Updates to StraitsX's General Terms & Conditions

Additional Definitions

• Clause 3.1.23 of the General T&Cs: Updated the definition of “Merchant Account” to expand its scope to merchant acquirers, include StraitsX E-money as a supported payment instrument, and clarify the types of assets that may be accepted and withdrawn through the account.
  
  
• Clause 3.1.47 of the General T&Cs: Updated the definition of “StraitsX Accounts” to expressly include any StraitsX Internal Account within the accounts that StraitsX may introduce from time to time.
  
  
• Clause 3.1.48 of the General T&Cs: New definition. A “StraitsX Internal Account” is any internal user profile, internal record, ledger entry, or internal wallet (including any purpose-bound money or settlement wallet) that StraitsX creates and maintains solely for its own record-keeping, processing, reconciliation, or settlement purposes in connection with the StraitsX Services, and which (a) you cannot access, operate, or control; (b) you cannot use to initiate or execute any payment transaction; and (c) in which you hold no balance, claim, or proprietary interest.
  
  
• Clause 3.1.57.4 of the General T&Cs: Updated the definition of StraitsX Services to refer to “making or receiving any payment, transfer, or remittance (including a PayNow Scan-and-Pay Service).”

Your Instructions and Authorisations

• Clause 5.2.1 of the General T&Cs: Updated the clause to streamline references to the persons whose instructions StraitsX may act upon.
  
  
• Clause 5.3 of the General T&Cs: Expanded the clause to provide additional clarity on the treatment of instructions originating from a StraitsX Account or an account with a third-party platform, including in certain circumstances involving unauthorised or fraudulent activity.

Attached Bank Account

• Clause 6.1 of the General T&Cs: Updated the clause to refer to transfer/remittance transactions instead of remittance transactions.

Your Errors

• Clause 8.1.1 of the General T&Cs: Updated the clause to refer to transfers, payments, and remittances instead of remittances and third-party payments.
  
  
• Clause 8.4 & 8.5 of the General T&Cs: Updated the clause to refer to onward transfer/remittance transactions instead of onward remittance transactions.

Restricted Activities

• Clause 9.1.31: Expanded the clause to prohibit opening, maintaining, or operating a StraitsX Account on behalf of, or for the benefit of, another person, including allowing the account to be used as a conduit for another person’s funds or transactions.
  
  
• Clause 9.1.32: New clause prohibiting you from allowing any third party to access, control, or operate a StraitsX Account, or disclosing account credentials, authentication details, access tokens, or other means of access to any third party (unless otherwise authorised).

Limitations of Liability

• Clause 21.1.10: Added a clause covering loss or liability arising from any act, omission, instruction, or transaction of any Authorised User or other person granted access to or control over a StraitsX Account or Services, including where such act, omission, instruction, or transaction exceeded the person's assigned permissions or was not in fact authorised by the account holder.
  
  
• Clause 21.1.12: Updated the clause to expand the scenarios in which StraitsX is not liable for unauthorised access or transactions arising from a user’s failure to comply with their security obligations, including in relation to credential security, MFA, third-party account access, and device integrity.
  
  
• Clause 21.1.16: Updated the clause to clarify that the monitoring obligation includes verifying that completion notifications match the user’s instruction and notifying StraitsX where a completion notification is not received within the expected timeframe.

Additional Terms & Conditions Relating to StraitsX Accounts

Service Description

• Clause 1.1.4: Update the clause to refer to a StraitsX Internal Account, which may be created to process transaction instructions issued to StraitsX via a third-party platform and to hold funds solely for StraitsX’s record-keeping, reconciliation and settlement purposes.

Authorised User & Linking a Debit Card to StraitsX Digital Assets Account

• Clause 3.1: New clause containing a user acknowledgement that granting, allowing, or facilitating third-party access to or control of a StraitsX Account (other than through a validly appointed Authorised User) constitutes a Restricted Activity and a breach of the T&Cs.
  
  
• Clause 3.2: Updated the clause to add “for corporate entities” as an example of when the authorised user provision is applicable.
  
  
• Clause 3.3: Updated the acknowledgement to include the risks associated with allowing another person to operate or transact on a StraitsX Account, including the risk of improper authorisation or execution of instructions.

User Obligations

• Renamed heading: Updated the section heading from “Safeguarding your StraitsX Accounts ID, password and API keys” to “Safeguarding access to your StraitsX Accounts”.
  
  
• Clause 13.1: Updated the clause to broaden the scope of the user’s security obligations to cover both credential security and third-party access control, and to expressly apply regardless of whether any failure was deliberate, inadvertent, negligent, or induced by deception, phishing, or social engineering.
  
  
• Clause 13.2: New clause consolidating the previous sub-clauses on credential protection, confidentiality, and code record-keeping into a single sub-clause.
  
  
• Clause 13.4: New clause prohibiting the granting or allowing third-party access to or control of StraitsX Accounts, Services, or devices, including through remote-access or screen-sharing software.
  
  
• Clause 13.5: New clause requiring the user to access StraitsX Services only through official StraitsX channels and not to enter credentials on any non-official channel.
  
  
• Clause 13.9: New clause requiring the user to verify the authenticity of any communication before acting on it, including confirming it originates from an official StraitsX channel, with no presumption of authenticity for content on social media or other non-official channels.

