Gemini Gets Full MAS MPI License in Singapore

Gemini has secured a Major Payment Institution (MPI) license from the Monetary Authority of Singapore, completing a regulatory journey that began with an in-principle approval nearly two years ago. For accounting firms, CFOs, and auditors serving clients with Singapore crypto exposure, the grant signals a maturing local licensing regime and raises specific questions about client due diligence, counterparty classification, and the recordkeeping standards that now apply to any business touching a fully licensed digital asset venue in the city-state.

What the MAS Just Approved

MAS issued the MPI license to Gemini Digital Payments Singapore, the exchange's locally incorporated entity. The regulator's Financial Institutions Directory now lists the company as authorized to provide two regulated activities: digital payment token (DPT) services and cross-border money transfers.

MPI versus standard payment institution status

Singapore's Payment Services Act creates two tiers of payment institution licensing: standard and major. The threshold that matters is transaction volume. Standard Payment Institution licensees face caps on the value of transactions they can process; MPI licensees face no such ceiling. In exchange for that operational freedom, MPI holders are subject to a more demanding supervisory framework, because MAS takes the view that scale increases systemic risk. That asymmetry is worth understanding before onboarding any platform as a counterparty or custodian.

The path to full approval

Gemini has operated in Singapore since 2020. Its local regulatory journey involved three distinct phases that accounting professionals should map carefully when reconstructing a client's transaction history:

• Initial operations under an exemption held by Gemini Trust Company, the US parent entity.
• An in-principle approval from MAS, granted roughly two years before the full license.
• A migration of Singapore customers in April 2025 from the exempt entity to Gemini Digital Payments Singapore, the locally incorporated vehicle, while the final application was pending.
• Full MPI license awarded in September 2026, after the formal application was filed in October 2024.

Each of these transitions potentially changed the legal counterparty on a client's account. For firms preparing financial statements or tax filings that reference historical Gemini Singapore transactions, verifying which entity held the account at any given date is not optional; it affects how you identify the regulated party and assess the adequacy of the AML/KYC controls that were in place at the time.

Regulatory Implications for B2B Professionals

Counterparty due diligence just got cleaner

When a digital asset exchange holds a full MPI license from MAS, a licensed regulator with a robust supervisory track record, accounting firms and corporate treasury teams have a cleaner due diligence baseline. MPI licensees must comply with MAS's Notice PSN02 on AML/CFT for DPT service providers, which mandates customer due diligence, transaction monitoring, suspicious transaction reporting, and record retention. Knowing that your client's Singapore exchange counterparty operates under that regime simplifies the third-party risk section of your workpapers.

That said, a license does not eliminate the need for your own controls. Firms should still obtain confirmation of the MPI status directly from the MAS Financial Institutions Directory rather than relying on a platform's self-representation, and should document that check in the client file.

Cross-border money transfer authorization: the treasury angle

The MPI license covers not just DPT services but also cross-border money transfers. For corporate clients using Gemini Singapore as part of a treasury or liquidity management workflow, this dual authorization matters. It means the entity is regulated for both legs of a transaction that converts crypto to fiat and transfers the proceeds internationally. Under Singapore's AML rules, the platform must apply correspondent-bank-equivalent due diligence on those flows. CFOs and their finance teams should factor this into their documentation of banking and payment rails, particularly where group treasury policies require evidence of the regulatory status of every institution in the payment chain.

Audit and assurance considerations

For auditors signing off on client financial statements that include digital asset balances held at or transacted through Gemini Singapore, the full MPI status now provides a cleaner regulatory anchor. Prior to the April 2025 customer migration, those balances were technically held under an exemption arrangement. Auditors reviewing periods that straddle the migration date should confirm: which entity held custody, whether the client received formal notification of the transfer, and whether any terms of service changes affected the accounting classification of the assets (for example, whether the arrangement shifted from a commingled to a segregated custody model, which can affect whether the assets appear on or off the client's balance sheet under FRS 38 or equivalent standards).

Crypto accounting software and the Singapore licensing dataset

Firms using crypto accounting software to classify exchange transactions need their tooling to correctly identify the regulated entity behind each API connection or CSV import. Now that Gemini Digital Payments Singapore is the licensed entity for Singapore customers, any data pipeline that still references Gemini Trust Company as the counterparty is producing a legally inaccurate record. This is a data hygiene issue that should be addressed proactively, especially for clients whose books cover the April 2025 migration window.

AML and KYC: What Changes on the Ground

Enhanced obligations for MPI licensees

MAS has been explicit: MPI status comes with more comprehensive regulation precisely because the absence of volume caps means these platforms can grow to a scale that poses systemic risk. The supervisory obligations MPI holders face include stricter capital adequacy requirements, enhanced AML/CFT controls, and regular independent audits of their compliance frameworks. For firms advising clients who are institutional counterparties of Gemini Singapore, such as OTC desks, custody clients, or corporate traders, this is relevant context when assessing the adequacy of a counterparty's controls under your own firm's AML policy.

The customer migration as an AML event

When Gemini migrated Singapore customers from the Trust Company entity to the locally incorporated entity in April 2025, that transfer was, from a compliance standpoint, an account re-papering event. MAS rules require that DPT service providers maintain up-to-date KYC records and conduct periodic customer reviews. If a client's KYC was refreshed as part of that migration, there should be documentation. Firms conducting AML reviews or preparing SAR-adjacent analysis for Singapore-exposed clients should ask whether the client has records of the re-papering notice and any updated terms.

