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Is an electronic wallet (e-wallet) top up service considered an account issuance service?
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Source: https://www.mas.gov.sgMAS has observed that there are businesses offering e-wallet top up services. This is usually where the service provider (Business X) accepts money from a customer for the purpose of sending the money to an e-wallet operator, so that the e-wallet operator can top up the customer’s payment account.
Business X does not provide an account issuance service because it does not operate the payment account and top up the payment account. Instead, it only hands over the money to the e-wallet operator.
Business X would however be providing an account issuance service in a situation where Business X (rather than the e-wallet operator) operates the payment account and tops up the payment account. In that situation, Business X will need to hold a licence to provide an account issuance service, unless it is exempted.
This information provided here is sourced from the MAS website.
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