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Approaching the actors: a sequence

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A Swiss or German group establishing a regulated digital-asset business in Singapore meets the actors in roughly this order, which should be planned. - Singapore counsel, admitted under the Legal Profession Act 1966, to give the regulatory and corporate advice that only a Singapore-admitted lawyer may give. - A registered corporate service provider and ACRA, for incorporation, the resident director and the register of controllers. - The Ministry of Manpower, for the Employment Pass of the founder or the local chief executive, which MAS will expect to see in place. - A bank, approached with the business plan and the regulatory analysis before the licence application is filed, because MAS asks for banking arrangements in the application. - MAS, through a pre-application meeting and then the application, with the Payments Department or the relevant capital markets department as the counterpart. - IRAS, for an advance ruling if the token or incentive position is uncertain, and in any case for the first corporate tax filing. - The Blockchain Association Singapore, for membership and the working groups. - An external auditor, appointed before the licence is granted, because the first payment services audit falls due within the first financial year.

The sequence takes between nine and eighteen months for a major payment institution licence, as Part K, Chapter X and Part Q, Chapter IV set out with ranges. The Swiss reader will compare it with the Swiss sequence of SRO affiliation, bank account and, where needed, FINMA licence described in Part E, Chapter XII, and will find the Singapore path longer at the regulator and shorter at the bank.

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.

Setting up or expanding in Singapore?

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 Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.