Digital Token Service Providers under Singapore Financial Services and Markets Act
On 30 May 2025, the Monetary Authority of Singapore (MAS) launched the full licensing and compliance regime for Digital Token Service Providers (DTSPs) under the Singapore Financial Services and Markets Act 2022, for Digital Token Service Providers operating in or from within the Singapore Financial markets. Following a comprehensive consultation process, MAS published regulatory instruments to ensure clarity, risk containment, and AML/CFT integrity for custodial, exchange, transmission, and facilitation services relating to digital tokens.
- The finalised framework follows two MAS publications: the Consultation Paper “Consultation Paper on Proposed Regulatory Measures for Digital Token Service Providers under the Financial Services and Markets Act 2022” issued on 3 October 2024 and the “Response to Feedback Received from Consultation Paper on Proposed Regulatory Measures for Digital Token Service Providers” published on 30 May 2025.
- All DTSPs must be licensed under Section 138 of the FSM Act, with no transitional exemptions permitted.
- Operating without a licence post-effective date constitutes an offence under Section 137(6).
- Minimum base capital requirement is SGD 250,000; annual licence fee is SGD 10,000.
- Licensing applies to both domestic and cross-border entities providing services “in or into” Singapore.
- MAS will assess foreign applicants based on regulatory equivalence, group structure, and financial integrity.
- Notice FSM-N27 codifies AML/CFT compliance requirements, including CDD, monitoring, screening, and a Singapore-based compliance officer.
- Notice FSM-N28 imposes mandatory reporting of suspicious transactions and fraud within five business days to both MAS and the STRO.
- Regulatory reporting is governed by Notice FSM-N29, which requires monthly, semi-annual, and annual filings via MASNET.
- Notice FSM-N30 mandates IT risk controls, incident notification within one hour, and root cause submission within 14 days.
- Notice FSM-N31 mandates cyber hygiene safeguards including MFA, patch protocols, and restricted admin access.
- Notice FSM-N32 sets strict record-keeping standards including formatted receipts, 5-year retention, and digital token segregation.
- Notice FSM-N33 regulates public communications, requiring visible risk disclosures and prohibiting misleading group-level claims.
- Governance standards are set under MAS Guidelines FSG-G01, which covers integrity, competence, and fitness of all key personnel.
- Special reference made to Cross-border DTSPs who must revise marketing content, system design, and disclosures to avoid inadvertent breach of MAS requirements.
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Monetary Authority of Singapore Publishes Clarification on Licensing Deadline for Cross-Border Digital Token Service Providers Under FSMA 2022
On 6 June 2025, the Monetary Authority of Singapore (MAS) issued a formal media release clarifying the licensing obligations, exemptions, and regulatory enforcement timelines applicable to Digital Token Service Providers (DTSPs) under the Singapore Financial Services and Markets Act 2022 (FSMA 2022). The clarification follows MAS’s response to DTSP consultation feedback released on 30 May 2025 along with annexures, which together operationalise the DTSP regime. This specifically addresses the licensing status of cross-border DTSPs, stating that entities providing services solely to overseas clients will require authorisation by MAS from 30 June 2025, or cease operations altogether.
- According to MAS, they will generally not grant licences for DTSPs operating exclusively on a cross-border basis due to high money laundering and terrorism financing risks.
- Any unlicensed DTSP offering regulated services to foreign clients must halt all activities by the implementation date.
- DTSPs licensed to serve Singapore-based customers may continue to offer their services globally without restriction.
- The new regime does not apply to DTSPs dealing solely with utility tokens or governance tokens; such services remain unregulated under FSMA 2022.
- DTSPs based overseas but offering regulated services to non-Singapore clients must still obtain a Singapore licence if they are considered to be operating “in or into” Singapore.
- MAS has proactively contacted affected DTSPs and advised them to prepare orderly wind-down plans to avoid regulatory breach.
- The regulatory stance on cross-border DTSPs has been consistently communicated by MAS since February 2022.
- All firms engaging in token-related activities must now reassess their operating model, legal standing, and licensing exposure under the FSMA framework.
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United States SEC and CFTC Extend Form PF Compliance Deadline to 01 October 2025
On 11 June 2025, the United States Securities and Exchange Commission (US SEC) and the United States Commodity Futures Trading Commission (US CFTC) announced a further extension of the compliance deadline for the amended Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers to 1 October 2025. This decision gives advisers to private funds, particularly those also registered as commodity pool operators (CPOs) or commodity trading advisers (CTAs), an extended window to align systems, policies, and reporting workflows with the upcoming regime.
- The amended Form PF was adopted on 08 February 2024 under the United States Investment Advisers Act of 1940.
- The compliance date was first set for 12 March 2025, then extended to 12 June 2025, and now further deferred to 1 October 2025.
- Form PF applies to US SEC-registered investment advisers to private funds, including dual registrants with the US CFTC.
- The amendments are supposed to improve systemic risk surveillance by the Financial Stability Oversight Council and reinforce investor protection through richer, timelier reporting data.
