Singapore Region Specific Terms

With respect to Services provided by Thunes Singapore, the following provisions shall apply and are included as part of the legally binding Agreement between you and Thunes:

1.      The following definitions shall be included in the Definitions to the Terms and shall have the following meaning in these Singapore Region Specific Terms unless the context requires otherwise:

Foreign Entity means any entity that is not incorporated, formed or registered in Singapore and does not carry on business in Singapore.

Foreign Individual means any individual who is not resident in Singapore

MAS means the Monetary Authority of Singapore.

PSA means the Payment Services Act 2019 of Singapore, associated regulations, notices, guidelines, codes of practices, as may be amended from time to time.

Relevant Money means any money received by Thunes Singapore (Thunes Asia Pte Ltd) from, or on account of a Customer in respect of its provision of its cross-border money transfer services, subject to certain prescribed exclusions and as defined under Section 23 of the PSA.

2.      A new Section 3(g) is included as follows:

3(g). Apart from Thunes Asia Pte Ltd, no other Thunes entity or Affiliate carries on the business of providing payment services under the Payment Services Act 2019 in Singapore. No other Thunes entity or Affiliate offers, promotes or advertises any payment services provided by Thunes or the Thune Group of companies in Singapore or to Singapore persons.

3.      The following shall be added to Section 7 as a new subparagraph (h):

7(h). Pursuant to Section 23 of the PSA, Thunes maintains a trust account with a relevant safeguarding institution (as Thunes may determine in its discretion from time to time – the Safeguarding Institution) in accordance with Applicable Law in which Thunes deposits all Relevant Money that it receives from or holds on account of its Customers. Such trust account shall be referred to as the Safeguarded Account.

4.      The following shall be added to Section 7 as a new subparagraph (i):

7(i). You acknowledge, understand and agree that: 

a.      The Relevant Money that we receive or hold on your behalf will be held in the Safeguarded Account.

b.      While the Relevant Money in the Safeguarded Account will be distinguishable and maintained separately from any other account where Thunes deposits its own moneys, your Relevant Money may be commingled with the Relevant Money that Thunes receives from or holds on account of its other Customers. Thunes will also deposit the Relevant Money that it holds for other Customers in the same Safeguarded Account. 

c.      Such commingling of your Relevant Money with the Relevant Money of other Customers in the same Safeguarded Account may give rise to some risks. While we will take steps to ensure that there are clear records kept and robust periodic reconciliation, some risks of such commingling may include: 

i.          In the event of insolvency of the Safeguarding Institution or Thunes, there is a risk that you may not be able to recover your Relevant Money fully;

ii.         There may be challenges in asserting your claims over the amount of Relevant Money held in the Safeguarded Account and there may be a risk of dispute among Customers; and

iii.        There may be delays in making a claim to recover your Relevant Money. This could occur if a liquidator freezes the entire Safeguarded Account.

You agree that Thunes may, notwithstanding any provision in the Agreement, withdraw your Relevant Money from the Safeguarded Account for any purpose permitted under Applicable Law.

5.      The following shall be included at the end of Section 7(b) 

You further acknowledge and agree that any interest earned from the maintenance of your Relevant Money in the Safeguarded Account will not accrue to you and will instead be retained by Thunes. Such interest will not constitute Relevant Money, and you will not be entitled to such interest.  

Last modified: July 21, 2026