Data protection: Comparison with Switzerland

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The Swiss and Singapore regimes are close in structure and differ in enforcement. Switzerland has no administrative fines against organisations. Its sanctions are criminal fines of up to CHF 250,000 against the responsible individuals, which concentrates the mind of a compliance officer in a different way.¹ Singapore fines the organisation up to 10 per cent of local turnover. Switzerland requires breach notification "as soon as possible" where the breach is likely to result in a high risk. Singapore gives three days after assessment and sets a numerical threshold. Switzerland treats data about an identifiable person as personal data in the same way as Singapore and has the same difficulty with public blockchains, on which the Federal Data Protection and Information Commissioner has not issued guidance comparable to the Singapore guide. A group that builds its privacy programme to the Singapore standard will generally satisfy the Swiss one, with the addition of the Swiss-specific documents: the register of processing activities and the data protection impact assessment for high-risk processing.²

Cross-border perspective

You can run a single privacy programme for a Zug–Singapore group if you adopt the stricter rule on each point. Keep personal data off every public chain. Treat wallet addresses linked to known customers as personal data in both places. Use the EU Standard Contractual Clauses with Swiss amendments for every transfer out of Switzerland and a binding intra-group agreement for every transfer out of Singapore. Set the breach clock to the shortest applicable period, which is the one-hour MAS incident notification for licensed entities and the three-day PDPC notification for personal data. A programme built this way will withstand an inspection by either regulator and, more to the point, will withstand the attention of the people who attack crypto businesses for their customer lists.

Notes

Art. 60–63 FADP (SR 235.1). ↩
Art. 12 (register of processing activities) and Art. 22 (data protection impact assessment) FADP (SR 235.1). ↩

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.

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