The opinion letter written by the law firm to us was simply sorted out by gpt: 1/ Singapore MAS issued the final guidance on the DTSP regulatory framework under the Financial Services and Markets Act (FSMA). FSMA will officially take effect on June 30, 2025, and DT-related businesses that are not compliant will be required to stop operations immediately. 2/ What is DTSP? Any institution that has an office in Singapore and provides the following services to overseas customers may belong to DTSP: •Token trading •Transfer, exchange, matching •Custody services •Advisory/matching transactions 3/ But here comes the point: If you are already licensed or exempted under PSA/SFA/FAA, you do not need to apply for a DTSP license under FSMA! ✅ PSA license ✅ PSA exempted ✅ SFA/FAA licensed or exempted 👉 You are an exempt party and do not need to apply again 4/ For example: If you are a custodian, you are already licensed or exempted under PSA, even if you serve overseas customers, you do not need to apply for a new DTSP license. But you still need to meet the additional regulatory obligations of FSMA: 5/ New obligations include: • More stringent technology risk management (TRM) • Annual audit report submission • Higher AML/CFT requirements • Report major security incidents to MAS within 1 hour • Prohibit cash payments above S$20,000 6/ The goal of FSMA is to integrate the regulatory authority of MAS and unify the supervision of institutions under different licenses. MAS no longer tolerates gray areas. The focus of supervision has shifted from "whether it is licensed" to "whether it is compliant." 7/ The supervision of stablecoins is also being upgraded simultaneously: • Single currency stablecoins (SCS) have an independent regulatory framework • Other stablecoins are considered DPTs and are still under the jurisdiction of PSA • If stablecoins are used as underlying assets of derivatives, they may be included in SFA supervision 8/ So, you need to ask yourself two questions: ✅ Do I already have a PSA/SFA license or exemption? ✅ Do I provide DT services to overseas customers? If the first answer is "yes", then you don't need a new application; but you need to upgrade your compliance! 9/ Summary: ❗ DTSPs that are neither licensed nor exempted must either obtain a license before June 30 or close down ✅ Licensed/exempted companies can continue to operate, but must meet higher compliance thresholds 📈 MAS will continue to tighten digital asset regulation, don’t wait until the last day to act