Addresses and pseudonymity

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An address is a string of letters and digits. It carries no name. Anyone can generate as many addresses as he wishes at no cost. The ledger therefore records every transaction in full public view while identifying no one. This pairing of complete transparency with complete pseudonymity shapes anti-money-laundering law in both hubs. Switzerland's FINMA treats an unhosted address as belonging to no identified person until a financial intermediary has verified control over it by a technically suitable method, which is why the Swiss travel rule requires proof of control before a licensed intermediary transfers to a private wallet.¹ MAS applies the same logic through its value-transfer requirements in Notice PSN02, described in Part L, Chapter III.

Pseudonymity also has a data-protection dimension. An address becomes personal data once it can be linked to a natural person, which blockchain analytics firms routinely achieve. Part D, Chapter X and Part J, Chapter IX treat the consequences under the Swiss Federal Act on Data Protection and Singapore's Personal Data Protection Act 2012.

Notes

FINMA Guidance 02/2019 of 26 August 2019 on payments on the blockchain, section 2 (application of Art. 10 AMLO-FINMA to transfers to and from external wallets). Treated in Part F, Chapter IV. ↩

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.

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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.

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