Assessment

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Part 9 is the clearest statement of Singapore's policy on digital assets since the 2022 collapses. The regime does not seek to attract firms. It seeks to ensure that no firm can use Singapore as a flag of convenience for activity that MAS cannot supervise. In the Swiss comparison it has no counterpart. A Swiss AG that provides crypto services exclusively to foreign customers is a financial intermediary under the Anti-Money Laundering Act (AMLA; GwG) and must affiliate to an SRO. There is no Swiss prohibition on serving foreign customers from Switzerland and no suggestion that FINMA would refuse to supervise such a firm (see Part F, Chapter II). Switzerland regulates the firm because it is there. Singapore, under Part 9, tells the firm to go elsewhere unless it also serves Singapore.

For a founder deciding between the two hubs, the lesson is direct. If the business is global and does not need Singapore customers, the Singapore entity should hold no customer relationships and no assets, or should not exist. If the business wants Asian customers including Singapore residents, the Payment Services Act licence is the route, with all that Chapters II and III entail. If the business wants a regulated European or Swiss base for global customers, Switzerland remains open in a way that Singapore has chosen not to be.

Question	Switzerland	Singapore
Firm incorporated locally, customers all abroad	Lawful; SRO affiliation under AMLA required for exchange or custody	Part 9 FSMA licence required; MAS will generally refuse; cease or restructure
Firm licensed locally, customers at home and abroad	Lawful under SRO/FinIA/BankA licence	Lawful under PSA/SFA licence; exempt from Part 9
Letterbox entity with no local operations	Possible but SRO will require a Swiss AML officer	Caught by Part 9 by incorporation alone
Individual employee of foreign firm working locally	No licence issue for the individual	No Part 9 licence by employment alone; employer may trigger main Acts
Policy stance	Regulate what is here	Regulate what serves Singapore; discourage the rest

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 if you need any further information.

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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.