- New reporting thresholds and event-triggered disclosures, particularly for large hedge fund advisers, require significant upgrades to back-office infrastructure.
- The extension gives entities more time to build, test, and implement robust reporting systems without compromising data quality or facing rushed compliance.
- The delay also allows legal and compliance teams to review their firm-wide controls, calibrate internal protocols, and validate third-party vendor integrations.
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US SEC Appoints Brian T. Daly as Director of Investment Management Division, Effective 8 July 2025
On 13 June 2025, the United States Securities and Exchange Commission (US SEC) appointed Brian T. Daly as Director of the Division of Investment Management, with effect from 8 July 2025..
- Mr Daly was a partner at Akin Gump Strauss Hauer & Feld LLP in New York, advising investment advisers on compliance, fund operations, and governance.
- He previously served nearly a decade at Schulte Roth & Zabel LLP and held senior in-house roles at Millennium Partners, Kepos Capital, and Raptor Capital Management.
- His education includes a J.D. from Stanford Law School, where he was Associate Editor of the Stanford Law Review and Editor-in-Chief of the Stanford Journal of International Law.
- He also holds a B.A. magna cum laude from Catholic University and an M.A. from the East-West Center at the University of Hawaii.
- Mr Daly has taught legal ethics at Yale Law School and served on the Board of the Managed Funds Association.
- Mr Daly expressed enthusiasm for contributing to a “new day” at the US SEC, focusing on statutory precision and minimising unnecessary regulatory burdens on investment advisers.
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US SEC Appoints Jamie Selway as Director of Trading and Markets, Effective 17 June 2025
On 13 June 2025, the United States Securities and Exchange Commission (US SEC) appointed Jamie Selway as Director of the Division of Trading and Markets, with effect from 17 June 2025. A market structure expert with roots in both policymaking and financial innovation, Selway’s leadership is a new chapter in the agency’s regulatory engagement with modern markets.
- Jamie Selway was most recently a partner at Sophron Advisors, a financial consultancy.
- His prior roles include Head of Electronic Brokerage at Investment Technology Group, Chief Economist at Archipelago, and Managing Director at White Cap Trading, which he co-founded.
- He previously worked in regulatory policy at the National Association of Securities Dealers (now FINRA) and conducted equity derivatives research at Goldman Sachs.
- Selway holds a Master’s degree in Financial Mathematics from the University of Chicago and a Bachelor’s in Mathematics and European History from Washington & Lee University.
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US SEC Appoints Kurt Hohl as Chief Accountant Effective 7 July 2025
On 13 June 2025, the United States Securities and Exchange Commission (US SEC) appointed Kurt Hohl as Chief Accountant, effective 7 July 2025. Mr Hohl returns to the US SEC with nearly four decades of expertise in global accounting, audit oversight, and regulatory policy, marking a significant leadership reinforcement at a time of rapid financial market evolution.
- Kurt Hohl previously served at the US SEC between 1989 and 1997, rising to Associate Chief Accountant in the Division of Corporation Finance.
- He was in core team of drafting the foundational Financial Reporting Manual, a guide still used by the US SEC and accounting professionals today.
- Hohl spent 26 years at Ernst & Young (EY), ultimately as Global Deputy Vice-Chair of EY’s Global Assurance Professional Practice, leading over 1,400 professionals worldwide.
- Most recently, he was the founder of Corallium Advisors, advising on audit, IPO readiness, and regulatory compliance.
- He is a Certified Public Accountant (CPA) in Virginia and holds a Bachelor of Business Studies in Accounting from James Madison University.
- Acting Chief Accountant Ryan Wolfe, who has served in the role since January 2025, will return to his prior position as Chief Accountant in the Division of Enforcement.
- US SEC Chairman Paul S. Atkins praised Hohl’s return, citing his international perspective, integrity, and technical acumen as critical to advancing the US SEC’s mission.
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US SEC Appoints Erik Hotmire as Chief External Affairs Officer and Director of Public Affairs, Effective 16 June 2025
On 13 June 2025, the United States Securities and Exchange Commission (US SEC) appointed Erik Hotmire as Chief External Affairs Officer and Director of the Office of Public Affairs, with effect from 16 June 2025. This marks Hotmire’s return to the agency after a distinguished career spanning high-level roles in both the public and private sectors.
- Hotmire previously served as Senior Advisor and spokesman to former US SEC Chairman Christopher Cox.
- He also provided advisory support to the US SEC’s Division of Enforcement.
- During the George W. Bush Administration, he was Special Assistant to the President and White House domestic policy spokesman.
- In the private sector, he held key roles including partner and co-founder of Watermark Strategies, global co-lead of financial institutions at Brunswick Group, senior managing director at Teneo, and partner at FGS Global.
- Hotmire began his professional journey in broadcast journalism and holds a Bachelor’s degree in political science from Taylor University.
- US SEC Chairman Paul S. Atkins expressed confidence in Hotmire’s leadership to enhance the Commission’s communication and outreach.
- Hotmire stated he is honoured to support the SEC’s mission of investor protection, market integrity, and capital formation in a dynamic financial environment.
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