MAS Notice PSN02 is issued under section 16 of the Financial Services and Markets Act 2022 and applies to all digital payment token (DPT) service providers licensed under the Payment Services Act 2019. It provides binding anti-money laundering and counter-terrorism financing (AML/CFT) obligations that incorporate FATF Travel Rule standards, effectively operationalising Wire Transfer Regulations in the context of virtual asset service provision in Singapore.

Application of the Travel Rule to Digital Token Transfers

The Notice treats all DPT transactions involving a transfer of value from one entity to another as value transfers subject to regulatory obligations akin to traditional wire transfers. These include:

• Identification and verification of the value transfer originator

• Accurate transmission of originator and beneficiary information

• Secure and prompt delivery of this information to beneficiary institutions

• Full retention and disclosure capability to MAS and law enforcement

These measures directly align with WTR principles requiring transparency and traceability in all fund transfers.

Threshold-Based Data Transmission Requirements

The Notice sets specific information standards based on transaction thresholds:

• For transfers up to S$1,500: The ordering institution must include the originator's and beneficiary’s names and account or transaction reference numbers.

• For transfers exceeding S$1,500: Additional originator data is required, including either address, national ID, or date/place of birth. Identity must be verified before transmission.

This two-tiered approach reflects FATF’s guidance on proportionality while still maintaining compliance with WTR traceability expectations.

Responsibilities of Institutional Actors

The Notice assigns distinct duties to each party in the transfer chain:

• Ordering Institutions: Must collect and verify full information, securely transmit it, and retain records for five years. Transfers must be rejected if minimum data requirements cannot be fulfilled.

• Beneficiary Institutions: Must detect transfers with missing data, verify beneficiaries where needed, and determine when to execute, suspend or reject transfers based on internal risk policies.

• Intermediary Institutions: Must retain all information received, forward it securely, and take reasonable measures (consistent with straight-through processing) to detect and handle non-compliant transfers.

These roles mirror the WTR framework and support complete data integrity across the transaction lifecycle.

Record-Keeping & Disclosure Obligations

All PSPs must retain transaction and CDD information for at least five years. Records must enable complete reconstruction of the transaction and be made available to MAS, the Suspicious Transaction Reporting Office (STRO), or law enforcement without delay. This satisfies WTR criteria for data accessibility and auditability.

Suspicious Transaction Reporting (STR)

STRs must be filed promptly for any transaction where there are grounds to suspect money laundering or terrorism financing. This includes cases where:

• Required transfer information is incomplete or unverifiable

• Customer behaviour raises red flags

• Transactions are unusually large or lack economic purpose

STRs must include full transaction metadata and be submitted both to the STRO and MAS, reinforcing WTR-aligned reporting transparency.

Group-Wide Controls & Third-Party Reliance

The Notice mandates group-wide AML/CFT policies, particularly where PSPs operate through branches or subsidiaries. Third-party reliance for CDD is permitted only under strict conditions, including immediate access to CDD records and assurance of FATF-aligned AML controls by the third party. These measures ensure that WTR responsibilities cannot be subcontracted without appropriate oversight.

Conclusion: WTR Compliance Integration

MAS Notice PSN02 embeds FATF Travel Rule and Wire Transfer Regulation principles into Singapore’s digital asset regulatory regime. Through specific duties for ordering, intermediary and beneficiary institutions; robust CDD and data retention requirements; and a strong supervisory framework, the Notice ensures that digital payment token transfers meet the same standards of traceability, accountability, and transparency as conventional wire transfers. This integration protects Singapore’s financial system from abuse and demonstrates regulatory leadership in applying WTR to evolving financial technologies.