Proposed Acquisition Of Shares Of SingCash Pte. Ltd. By MT Financial FZ-LLC

Reference:

CCS   400-140-2024-005

Notifying Parties:

MT Financial FZ-LLC

Notifying Date:

14 November 2024

Summary of transaction:

(i)       the names of the merger parties; 

·       MT Financial FZ-LLC (“MTFFZ”); and

·       SingCash Pte. Ltd. (“SingCash”) 

(collectively, the "Parties", each a “Party”).  

(ii)       a description of the transaction; 

The transaction involves MTFFZ’s proposed acquisition of 100% of the issued ordinary shares in the capital of SingCash (“Proposed Transaction”). 

(iii)      a description of the business activities of the merger parties worldwide and in Singapore; 

MTFFZ

MTFFZ is a 100% subsidiary of The Western Union Company, and is listed on the New York Stock Exchange. In Singapore, cross-border money transfer services are provided by Western Union Global Network Pte Ltd (“WUGN”) which is wholly owned by the Western Union Company. 

In Singapore, WUGN, provides outbound and inbound cross-border money transfer services on a consumer-to-consumer basis.

SingCash

SingCash provides cross-border money transfer services, through its Dash platform. SingCash provides outbound cross-border money transfer services on a consumer-to-consumer basis. 

SingCash does not have operations outside of Singapore. 

(iv)      a description of the overlapping goods or services, including brand names; 

SingCash and MTFFZ, through WUGN, overlap in the supply of outbound cross-border money transfer services to consumers in Singapore.  

(v)      a description of substitute goods or services; 

MTFFZ submits that all channels of outbound cross-border money transfer services (e.g. banks versus non-banks, retail versus digital) are close substitutes from the customer’s perspective.  

(vi)      The applicant's views on: 

a.        definition of the relevant market(s); 

MTFFZ submits that the relevant market is the supply of outbound cross-border money transfer services to consumers by banks and non-banks (which includes both traditional and digital-only cross-border money transfer service providers) in Singapore. 

b.        the way in which competition functions in this market; 

(1)  On pricing, firms can differ in terms of their transfer fees, exchange rates and surcharges for using a certain payment mode.

(2)  On quality, firms can differ in terms of service time (i.e. number of days for overseas recipient to receive the cross-border money transfer), extensiveness of the firm’s payment rails, and convenience of their physical outlet locations (if any). 

c.        barriers to entry and countervailing buyer power 

Barriers to entry

The primary barrier to entry is the regulatory requirement to obtain the necessary license to provide cross-border money transfer services.

Countervailing buyer power

Customers are individual consumers who are unable to negotiate pricing. However, the merged entity will be constrained due to customers’ ability to compare the prices and quality of service providers, and their ability to switch from one service provider to another. 

d.       the competitive effects of the merger (non-coordinated, coordinated and/or vertical effects, as relevant). 

Non-coordinated effects

MTFFZ submits that the Proposed Transaction will not give rise to non-coordinated effects for the following reasons: 

(1)  the multitude of existing and potential competitors that can easily expand or enter to exert significant competitive pressure on the merged entity, especially given the closeness of competition amongst existing competitors; 

(2)  the absence of material barriers to entry or expansion; and 

(3)  the ability of customers to compare and switch easily between different suppliers. 

Coordinated effects 

MTFFZ submits that the Proposed Transaction will not give rise to coordinated effects for the following reasons:

(1)  presence of numerous existing and potential competitors;

(2)  the ease of switching by customers; and

(3)  the low barriers to entry.

Vertical effects

The Parties submit that there is no existing vertical relationship between MTFFZ and Singcash.

Conglomerate effects

MTFFZ submits that the Proposed Transaction will not give rise to conglomerate effects for the following reasons:

(1)  SingCash’s insignificant market share in each of the other payment services markets that it operates in;

(2)  multitude of other financial institutions that are currently licensed to provide a range of payment services, capable of providing a comparable complementary suite of payment services to customers to compete against the merged entity; and

(3)  ability for customers can simply refuse or reject any form of tying and bundling by switching to the many other apps that provide a range of payment services.  

Decision:

16 January 2026 

Following its assessment, CCS has concluded that the Proposed Transaction, if carried into effect, will not infringe the section 54 prohibition of the Competition Act 2004. 

The Grounds of Decision will be uploaded in due course.