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26 August, 2019
The Monetary Authority of Singapore (“MAS”) launched Sandbox Express on 7 August 2019 to provide firms with a faster option to test innovative financial products and services in the market.
What are the main benefits of the Sandbox Express?
Sandbox Express shortens the approval process for entry into the sandbox by relying on standard disclosures and pre-determined rules. Eligible applicants can begin market testing in the pre-defined environment of Sandbox Express within 21 days of applying to MAS instead of taking a longer time to customise their sandboxes under the existing FinTech Regulatory Sandbox.1
Who can apply to be in the Sandbox Express?
MAS will take a phased approach by starting with an initial set of activities regulated by MAS, and will continue to review whether appropriate constructs could be established to facilitate meaningful experiments for other regulated activities.
For a start, Sandbox Express will be available specifically for:
(a) insurance brokers;
(b) recognised market operators; and (c) remittance businesses.
What is the evaluation criteria?
Sandbox Express is only suitable for financial services or products which carry risks that can be reasonably contained by pre-determined, standardised sandbox constructs. 2 In submitting the application to enter the Sandbox Express, applicants agree to be bound by these sandbox constructs, which may be implemented as licence conditions or exemption conditions, depending on the type of sandbox.
Firms must comply with all conditions of approval including providing clear and proper disclosure to the customer as well as submitting regular progress reports to MAS.3
The sandbox constructs, application form and progress reporting form are available in the following annexes:4
(a) Sandbox constructs (Annex A);
(b) Application form (Annex B); and
(c) Progress reporting form (Annex C).
What is the duration of the Sandbox Express?
Experiments can remain in Sandbox Express for up to nine (9) months.
For further information, please contact:
Stephanie Magnus, Principal, Baker & McKenzie.Wong & Leow
stephanie.magnus@bakermckenzie.com
1 For applications that are deemed by MAS to be complex and require more time to assess, MAS may notify the applicant within twenty-one (21) days from the date of receipt of the application that MAS will not consider the application under Sandbox Express and will instead treat it as an application under the current FinTech Regulatory Sandbox.
2 The FinTech Regulatory Sandbox that was operational since 2016 remains open for applicants with more complex business models or where MAS requires more time to understand the risks of the activities.
3 The applicant is required to submit to MAS: (a) a progress report every two (2) months from the start of the approved period; and (b) a final progress report at the end of the approved period.
4 See “Annex A Sandbox Constructs”, “Annex B Application Form”, and “Annex C Progress Reporting Form” found under https://www.mas.gov.sg/development/fintech/sandbox-express.
