You can see the rules and regulations in other jurisdictions.
Singapore law does not permit 'passporting' of fintech firms and services. Just because a company is licensed in a foreign jurisdiction doesn't entitle it to engage in regulated activities in Singapore. Depending on the type and scope of the products and services it offers, an offering to persons in Singapore may require licensing from the local authorities.1
What happens if a fintech company does not specifically target Singaporeans with its fintech products or services? The licensing requirements under the FAA and the SFA may still be triggered as they have extraterritorial effect.1
"Where a person does an act partly in and partly outside Singapore which, if done wholly in Singapore, would constitute an offence against any provision of this Act, that person shall be guilty of that offence as if the act were carried out by that person wholly in Singapore, and may be dealt with as if the offence were committed wholly in Singapore."1
When considering licensing requirements, even if an act is done entirely overseas, the test is whether it has a 'substantial and reasonably foreseeable' effect in Singapore. No definitive rule can be provided and one factor to consider is that there has been no promotion of the fintech product or service to people in Singapore. This should be assessed on an individual basis.1
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