Since 2016 I have been developing COREDO as a partner that takes on complex legal and financial challenges of international business. During this time the COREDO team has executed dozens of company registration projects in the EU, the UK, Singapore and Dubai, obtained licenses for clients in the payments, forex, crypto services and electronic money segments, and also built reliable AML/CFT programs. Today I want to systematically analyze a topic that regularly comes up in strategic sessions with founders and CFOs: how to obtain a Major Payment Institution license in Singapore and turn it into sustainable competitiveness in the Asian and European markets.
Why Singapore: the MPI license
The MPI license in Singapore (often called MPI license Singapore) opens access to key activities: cross-border and domestic money transfer, merchant acquisition, issuance of electronic money (e‑money), as well as integration with local schemes PayNow and FAST through a sponsor bank or an approved operator. In practice this creates a base for remittance lines, aggregator models, wallet products and B2B payments with fast settlement and predictable liquidity.
Our experience at COREDO has shown that a Major Payment Institution license in Singapore is an effective anchor not only for Asian markets but also for international expansion through MPI into Asia and Europe. Payment businesses gain simpler transaction routing and improved access to acquiring banks, especially with properly configured AML/CFT and monitoring technologies.
The boundary between Major PI and Standard PI
The PSA distinguishes two classes of universal payment licenses: Standard Payment Institution (SPI) and Major Payment Institution (MPI). The choice of class is not a formality but a strategic factor for unit economics and scalability.
SPI is suitable for companies with limited volumes. Threshold values for average monthly volumes are set by MAS for each service and for aggregate services, and for electronic money there is a limit on float. As volumes grow, a company will inevitably face the need to upgrade the license.
Requirements for obtaining MPI
MAS uses a risk-based approach and assesses readiness across several areas. Below are the key ones that we cover in client applications.
- Ownership structure and beneficial ownership. MAS expects a transparent structure, documentary evidence of ultimate ownership and the absence of sanctions or legal risks. The compliance document package for an MPI applicant should include the ownership chain, proof of source of funds and declarations of beneficiaries.
- Directors and local presence. Director and local representative requirements for MPI include having at least one director who is a Singapore resident under the Companies Act, as well as competent executive-level personnel able to manage risks. For compliance, local roles are critical: a compliance officer and an AML officer available to MAS for interaction.
- MAS Fit and Proper test. The regulator applies Fit and Proper to directors, key managers and beneficiaries. They assess business reputation, experience, integrity, financial soundness and track record. The COREDO team prepares dossiers according to the MAS Guidelines on Fit and Proper Criteria and organizes a pre‑submission with the regulator to clear questions in advance.
- Capital requirements for MPI and financial resources. For Major PI there is a minimum paid-up capital at a level commensurate with the risk profile of the services, usually not less than SGD 250,000. Additionally MAS may request a security deposit in a range that depends on the class of services and volumes. We model liquidity stress scenarios and capital adequacy in advance.
- AML/CFT requirements for MPI and KYC processes. The applicant must demonstrate a full AML/CFT program: policies, CDD/EDD, sanctions screening, transaction monitoring, SAR, staff training. KYC requirements when obtaining MPI include risk-based approach, procedures for B2B and B2C, a PEPs policy and independent verification.
- Technological and operational readiness. MAS assesses information security, compliance with TRM Guidelines, the presence of an ISO 27001/PCI DSS roadmap, BCP/DRP plans and incident response. We link this to operational SLA, latency, throughput and resilience.
How to obtain a license MPI in Singapore
The action plan used by the COREDO team is based on MAS regulatory practice and the real lifecycle of a payments startup.
- company registration in Singapore (ACRA) and basic substance. We form the board of directors, appoint a local director, determine the office and key roles. From the very start we plan economic substance: functions, staff, and on-site decision-making.
- Pre-submission session with MAS (pre‑submission). I initiate meetings with the regulator to align the business model of the MPI payment operator, the scope of services under the PSA, target markets, KYC/KYB processes and the team’s knowledge. This reduces the risk of fundamental pivots at late stages.
