Investigating agencies: Comparative observations

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Three differences between the Swiss and Singapore investigative systems have practical consequences for structuring. First, Singapore investigations are centralised and police-led, while Swiss investigations are prosecutor-led and cantonal, so a Singapore case will proceed faster to charge but with less judicial supervision of the investigative phase. Second, Singapore's compelled-disclosure powers over keys and passwords are explicit and backed by criminal sanction, whereas Swiss law relies on seizure of devices and expert decryption, with the accused entitled to refuse cooperation. Third, the Singapore victim has no procedural standing in the criminal case beyond the compensation order, while the Swiss victim can join the proceedings as a private claimant (Privatkläger) under Art. 118 ff. CrimPC and pursue civil claims within the criminal process.¹ A founder who holds keys to customer assets in Singapore should assume that the police can and will compel their disclosure. A victim choosing where to pursue the criminal complaint should know that Switzerland offers more participation and Singapore more speed.

Notes

Swiss Criminal Procedure Code of 5 October 2007 (CrimPC; StPO), SR 312.0, Arts 118–126. ↩

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

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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.

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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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