Disruptive trends taking place in the payment services sector such as the surge in fintech innovation and the entry of non-financial players into the payments space have driven the shift towards more innovative forms of making payment such as through the use of digital wallets, online payment platforms and virtual wallets.

These developments have given rise to concerns on two levels:

• Firstly, the rise of new and innovative payments solutions has led to concerns over increased risks in areas such as money laundering, technology cybersecurity and interoperability.

• Secondly, the proliferation of retail players in the payments space has led to the possible disintermediation of banks from the payments value chain. In particular, where payment services are embedded with retail services and banks are not able to effectively compete.

Such concerns, in turn, have led to proposals to change the existing regulatory frameworks. This Update examines the proposed changes including the draft Payment Services Bill, and proposed refinements to the anti-commingling framework for banks in Singapore.

If you have any queries or would like to know more about how these changes may impact you, please contact:


Elaine CHAN
Joint Head – Financial Services Regulatory Practice
Partner - Asset Management & Funds Practice
d +65 6416 8010
e elaine.chan@wongpartnership.com
Click here to see Elaine’s CV.