- Preparation of a business plan and financial model for MPI. At COREDO we work out unit economics (MDR, interchange, FX margin), TCO, NPV and payback for the MPI license. The model covers scenarios of volume growth, take‑rate, churn, CAPEX on technology, OPEX on compliance and the staffing structure.
- Compliance design. We create an AML/CFT program, CDD/EDD procedures, a sanctions screening policy, risk assessment (RBA), a governance matrix and an independent ininternal audit. For crypto‑services we take into account VASP/DPT requirements and legal risks when working with tokenized assets.
- Technology stack. We design the API gateway and microservices architecture, define latency and throughput targets, plan horizontal scaling and sharding, implement a PCI DSS/ISO 27001 roadmap, and build in fraud detection and transaction monitoring.
- Application process to MAS for an MPI license. We prepare the full form, attachments on directors and beneficiaries, technological and compliance descriptions, contractual models with outsourcing providers and cloud hosting, and policies on data residency and GDPR.
- Responses to MAS queries, interviews and fit‑and‑proper checks. We separately work on third‑party risk management, outsourcing compliance and cloud risks. It is important to document control and access to data, and to conduct Due Diligence of suppliers.
- Setting up banking relationships and integrations. We build relationships with acquiring banks and correspondents, define settlement cycles, liquidity management and schemes for PayNow and FAST (through a sponsor bank or an approved operator), and finalize SLAs.
- Post‑licensing readiness. We update BCP/DRP, the incident response plan, prepare for an on‑site MAS inspection, launch continuous monitoring and internal audit. We implement KPI dashboards for compliance and operations.
Cost, TCO and ROI
financial transparency begins with a detailed TCO. In our calculations we include government fees (application and annual fees for each type of service), security deposit, capitalization, expenses for the technology stack, PCI DSS/ISO 27001 compliance, salaries of key roles, external audit and internal control.
MPI business model: products and liquidity
An MPI license for a remittance operator opens a solid foundation for cross‑border transfers, wallet top‑ups, payouts to local banks and merchant acquiring. The ability to issue e‑money under MPI adds flexibility in B2C onboarding and building savings products.
In the technology roadmap there is room for merchant onboarding and KYC processes for sellers, transaction risk‑scoring, anti‑fraud and chargeback analytics. COREDO practice confirms that an API‑first approach and clear SLOs for latency reduce operational disruptions and improve merchant conversion.
AML/CFT, KYC/EDD and sanctions screening
MAS expects a comprehensive AML/CFT program for payment providers. I always start with an enterprise‑level risk assessment (RBA), covering geographies, products, channels, abuse typologies and customer profiles, including PEPs and high‑risk.
Next we form CDD processes for B2C and KYB for corporate clients, including beneficial ownership and transparency. Best practices for KYC/EDD in the B2B and B2C segments under MPI include eKYC with biometrics, automated sanctions screening against OFAC/UN/EU, adverse media and monitoring of changes in customer status in near real‑time.
PCI DSS technologies and BCP/DRP
Information security requirements for MPI, ISO 27001 as a management system, PCI DSS for card processing, and, where appropriate, SOC 2 for partner trust. Preparing the technology stack and APIs for PCI/PSA compatibility increases the chances of quick approval.
The incident response and business process recovery plan for MPI is formalized as a BCP/DRP with testing. I specifically insist on regular chaos tests, RTO/RPO metrics and an inventory of critical dependencies. This ensures real, not declarative resilience.
Local economic substance of outsourcing
How to ensure economic substance for MPI in Singapore: a real question for MAS. The solution lies in a combination of an office, management functions, local compliance and operations that take place on the territory of the country. The COREDO team helps determine the set of functions that truly create value and embed them in the organizational structure.
Outsourcing and risk management of third parties for MPI require contractual KPIs, audit rights, exit‑strategies and data governance. We align cloud hosting with MAS outsourcing and TRM requirements, considering data residency, cross‑border access and GDPR for EU customer personal data.
