by Dean
Share
Share
S$1,500 does not determine whether the Travel Rule applies. Under MAS Notice PSN02, institution-to-institution digital payment token value transfers are subject to information requirements regardless of value. The threshold changes the information set that must accompany the transfer.
PSN02 took effect on 28 January 2020. The current notice is dated 2 April 2024 and was last revised on 30 June 2025, with the latest amendments taking effect on 1 July 2025.
Which DPT service providers are affected?
PSN02 applies to payment service licensees carrying on a business of providing digital payment token services.
On 4 April 2024, MAS expanded the scope of regulated payment services. The expanded definition covers activities including DPT custody, facilitating DPT transfers between accounts and facilitating DPT exchanges where the provider does not possess the money or tokens involved.
A firm offering these services should assess whether it requires licensing under the Payment Services Act 2019. It should then identify whether it acts as an ordering, beneficiary or intermediary institution in each transfer flow.
What information must accompany a DPT transfer?
| Transfer value | Information accompanying the transfer |
|---|---|
| S$1,500 or less | Originator’s name and account number, plus beneficiary’s name and account number. Where no account exists, a unique transaction reference number must be used. |
| Above S$1,500 | The basic information above, plus the originator’s address or other permitted official identifying information, such as a unique identification number or date and place of birth. |
The required information must accompany the transfer before or at the same time as the transfer. For transfers of S$1,500 or less, the ordering institution must also be able to provide the fuller information required under PSN02 within three business days of a valid request.
Some providers use the full information set for every transfer to reduce threshold errors. This is an operational choice, not a separate MAS requirement.
What must ordering and beneficiary institutions do?
The ordering institution must identify the originator, verify the required information and ensure accurate data accompanies the transfer.
The beneficiary institution should have controls to detect missing or incomplete information. Its policies should explain when a transfer will be executed, suspended, rejected or escalated for further review.
Technical transmission alone is not enough. Firms should retain evidence showing what information was sent or received, when screening occurred and how exceptions were resolved.
Transfers involving private or self-hosted wallets require a different process because there may be no receiving institution available to accept a Travel Rule message. Firms should document their risk assessment, customer checks, wallet screening and the reason for applying a different control.
Common implementation gaps
Common weaknesses include outdated assessments following the 2024 scope expansion, inconsistent treatment of counterparties that cannot receive Travel Rule data, weak threshold logic and no documented response to missing information.
Blockchain analytics and sanctions screening can support the wider AML framework, but they do not replace the information-transfer requirements in PSN02.
Pro Tip: Test one outgoing transfer, one incoming transfer and one transfer with missing information. Confirm that the information, screening result, decision and escalation history can be reconstructed from the firm’s records.
Frequently asked questions
Does the Travel Rule apply below S$1,500?
Yes. The threshold changes the required information set. It does not create a general exemption.
Does it apply to private wallets?
A private wallet may not have another regulated institution to receive the information. The provider should still apply appropriate customer due diligence, screening, risk assessment and recordkeeping controls.
Are Standard Payment Institutions exempt?
No general Travel Rule exemption applies solely because a licensed DPT service provider holds an SPI rather than an MPI licence.
Is Your Travel Rule Process Ready for Review?
Alder’s AML and KYC support and compliance audit teams can review your Travel Rule procedures, transfer data, screening controls and exception handling.
About the Author: Dean
