If your company collects money from people and sends it on to others, for example remitting money home for workers, paying overseas suppliers on behalf of clients, or receiving funds for buyers of cryptocurrency, it may be providing a payment service that needs a licence from the Monetary Authority of Singapore. Under the Payment Services Act 2019, carrying on a business of providing any type of payment service in Singapore without a licence, unless exempted, is punishable by a fine of up to S$125,000, imprisonment of up to three years, or both, and up to S$12,500 a day for a continuing offence after conviction. Police have charged operators of small shops, company directors and individuals using their own accounts. If your business does this, stop taking new money and get advice now.
Stop before the next transfer, and get advice on how to unwind properly. There is no published amnesty for unlicensed payment services. What you can control is whether the activity stops now, whether the records are complete and honest, and whether customers’ money is dealt with lawfully. Continuing while you “look into it” adds to the exposure, and the money may also raise money laundering questions.
What counts as a payment service
MAS regulates seven types of payment service under the Act, including domestic money transfer and cross-border money transfer services, and requires providers to hold a licence unless an exemption applies. Not every payment-related activity is regulated. MAS’s payment services licensing FAQs explain that the Act carves out, for example, services involving only limited-purpose e-money, and payment services solely incidental to regulated activities of a regulated financial services company. Whether a particular arrangement is caught depends on the facts, which is why advice matters.
Warning signs that a business may have drifted into a payment service:
- It receives money from many people and sends it to others, rather than receiving money for its own goods or services.
- It charges a fee or earns a spread on the transfer itself.
- Customers use it because it moves money more cheaply or quietly than a bank.
- It settles amounts for customers through accounts or cards held by other people.
Cases the police have announced
- April 2026: two men to be charged over cross-border remittances of more than S$38.6 million and S$301,000. Police seized cash, ATM cards belonging to others and transaction record books. Both were also charged under the Employment of Foreign Manpower Act for being self-employed foreigners without work passes (SPF, 23 April 2026).
- December 2025: a former company director to be charged after his company’s account at a payment provider received about GBP 1.4 million from overseas accounts from buyers of cryptocurrency. Police said he did not try to establish the source of the money, and at least GBP 75,050 was scam proceeds.
- July 2025: the sole director and signatory of two foreign companies with Singapore bank accounts charged with unlicensed cross-border money transfer, unlicensed remittance under the older Money-Changing and Remittance Businesses Act, and possessing property reasonably suspected to be criminal benefits.
These are charges, not convictions, but they show the pattern: the company or personal account is the tool, and the director is the person charged.
Why it is treated seriously
Police have explained that unlicensed providers are not regulated and are not subject to strict anti-money laundering controls. That is why unlicensed payment cases often come with money laundering questions: a business that moves strangers’ money without checks is easy for criminals to use. Directors who operate such accounts can face the separate offences of rash or negligent money laundering.
What to do if your business has been doing this
- Stop accepting new money for transfer.
- Do not destroy or tidy up records. Keep every ledger, message and bank statement.
- Work out the position of money on hand: whose it is, where it was meant to go and what the customers were told.
- Take legal advice before returning or sending any of it, and before contacting MAS or the police.
- Decide the future: stop the activity for good, restructure so the company only receives money for its own sales, or, if the business is viable, explore with advisers whether a licence is realistic. The MAS licensing process is demanding.
- Review your bank relationships. Banks monitor for this pattern and may ask questions or close the account. See responding to a bank KYC review.
Paying suppliers or receiving funds for group companies
Many genuine businesses pay on behalf of related companies or collect for overseas parents. Whether this is caught depends on how it is structured, who the customer is and whether an exclusion applies. Document the commercial arrangement, keep intra-group agreements and invoices, and get advice before it becomes a regular flow of third-party money.
Companies that market financial services they are not licensed for may also be named by MAS. See the MAS Investor Alert List and what to do.
Frequently asked questions
We only help our foreign workers send money home, and we do not charge. Is that a problem?
Collecting workers’ money and sending it overseas is a money transfer. Whether it is carried on as a business and whether an exemption applies needs advice. The safer course is to help workers use a licensed provider directly.
How do we check whether a provider is licensed?
Use MAS’s Financial Institutions Directory, and deal only through the provider’s official channels.
We are building a payments product. Where do we start?
Start with the licence type and the activities you plan. See Payment Services Act licence types.
More on the company law hub.
Has your business been moving money for others?
If your company, or you as a director or shareholder, has been collecting and forwarding money for others, or the bank or police are asking about it, contact the Raffles Corporate Services team at [email protected] or on WhatsApp at +65 8501 7133 or +65 9018 0072. We will help you understand the position, reconstruct the ledgers from bank records, and restructure the company’s payment flows. Where your matter needs a lawyer, we will refer you to a firm on our panel of Singapore law firms that regularly handles payment services and money laundering matters. Raffles Corporate Services is a corporate services provider, not a law firm, and this article is general information, not legal advice.
The Raffles Corporate Services Editorial Team