Additional Terms & Conditions Relating to Payments, Transfers or Remittance

Service Description

• Clauses 1.1: Updated the clause to reflect the current suite of StraitsX Services and supported payment instruments including the PayNow Scan-and-Pay Service.

Payments/Transfers/Remittance

• Clause 2.1: Updated the clause to expand the scope from remittance services to StraitsX Services broadly, including payments, transfers, and the PayNow Scan-and-Pay Service.
  
  
• Clause 2.2: Updated the clause to expand the scope from remittance services to StraitsX Services broadly, including payments, transfers, and the PayNow Scan-and-Pay Service.
  
  
• Clause 2.3: Updated the clause to remove the statement that a StraitsX Account is created specifically for remittance onboarding; account creation is now addressed in clause 2.7.
  
  
• Clause 2.4: Updated the clause to clarify that instructions may be given through a StraitsX interface embedded within the third-party platform or otherwise.
  
  
  • Clause 2.4.1: Expanded the clause to include additional funding sources including funds remitted by a third party on the user's behalf (in addition to the user's Attached Bank Account), and expanded the recipient to any third party (e.g. a PayNow merchant).
    
    
• Clause 2.5: Updated the clause to clarify the nature of the relationship between the user, StraitsX, and the third-party platform, including that each instruction is given directly by the user, the third-party platform acts only as a technical conduit, and the third-party platform is not StraitsX’s agent and does not control or instruct StraitsX on the user's behalf.
  
  
• Clause 2.6: New clause governing the PayNow Scan-and-Pay Service, covering how payments are initiated, the standing instruction mechanism, transaction restrictions (domestic SGD, Singapore location, UEN merchants only), StraitsX’s right to decline payments, and the independent nature of the service.
  
  
• Clause 2.7: Updated the clause to introduce the StraitsX Internal Account, an account type that may be created for users, and to clarify its purpose, the types of funds it may hold, and that the user has no access to, control over, or claim to it and that it is not a payment account under the Payment Services Act.
  
  
• Clause 2.8: Updated the clause to expand the scope from the StraitsX remittance service to StraitsX Services broadly, including the PayNow Scan-and-Pay Service.
  
  
  • Clause 2.8.1: Updated the clause to refer to the StraitsX Internal Account instead of StraitsX Account, and to expand the scope of any restriction from remittance services to any StraitsX Service.
    
    
• Clause 2.9: Updated the clause to replace remittance-specific references with references to StraitsX Services broadly.
  
  
• Clause 2.10: Updated the clause to refer to transactions broadly instead of remittances, and to expand possible recipients from third-party platforms to third parties to whom the user sent, or from whom they received, the payment, transfer, or remittance, with PayNow merchants as an example.
  
  
  • Clause 2.10.1 & 2.10.2: Updated references from "third-party platform" to "third party.
    
    
  • Clause 2.10.3: Updated the clause to simplify and broaden the description of covered discrepancies, removing the specific reference to onward remittance to the user’s Attached Bank Account.

Sending Payments/Transfers/Remittance

• Clause 3.1: Updated the clause to include a third-party platform as an additional originating source for payments, transfers, or remittances.
  
  
  • Clause 3.1.3: Updated the clause to include a merchant’s account with a PayNow member institution as an example of a third-party bank account recipient.
    
    
• Clause 3.2: Updated the clause to refer to payment/transfer/remittance transactions broadly instead of remittance transactions only, and added a specific SGD 20,000 per-transaction limit for the PayNow Scan-and-Pay Service.
  
  
• Clause 3.4: Minor capitalisation fix (“Credit card” → “credit card”).
  
  
• Clause 3.11: New clause requiring the user to complete any additional authentication required (including one-time passwords or two-factor authentication) before StraitsX processes any payment, transfer, or remittance above prescribed thresholds, and specifying that transaction signing is required for PayNow transactions above S$1,000 in accordance with the PayNow Scheme Rules.
  
  
• Clause 3.12: Updated the clause to remove the list of asset types subject to review and replaced it with a reference to PayNow transactions triggered via the PayNow Scan-and-Pay Service as an example of transactions that may be subject to review.
  
  
• Clause 3.14: Updated the clause to include PayNow transactions triggered via the PayNow Scan-and-Pay Service as an example of a failed outbound transaction, clarified the deduction of bank fees, and replaced “remittance” with “payment/transfer/remittance” throughout for consistency.

Receiving Payments/Transfers/Remittance

• Clause 4.1: Updated the clause to add a reference to Merchant Account Users as an example of a user who may receive payments, and minor drafting fixes.
  
  
• Clause 4.8: Updated the clause to replace “remittance instruction” with "payment/transfer/remittance instruction" for consistency.
  
  
• Clause 4.10: New clause setting out user obligations in connection with the use of any PayNow capability provided by StraitsX, including compliance with the PayNow Scheme Rules, QR code specifications, surcharge prohibitions, sub-distribution restrictions, proxy registration requirements, and branding guidelines.

Additional Terms & Conditions Relating to StraitsX Data Privacy Policy

• Clause  6.1.6: Amended the clause to expand the list of third parties StraitsX may disclose Personal Information to, including law enforcement, government officials or other third parties that may include authorities outside your country of residence as well as the list of permitted purposes for disclosure, including assisting in the prevention, detection, investigation or prosecution of any actual or suspected illegal activity.
  
  
• Clause 6.1.8: Renumbering fix.