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Eunice Tan

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Eunice is a principal in the Financial Services Regulatory practice group of Baker McKenzie's Singapore office and a member of the Firm's Global Financial Services Regulatory Steering Committee. Eunice has extensive experience in regulatory, legal and compliance matters in the financial services and fintech sectors. Her clients include banks, investment managers, broker-dealers, payments companies and other financial institutions.
Eunice is consistently recognised as the Next Generation Partner for Financial Services Regulatory in Legal 500 Asia Pacific. Clients have described her as: “an exceptional lawyer with deep knowledge of financial services; "commercial and solutions-oriented and has an excellent relationship with the regulator which is of benefit to her clients"; "singled out for being smart and having the ability to navigate the Singapore regulatory landscape"; "is responsive, pleasant and willing to explore different parameters" and "is outstanding in that she always carefully and clearly explains the situation and background of the issue so that we can fully understand it, she always has a quick response and she has a deep understanding of the financial industry and our company."
Eunice is a frequent speaker at legal and financial industry seminars and forums. She also regularly assists clients in coordinating industry responses and participate in consultation with the Monetary Authority of Singapore on policy and legislative changes.

On 6 November 2024, the Monetary Authority of Singapore published its responses to the feedback on the July 2023 consultation paper that set out a proposed regulatory framework for Single Family Offices operating in Singapore. SFOs are exempt from licensing under the Securities and Futures Act 2001, and the proposals are aimed at harmonizing the criteria for a simplified class exemption regime and addressing potential money laundering risks posed by SFOs.
MAS will provide further details on the effective date of implementation, revised legislation and mode of submission for the initial notification and annual return prior to the implementation of the SFO framework.

On 24 October 2024, the Monetary Authority of Singapore (MAS) and Infocomm Media Development Authority of Singapore (IMDA) announced that the Shared Responsibility Framework (SRF) for phishing scams will be implemented on 16 December 2024 via a set of guidelines. Under the SRF, financial institutions (FIs) and telecommunication operators are assigned duties to mitigate phishing scams. The MAS and IMDA expect responsible entities to bear any scam losses arising from failure to fulfill any of the relevant duties under the “waterfall” approach.

On 4 October 2024, the Monetary Authority of Singapore (MAS) published the Consultation Paper on Proposed Regulatory Approach, Regulations, Notices and Guidelines for Digital Token Service Providers issued under the Financial Services and Markets Act 2022 (P010-2024) (“Consultation Paper”).
The Consultation Paper, which includes a number of Annexes, sets out the MAS’ proposed new regulatory framework for digital token service providers (DTSPs) that will be regulated under Part 9 of the Financial Services and Markets Act 2022 (FSMA). The MAS’ key proposals for the new regulatory framework for DTSPs center around licensing requirements, anti-money laundering and countering the financing of terrorism compliance, financial obligations and governance requirements

The Guidelines on the Provision of Consumer Protection Safeguards by Digital Payment Token Service Providers was first issued by the Monetary Authority of Singapore on 2 April 2024 and was recently revised on 19 September 2024 to include further consumer protection measures that were discussed in the MAS’ Response to Public Consultation on Proposed Regulatory Measures for Digital Payment Token Services (Part 2).

On 26 July 2024, the Monetary Authority of Singapore (MAS) updated the Guidelines on Licensing for Payment Service Providers (PS-G01), which became effective on 26 August 2024. These changes are applicable to current and future Standard Payment Institutions (SPIs) and Major Payment Institutions under the Payment Services Act (PSA).
The updates can be divided into those that relate to (i) the application process for a new MPI or SPI license or a variation of an existing license under the PSA; and (ii) those that relate to ongoing business conduct.

The Monetary Authority of Singapore (MAS) issued the revised Guidelines on Fair Dealing — Board and Senior Management Responsibilities for Delivering Fair Dealing Outcomes to Customers (“Guidelines”) on 30 May 2024.
This comes around 17 months after the MAS issued the Consultation Paper P013-2022, which proposed amendments to the Guidelines on Fair Dealing. The amendments widen the scope of the Guidelines to apply to all financial institutions (FIs) in relation to all products and services offered by FIs to users and prospective users, and introduce additional principles and guidance for selected areas.

The Monetary Authority of Singapore (MAS) issued the revised Guidelines on Fair Dealing — Board and Senior Management Responsibilities for Delivering Fair Dealing Outcomes to Customers (“Guidelines”) on 30 May 2024. This comes around 17 months after the MAS issued the Consultation Paper P013-2022, which proposed amendments to the Guidelines on Fair Dealing. The amendments widen the scope of the Guidelines to apply to all financial institutions (FIs) in relation to all products and services offered by FIs to users and prospective users (“Customers”), and introduce additional principles and guidance for selected areas.

On 28 March 2024, the Monetary Authority of Singapore (MAS) issued a response paper to feedback received on the repeal of the regulatory regime for registered fund management companies (RFMC).

MAS targets to repeal the RFMC regime on 1 August 2024. Existing RFMCs intending to continue with regulated fund management activity after this date must apply to be a licensed fund management company restricted to serving accredited and institutional investors.

Excerpt: This update focuses particularly on the expansion of scope to domestic money transfer services, cross-border money transfer services and digital payment token services, and examines who are the persons affected by such expansion, as well as what needs to be done by such affected persons in order to benefit from transitional arrangements and continue operations.