Payment services: Account issuance service

What is an "Exempt Product" for account issuance services that are deemed low risk?

• According to MAS (Notices), 
  last revised on 01 March 2022

  “exempted product” means ⎯
  (a) where the product involves an account issuance service, the product:

  (i) does not allow the withdrawal of any cash;
  (ii) does not allow a refund of any amount in excess of S$100 in cash from each
  payment account to any person, except:

  (A) upon the production of an identification document of the holder of
  the payment account that bears a photograph of that holder and
  is in force; and
  (B) where the person has a policy of keeping records of the refund
  and identification document mentioned in sub-paragraph (A) for at
  least 5 years after the date on which the refund is made; and

  (iii) is not able to contain an amount of money or the currency equivalent of e-money of more than S$1,000;

  (b) where the product involves a domestic money transfer service, the product
  satisfies at least two of the following requirements:

  (i) is to be used only as a means of payment for goods or services;
  (ii) is funded from an identifiable source;
  (iii) the payment transaction value does not exceed S$20,000;

  (c) where the product involves a cross-border money transfer service, the product is
  to be used only as a means of payment for goods or services and is funded from
  an identifiable source;