MAS Consultation Paper: New Regulatory Sandbox



MAS Consultation Paper: New Regulatory Sandbox

A photo of the Monetary Authority of Singapore

Date Published: 20 November 2018

Authors and Contributors: Quek Li Fei, Mike Chiam, Samuel Ling, and Adrian Toh.


On 14 November 2018, the Monetary Authority of Singapore (“MAS”) released a consultation paper “Sandbox Express” as part of its actions after reviewing its experience gained from the FinTech Regulatory Sandbox launched by MAS in 2016, proposing to improve the management and processing of sandbox applications. Sandbox Express comprises a set of pre-defined sandboxes for the following services:

  1. Insurance broking;
  2. Recognised Market Operators (RMOs); and
  3. Remittances.

MAS has proposed the creation of Sandbox Express with the objective of:-

  1. providing enterprising Fintech companies with a faster option to bring innovative financial services or products to market for testing; and
  2. to reduce the time and resources required of the applicants.

Click here to access the MAS Consultation Paper of 14 November 2018.

MAS will assess applications based on two (2) criteria – (a) whether the applicant’s key stakeholders are “fit and proper” (note: In deciding this, MAS will take into account the factors in the MAS Guidelines on Fit and Proper Criteria [Guideline No. FSG-G01]), and (b) technological innovativeness of the financial service or product.


Faster Approvals

MAS will endeavour to complete the assessment of the application and respond to the applicant within 21 days from the date of receiving the application.

In addition, for applications that are deemed by MAS to be complex and require more time to assess, MAS may decide not to consider the application under the Sandbox Express and instead assess it under the existing Fintech Regulatory Sandbox scheme.

For approved applications, information on the pre-defined sandbox entities and their activities will be published on the MAS website. MAS reserves the right to withdraw any approval of the application at any time, for example, if the entity is conducting an activity that is not permitted under the specific pre-defined sandbox.

The public consultation phase for the Sandbox Express will conclude on 13 December 2018.

Disclaimer: This update is provided to you for general information and should not be relied upon as legal advice.


CNPLaw’s Blockchain, Cryptocurrency and Initial Coin Offerings (ICOs) Lawyer

Quek Li Fei Legal Partner at CNPLaw LLP image


    In addition to Li Fei’s experience in acting for banks on varied transactions and in general corporate law, he also helps individuals in estate planning, including the legal aspects of wealth management, advising on and setting up trusts and off-shore structures to secure their future and the future of their families. Li Fei is also recognised as a Recommended Lawyer for Banking and Finance and Financial Services Regulatory by The Legal 500 Asia Pacific 2021.

    We have a particular passion and interest in blockchain technology applications, cryptocurrencies and ICOs. We currently advise issuers of tokens, ICO advisors, venture capital firms and entrepreneurs involved in this space on Singapore legal issues and regulatory compliance for a range of planned business activities, ranging from utilization of blockchain to enable business applications in diverse fields (including money remittance, solar energy, consumer rewards, structured social interaction; music and entertainment industry; holiday & leisure industry; employment marketplace, consumer rewards, crypto-asset security applications); to setting up cryptocurrency exchanges and issue of tokens on proprietary platforms.