Reporting and internal audit requirements for MPI imply an independent assessment of the effectiveness of AML/CFT, information security and operational controls. For mature teams I recommend an annual independent review, which MAS views positively.
MAS: from sandbox to on‑site inspections
Regulatory interaction is better built proactively. Pre‑submission meetings with MAS help clarify PSA interpretations and the scope of services, and the MAS regulatory sandbox is a useful track for innovations if a product requires a testing period.
The procedure for changing license conditions and expanding activities requires separate approvals. The solution developed at COREDO includes a governance process for change management so that any new product is brought into the scope of regulatory analysis in advance.
European regulation and expansion
The impact of PSD2 and European regulation on MPI models for expansion is expressed in requirements for open APIs, SCA and third‑party management. The COREDO team aligns security and compliance standards to avoid duplication of costs and speed up time‑to‑market.
Managing currency risks and FX‑hedging for multicurrency settlements is important when launching cross‑border produktov. We use a combination of NDF/forwards and internal exposure limits to maintain margin and the SLA for execution.COREDO Case Studies: How It Works
Another project was a payments aggregator for marketplaces, where the business model required merchant acquiring and issuing e‑money balances for sellers. The solution developed at COREDO combined a PCI DSS‑compliant architecture, KYB onboarding with eKYC and sanctions screening, as well as a roadmap for ISO 27001. MAS approved the model on the condition of an independent internal audit after 12 months, for which we prepared the client.
KPIs for Scaling
The term and renewal conditions of an MPI license depend on compliance with reporting and inspection outcomes. Post‑licensing MAS reviews focus on incidents, outsourcing and changes to the business model. COREDO’s practice confirms that regular training and a compliance culture reduce operational risks and speed up the approval of new initiatives.
Exit scenarios from the MPI business and portfolio transfer require pre‑defined options: portfolio sale, merger, license surrender. We work through legal and operational steps to protect clients and partners for any strategic decision.
Pre‑submission Checklist
Before clicking “submit” to MAS, I go through an internal checklist. This approach saves weeks of back-and‑forth and prevents critical failures.
- Business model: PSA services are clearly described, target markets and FX risks are justified, the financial model confirms sustainability.
- Ownership and Fit and Proper: the structure is transparent, sources of funds are verified, directors’ and beneficiaries’ dossiers are complete.
- AML/CFT: the RBA is complete, CDD/EDD procedures are ready, sanctions screening is configured, SAR processes are tested.
- Technology: architecture is documented, PCI DSS/ISO 27001 roadmap in progress, TRM controls mapped, BCP/DRP tested.
- Outsourcing: contracts include audit rights, SLAs and exit clauses, supplier due diligence completed.
- Banking relationships: draft agreements with acquirers/correspondents are agreed, settlement and liquidity calculated.
- Documents for MAS: forms, attachments, policies and reports are up to date, answers to expected queries are ready.
How COREDO Strengthens the Project
I structure support so that the client sees a clear trajectory. First, the strategic choice between Standard PI and MPI, assessment of the time horizon, costs and risks. Then, creating substance and organizational design, preparing the business plan and financial model, the compliance program and the technology project.
The COREDO team integrates regulatory experience, product analytics and security engineering practices. We engage vetted CaaS providers, regtech platforms, auditors and payment infrastructure. At the final stage we support the dialogue with MAS, prepare for on‑site inspections and help launch operational reporting.
MPI in Singapore: a Strategic Asset
The COREDO team has guided clients through the full cycle: from ACRA registration and pre‑submission with MAS to integration with PayNow/FAST and on‑site inspections. We see how a Payment Services Act (PSA) Singapore license turns into sustainable volume growth, predictable margins and partner trust across Asia and Europe. If you are considering the MPI path, embed risk management, economics and technology from day one, and licensing will become a catalyst for scaling rather than a brake.
I’m ready to discuss your business model, align it with MAS requirements and assemble a roadmap — from application to first transactions. At COREDO we value entrepreneurs’ time and focus, so every decision is tied to metrics and every document serves a real purpose: to accelerate the product’s route to market and maintain quality at international standards.