What Singapore's Crypto Licensing Landscape Signals

Gemini's full license is the latest data point in a consistent MAS posture: Singapore will license credible, well-capitalized exchanges, but the process is deliberate and the obligations are real. MAS has previously licensed other major venues and has also refused or revoked licenses where standards were not met. The two-year gap between in-principle approval and full MPI status for Gemini reflects the depth of the assessment MAS conducts, not a rubber-stamp process.

For accounting and audit professionals, the practical read is this: Singapore is building a licensing registry that can serve as a reliable reference point when classifying exchange counterparties. The MAS Financial Institutions Directory is a public, searchable resource. Making it a standard step in client onboarding and annual compliance reviews is straightforward and defensible.

Gemini itself has been expanding its regulatory footprint globally. Its Singapore MPI license sits alongside regulatory approvals it holds in other jurisdictions, including registration with the US Commodity Futures Trading Commission. That multi-jurisdictional profile is increasingly relevant for group-level consolidation work, where a parent entity's regulatory status in one jurisdiction can affect the risk classification applied to its subsidiaries in another.

Practical Steps for Accounting Firms and CFOs

Immediate actions

The following steps are worth taking now, rather than waiting for an audit cycle to surface the issue:

• Verify the MPI status of Gemini Digital Payments Singapore on the MAS Financial Institutions Directory and retain a dated screenshot or export in the client file.
• Review any historical transaction records that reference Gemini Singapore to confirm the correct legal entity is identified for each period: Gemini Trust Company (pre-April 2025), Gemini Digital Payments Singapore (post-April 2025).
• Check whether your crypto accounting software or digital asset accounting software correctly maps the Singapore entity, and raise a support ticket or manual override if it does not.
• Update counterparty risk assessments for clients using Gemini Singapore for custody, OTC, or cross-border transfers, noting the MPI license grant date and the enhanced supervisory obligations it carries.
• If you are an auditor, confirm whether the April 2025 migration generated any updated custody agreements or terms of service that affect the accounting classification of digital assets held at Gemini Singapore.

Longer-term bookkeeping and reporting considerations

Singapore-based clients with ongoing Gemini relationships should ensure their crypto bookkeeping software is configured to pull transaction data from the correct entity identifier. Any FRS 38-based intangible asset accounting or fair-value disclosures that reference exchange prices sourced from Gemini Singapore should document that the price source is now a fully MPI-licensed venue, which strengthens the reliability argument for using those prices as a market reference.

For group consolidations involving a Singapore subsidiary that uses Gemini as its primary digital asset venue, the MPI license status is relevant disclosure context in the related-party and financial instruments notes, particularly where group policy requires disclosure of the regulatory environment of significant counterparties.

Firms advising on licensing and AML controls in Singapore may also want to revisit whether their own crypto compliance policies reference the PSA licensing tiers explicitly, and update them to reflect that MPI holders carry a distinct and more demanding regulatory profile than standard licensees or exempt entities.

Frequently Asked Questions

What is a Major Payment Institution license under Singapore's Payment Services Act?

An MPI license is the higher of two payment institution license tiers under Singapore's Payment Services Act. Unlike a standard payment institution, an MPI holder faces no transaction-volume caps but must meet more stringent capital, AML/CFT, and operational requirements set by MAS. The license is required for any entity that regularly exceeds the thresholds set for standard licensees or that chooses to operate without volume restrictions.

Which entity holds the MAS MPI license for Gemini in Singapore?

The license was issued to Gemini Digital Payments Singapore, the locally incorporated entity. This is distinct from Gemini Trust Company, the US parent entity under which Singapore customers originally operated. The customer migration from the Trust Company to the local entity took place in April 2025.

How does this affect the AML/KYC obligations of firms that use Gemini Singapore as a counterparty?

It does not remove your own AML obligations, but it does strengthen your due diligence baseline. MPI licensees must comply with MAS Notice PSN02, which mandates customer due diligence, transaction monitoring, and record retention. You should verify the license status independently via the MAS Financial Institutions Directory and document that verification. Your counterparty risk assessment should also note the April 2025 entity migration and confirm that the client's KYC records reflect the correct legal counterparty from that date onward.

Should historical Gemini Singapore transactions be re-classified in the books?

Not necessarily reclassified, but the legal entity recorded as counterparty should be accurate for each period. Transactions before April 2025 were with Gemini Trust Company under an exemption. Transactions from April 2025 onward are with Gemini Digital Payments Singapore under the MPI license. If your records do not reflect this distinction, update them and note the basis for the correction. The accounting treatment of the underlying assets is unlikely to change, but the accuracy of the counterparty record matters for AML documentation and audit trail purposes.

Is the MAS Financial Institutions Directory a reliable source for verifying crypto exchange licensing?

Yes. The MAS Financial Institutions Directory is a publicly accessible, regulator-maintained database. It is the authoritative source for confirming whether a DPT service provider holds a current MPI or standard payment institution license in Singapore. Firms should use it directly rather than relying on a platform's self-reported status, and should retain evidence of the search date in their workpapers.

Source: Cointelegraph