Coinbase is the one of the world's largest cryptocurrency exchange, providing an easy and secure place to buy, sell, and manage digital currency. It has over 56 million users across 32 countries worldwide including Singapore.

In January 2020, the Monetary Authority of Singapore (MAS) implemented the Payment Service Act (PSA), a comprehensive regulatory framework for companies handling activities relating to digital assets. The new ruling means cryptocurrency-related services such as Coinbase need to obtain licenses from MAS to continue their operations in Singapore.

One of the challenges faced by Coinbase was the lack of policies and procedures that are localised to suit the requirements of MAS. They also do not have in-house security compliance personnel or a team to assist in the application process.

Over a period of 2 months, Pragma provided advisory support in Coinbase's PSA application process in the aspects of security compliance and responding to questions related to technology risks raised by the authorities.

Given the complexity of the project and lack of an in-house security compliance team within Coinbase, Pragma worked closely with the client's Legal Counsel, Head of Compliance and Director for Security and Privacy to leverage their existing global policies and procedures, as well as align their service level agreements to meet MAS compliance requirements. We also interpreted the Act to ensure it's applicable for cryptocurrency exchanges.