Digital payment token service providers

Digital payment token (DPT) compliance support in Singapore.

Practical compliance support for licensed crypto businesses operating within Singapore’s DPT framework, working alongside management and your in-house compliance team. We review selected controls, organise evidence and turn issues into an agreed workplan.

Discuss your compliance needs

Support shaped around how your firm works.

This support may be useful if you are:

  • Licensed DPT service providers with an in-house compliance function seeking additional review and advisory capacity.
  • COOs and compliance leads who need clearer management reporting, issue ownership and remediation follow-up.
  • Firms reviewing how an agreed product or operating change affects their policies and compliance arrangements.

We confirm suitability and scope case by case. Your firm’s activities and circumstances—not its sector label alone—determine what may be needed.

Choose the support you actually need.

After reviewing your activities, current arrangements, internal ownership and priorities, we can agree which workstreams belong in the engagement.

01

Policies that reflect actual operations

Review or prepare selected policies and procedures against the agreed business model. Clarify control owners, escalation points and the evidence the firm should retain; management approves and implements changes.

02

Selected AML/CFT and monitoring reviews

Sense-check agreed customer-risk, due-diligence or monitoring questions using the information supplied. Identify gaps and follow-up questions for the responsible team; operational screening and final case decisions remain with the firm.

03

Compliance calendar and submissions preparation

Organise an agreed inventory of recurring obligations, internal review points and submission preparation tasks. Confirm applicability and ownership with the firm rather than treating a generic checklist as its complete obligations.

04

Management reporting and remediation

Help structure selected findings into a report and action register: issue, evidence, impact, owner, target date and closure criteria. Use working discussions to surface overdue actions and matters requiring management decisions.

05

Product and operating-change review

Review the agreed change description, identify compliance questions and map dependencies for management consideration. Specialist legal, technical or assurance work is identified separately where needed.

06

Training and assessment preparation

Prepare agreed staff training or help organise policy and control evidence for an external review. The firm runs its controls, provides accurate evidence and engages any independent assessor separately.

What an agreed working month could look like.

A fictional DPT provider example showing how priorities become review work and management actions. Actual work and frequency depend on your engagement.

  1. 01

    Plan

    The in-house compliance lead identifies one monitoring-review question, one policy change and the management-report priorities.

  2. 02

    Review

    AA reviews the agreed documents and selected evidence, recording gaps and questions for the responsible team.

  3. 03

    Follow up

    The firm supplies clarification, approves actions and updates owners, target dates and closure evidence in its action register.

  4. 04

    Discuss

    A working meeting reviews progress and unresolved decisions. Quarterly reporting is prepared when included in the agreed package.

This is an illustrative planning aid, with fictional workstreams and no prescribed regulatory deadlines. It is not a complete compliance calendar or a substitute for assessing your firm's requirements.

Download the editable example workplan (CSV)

Know what sits outside the scope.

  • Replacing the in-house local compliance officer or accepting a formal compliance-officer appointment.
  • Running all customer screening, transaction monitoring, investigations or final onboarding decisions.
  • Independent audit or assessment, legal opinions, penetration testing, custody or technology implementation.
  • Unlimited incident support, a guarantee of regulatory compliance or a guarantee that findings will be closed.

Management keeps ownership.

  • Maintain suitable in-house personnel, authority, systems and operating controls.
  • Provide complete information and retain the evidence of how controls operate.
  • Approve customer-risk decisions, policies, submissions and remediation actions.
  • Implement agreed actions and obtain specialist advice or independent assurance where required.

What we’ll clarify together.

  1. Which licensed activities and actual services does your firm operate?
  2. Who is your in-house compliance lead, and which tasks need additional support?
  3. What findings, operating changes or reporting needs should the first workplan address?
  4. What evidence is available, and who will approve and implement the actions?

What you may want to know.

Can AA replace our in-house DPT compliance officer?

No. This service supplements the firm’s in-house function. MAS’s licensing guidelines expect a DPT service provider to have an in-house local compliance officer; management remains responsible for the arrangements.

Can you help with selected AML/CFT questions?

We can agree review and advisory work on selected questions and supporting material. Your firm continues to perform operational controls and makes the final customer, escalation and reporting decisions.

Does support include an independent assessment or legal opinion?

No. Independent assurance and legal opinions are separate services. We can help organise agreed evidence and identify questions for the specialists your firm engages.

What should we bring to the first call?

A short description of your activities, internal compliance arrangements, immediate priorities and any open findings. We will agree a suitable secure process before requesting sensitive files.

How much does ongoing support cost?

Our published ongoing packages are starting points for a suitability discussion. The written proposal confirms the DPT workplan and boundaries; it does not assume that every DPT operating model fits the same package.

Match the workplan to your internal capacity.

These are our published ongoing packages. We confirm suitability, the sector-specific workplan and exclusions in a written proposal before work starts.

Standard Compliance Advisory

S$1,000 per month

Monthly compliance calls, with questions welcomed between calls as they arise.

No separate onboarding fee.

No minimum term.

Compliance Starter Pack

S$2,500 per month

Monthly working meeting, quarterly compliance reports and ad-hoc compliance Q&A on working days.

For new firms, a separate S$4,000 setup fee will apply to prepare all necessary policies and procedures, and provide staff training for compliance operations.

Application support is scoped and quoted separately. External, statutory and third-party charges are separate unless expressly agreed. Published packages do not include a formal compliance-officer appointment.

Read the full package scope and fee terms

Start with a focused conversation.

Share the immediate issue, ask initial questions and see whether there is a sensible basis for an engagement.

Discuss your requirements
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