A decision sequence for the Asian hub

The analysis of this chapter can be reduced to a sequence of questions that a Swiss group should answer in order.

Who are the customers? Retail in Hong Kong or Greater China points to Hong Kong. Institutions, family offices and the Southeast Asian region point to Singapore. Retail in Southeast Asia points to Singapore as headquarters with local licences or partners in each market.
What is the product? Spot trading for retail, ETFs and a stablecoin under a statute in force point to Hong Kong. Tokenised funds and bonds, institutional custody and payments point to Singapore. Fast market-making or proprietary trading entities point to Dubai or Abu Dhabi.
Where is the money? If the group's investors or its treasury bankers sit in Switzerland, the Singapore domestic banks and the Swiss banks with Singapore branches offer the shortest route to an account. If they sit in Greater China, the Hong Kong banks do.
What will the Swiss regulator think? A Swiss licensee's expansion into Asia is reported to FINMA or its supervisory organisation, and a Swiss SRO member's group structure is examined at the annual audit. A Hong Kong or Dubai entity attracts more questions than a Singapore one.
What is the exit? A Singapore-licensed business sells at a premium to a buyer that values the MAS licence, as Part P, Chapter X explains. A Dubai licence is easier to obtain and correspondingly worth less on sale.

Example: A Zürich-based crypto broker licensed as a securities firm under the Financial Institutions Act wants to serve Asian institutional clients and later Asian retail. Applying the sequence, it chooses Singapore for the headquarters and the institutional business, applies for a major payment institution licence and accepts the retail restrictions as the price of the badge. It plans a Hong Kong platform licence for the retail phase two years later, when it will have a Singapore track record to show the SFC. It declines Dubai because its Swiss bankers have asked pointed questions about the Emirates. The structure is drawn so that the Singapore entity serves Singapore and regional institutional customers from the first day, which keeps it outside Part 9 of the Financial Services and Markets Act 2022 and inside the Payment Services Act 2019.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.