Most fintech questions in GMC come down to one issue: is what you do a regulated activity carried on by way of business, or is it software, infrastructure or a commercial arrangement that the Financial Services Act 2025 leaves alone? Get that wrong and you are either unlicensed or paying for a permission you never needed. Basnet Law Pte. Ltd. is the first law firm incorporated in GMC. We advise payment, lending, wealth and software businesses on where the GMC regulatory perimeter falls under the Financial Services Act 2025, and on getting the right Financial Services Permission from GFSO when one is needed. This page explains how the perimeter works and how we take a product through it.
How we help
- Perimeter opinions on Providing Money Services, defined as "currency exchange, Money Remittance or Payment Services", and on the carve-outs from Payment Services.
- Lending and buy-now-pay-later models against the Providing Credit and Arranging Credit activities.
- Robo-advice and wealth apps against Advising on Investments or Credit, Arranging Deals and Managing Assets.
- Software and infrastructure providers relying on the exclusions for arrangements that do not cause a deal, for enabling parties to communicate, and for order routing.
- Stablecoin and tokenised payment products under the Issuing a Fiat-Referenced Token activity.
- Licensing, Approved Persons and AML programme design under the Act and the AML and Sanctions rulebook.
- Electronic contracting and e-signatures under the Electronic Transactions Act 2010, applied in GMC by Schedule A to the Application of Laws Act 2024.
How GMC fintech regulation works, in plain terms
Fintech regulation in GMC starts with the General Prohibition in the Financial Services Act 2025: no person may carry on a Regulated Activity "by way of business in GMC" unless licensed or exempt. A person acts by way of business if the activity itself constitutes a business, if they hold themselves out as willing to engage in it, or if they regularly solicit others to transact.
Payments sit under the Providing Money Services activity. A Licensed Firm does not separately Provide Money Services where that is "in connection with and a necessary part of" another Regulated Activity it carries on. Cash transactions and direct transfers of a Fiat-Referenced Token between payer and payee are not Payment Services. Whether customer balances become Deposits depends on whether the money is lent to others or finances the business.
Software is not automatically regulated. Arrangements that "do not or would not bring about the transaction" are excluded from arranging, as is "merely providing means by which one party to a transaction... is able to communicate" with others. A pure order-routing system, where orders are transmitted but do not interact, is not a Multilateral Trading Facility. Suppliers whose main business is selling goods or services have further relief.
Every Relevant Person must comply with anti-money laundering obligations, conduct customer due diligence and maintain records as specified in the Rules. Financial promotions are restricted unless an exemption applies. On tax, computers and automation equipment attract accelerated allowances under the Income Tax Act 2025, and R&D expenditure is deductible.
Who this is for
- Payment and remittance companies entering GMC.
- Digital lenders and embedded finance providers.
- Wealth, trading and robo-advisory apps.
- Infrastructure, SaaS and data vendors serving Licensed Firms.
How an engagement runs
- Product walkthrough. We map each user flow and money flow to the regulated activities of the Act.
- Perimeter memo. A written analysis of the activities, the exclusions and the "by way of business" test, which you can show a bank or an investor.
- Licence strategy. Which permissions to seek, in what order, and the Approved Persons the GEN Rulebook requires.
- Application and IPA. Business model presentation, the application and the In-Principle Approval conditions, until the permission is granted.
- Build-out. AML programme, complaints handling and promotion review, so the firm is ready to trade on day one.
Frequently asked questions
Do I need a licence to run a payments app in GMC?
If you provide currency exchange, money remittance or Payment Services by way of business in GMC, yes. Some transaction types fall outside Payment Services under the Act's carve-outs, and we test each flow against them.
Is my SaaS platform for brokers a regulated activity?
Not merely because it enables communication between parties or transmits orders without interaction. If the platform brings about transactions, or holds itself out as arranging them, the Arranging Deals activity may apply. We put the answer in writing.
Can I hold customer funds in a wallet without a banking licence?
It depends on whether the funds are Deposits or are held in connection with Payment Services. The structure of the wallet, and whether balances are lent or used to fund the business, decides it, and we design the structure with that in mind.
Are e-signatures valid in GMC?
Yes. The Electronic Transactions Act 2010 applies in GMC through Schedule A to the Application of Laws Act 2024, with modifications, and under the Companies Act 2025 the Registrar may require transactions to be carried out through the electronic transaction system.
What AML obligations apply before launch?
The Act requires a Relevant Person to comply with AML obligations, conduct customer due diligence and keep records as specified in the Rules. The GEN Rulebook requires a Money Laundering Reporting Officer. We build the programme and help you appoint the officer before launch.
Talk to GMC counsel on the ground
Basnet Law Pte. Ltd. is the first law firm incorporated in the Gelephu Mindfulness City. A short conversation early in a matter usually saves time and cost later. Write to basnet@basnetgmc.com or office@basnetgmc.com with a few lines about your plans, and we will tell you plainly what is needed, how long it takes, and whether we are the right fit.
You may contact Basnet Law at basnet@basnetgmc.com or office@basnetgmc.com for any legal queries related to GMC.
