Following yesterday’s release of Singapore’s virtual currency exchange license application：The response to the article Basic Regulatory Framework has been strong，Everyone is very interested in applying for a virtual currency exchange license in Singapore，Gumeiluobao continues to invite Singapore New Asia Law Firm(limited liability company)（AsiaPractice）的创始人刘仁英律师为大家讲解什么样的虚拟货币服务需要牌照*免责声明：The copyright of the article belongs to the original author。
The content is the author's personal opinion，This official account is for reference only and does not constitute any investment or application advice.。一《支付服务法案》新加坡金融管理局（以下简称金管局）已意识到近年来，The development landscape of payment services has undergone significant changes，These changes were also recently mentioned in the Payment Services Bill (Draft) (hereinafter referred to as the "Draft")。
This "Draft" is a proposed version of the "Payment Services Bill" that will be introduced in the future.，Regulatory adjustments will be made to virtual currency transactions and other matters。Our firm will briefly introduce the relevant definitions in the Draft below (please refer to the bolded parts for important content)。
关于“虚拟货币”的定义（《草案》第2条(1)paragraph) in the Draft，Virtual currency is any digital form of value，Its definition is as follows:(a)exist in unit form;(b)Not priced in any fiat currency;(c)是一种已被公众或部分公众接受的用于支付商品、A medium of exchange for servicing or settling debts;(d)Can be transferred electronically，Save or trade;(e)Satisfy the nature and characteristics of other HKMA regulations。
However, this definition does not include the HKMA’s regulations on other digital forms of value.。申请执照（《草案》第7章）服务商若“提供虚拟货币服务”，You must hold a standard payment institution license or a professional payment institution license。
相关定义（《草案》附件一第II部分第1条）“提供虚拟货币服务”的定义为：(a)Trade with virtual currencies(b)Set up a virtual currency exchange(c)Other virtual currency services regulated by the Hong Kong Monetary Authority The definition of “transactions using virtual currencies” mentioned above is as follows::(a)Buy virtual currency(b)Sell Virtual Currency in exchange for other Virtual Currency or any other currency，but does not include：(i)Establish a virtual currency exchange Establish a virtual currency exchange，Refers to the establishment or operation of a virtual currency exchange，That is to say, the founder or operator can，through various exchanges、Actual offer or solicitation of offer to buy or sell virtual currency，Obtain currency or virtual currency (whether in advance or at another time)(ii)Accept payment for goods or services in the form of virtual currency(iii)Use virtual currency to pay for goods or services. The "virtual currency exchange" mentioned above refers to places or institutions that engage in the following activities (whether in electronic form or other forms)：(a)Exchanges can be issued through exchanges、Offers or invitations to buy or sell virtual currencies in exchange for other virtual currencies or any fiat currency。
(b)Offers that can be made on and through the exchange、Invitation to achieve redemption directly or indirectly，Purpose of selling or buying virtual currency(c)issue redemption、Buy、Persons offering or inviting offers to sell virtual currency，Unlike the person who accepts or makes a counteroffer。
However, the above definition does not include places and institutions where only one person can engage in the following activities：(i)Issue purchases regularly、sell，or an offer or invitation to exchange virtual currency；(ii)Accept purchases regularly、sell，or an offer or invitation to exchange virtual currency。二金管局关于支付服务的征求意见书2026年11月，The Hong Kong Monetary Authority seeks opinions from payment industry market participants on issues related to the Payment Services Bill。
In the consultation letter，Financial Supervisory Authority highlights virtual currency trading。its anonymous nature，Easily exploited as a tool for money laundering and terrorism financing。therefore，The Hong Kong Monetary Authority will set relevant anti-money laundering and anti-financing of terrorism obligations for intermediaries who convert virtual currencies into legal tender through transactions and the establishment of virtual currency exchanges.。The Hong Kong Monetary Authority also emphasized that virtual currency service providers must actually operate funds or virtual currencies.。
This is intended to exclude mainstream online marketplaces and social media platforms from the scope of proposed regulation.。Because compared to virtual currency exchanges，The risks of money laundering or terrorism financing faced by such platforms are different，And this type of platform only acts as a medium for information exchange.。
Cryptocurrency exchanges that meet the criteria of “owning funds”，will be
Require
Hold a license for payment services，包括由ICO发起人在ICO时设立的提供虚拟货币服务的交易所。三《数字代币发行指南》在金管局发布的《数字代币发行指南》（以下简称《指南》）中，The Financial Supervisory Authority mentioned the following typical intermediaries engaged in the issuance of digital tokens:。
(a)Operators of platforms engaged in the initial issuance of digital tokens (hereinafter referred to as primary platforms)。(b)从事数字代笔交易的平台（以下简称交易平台）的运营者。According to the provisions of the Guidelines，初级平台中发行的数字代币可构成受到新加坡《证券与期货法案》（第289章）监管的一种或多种资本市场产品。
If a junior platform operator engages in or claims to engage in such regulatory activities，Unless an exception is provided for under the Securities and Futures Act，It needs to apply for the relevant capital market service license。If the digital tokens issued on the trading platform constitute securities or futures trading contracts，Then the actions of the platform operator may constitute the establishment or operation of securities or futures markets.。
Operators that engage in such conduct or purport to engage in such conduct are required to obtain approval from the Hong Kong Monetary Authority under the Securities and Futures Act.，Become a market operator recognized by the Hong Kong Monetary Authority，Make the trading platform an HKMA-approved exchange，Unless otherwise provided for by the Securities and Futures Act。四总结目前，Legislation in this emerging area is evolving rapidly。It is reported that，The final "Payment Services Bill" will be different from the current "draft"。
despite this，Based on our experience in this practice area，The Monetary Authority of Singapore has already imposed compliance obligations and regulations on intermediaries such as exchange operators.
Require
，To combat money laundering and terrorism。These
Require
and obligations，It will be included in the formal bill to be introduced by the Hong Kong Monetary Authority in the future.。
therefore，These intermediaries must take certain preventive measures in accordance with the provisions of laws and regulations and procedures.，For example, conduct background checks on customers，Monitor transaction dynamics，Filter information，Report suspicious transactions promptly and keep complete transaction records。However, it is still important to draw your attention to the，In addition to local laws
Require
，Any transactions related to virtual currencies may also be governed by and governed by the laws of the customer’s location.。
There is something in between，If you need overseas legal advice，Our firm will be happy to recommend overseas law firms in the New Asia Legal Network。
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