Resolve the customer geography first
MAS’s June 2025 clarification explains that services supplied to Singapore customers are covered by existing financial-services regimes as applicable. A separate digital-token-service-provider regime addresses relevant services supplied solely overseas. MAS states it generally will not issue licences for the overseas-only model.
Document where customers are located, where the service is performed and whether tokens are digital payment tokens or capital-markets products. Incorporating in Singapore does not make an overseas-only token-service business an unrestricted route. Resolve the regulatory analysis before spending on a launch.
Describe the activity before choosing a company
Draw the customer journey from onboarding through deposit, trade, custody and withdrawal. State who owns or controls assets at every step, which entities provide each service and where customers live. Explain revenue, token rights, outsourcing, governance and the use of smart contracts.
Prepare a permission matrix that maps each activity to the authority and questions requiring an answer. Incorporation, a commercial trade licence, AML supervision and a financial-services authorisation are different parts of the analysis. Avoid selecting a route solely because a company can be incorporated quickly.
Build a decision-ready project file
Collect an ownership chart, management experience, financial forecast, custody design, AML controls, technology architecture and wind-down outline. These are preparation materials, not a complete statutory application checklist. Confirm the regulator’s actual submission requirements for your model.
Before taking customer money, obtain advice on the exact permissions, marketing constraints and launch conditions. Track unresolved issues, the official source consulted and the person responsible for closing each issue. Update the file when you change a token, customer market or custody arrangement.
Sources & scope
Official sources support the jurisdiction context. The working checklists are CryptoGov’s editorial preparation suggestions, not an exhaustive application or filing requirement. Confirm the rules and your circumstances before acting.