Cooperation among the regulators

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Competition between the hubs coexists with cooperation among their regulators, and a client who structures across them should know how much the regulators tell each other. MAS and FINMA signed a cooperation agreement on financial technology on 12 September 2016, one of the first of its kind, under which each refers innovative firms to the other and shares information on regulatory developments. MAS has similar agreements with the Hong Kong Securities and Futures Commission, with the Japan Financial Services Agency and with the Abu Dhabi and Dubai authorities, and all of them sit together in the Financial Action Task Force, the Financial Stability Board and IOSCO.¹ On enforcement the channels are the memoranda of understanding under the IOSCO Multilateral Memorandum, the mutual legal assistance treaties and, for anti-money-laundering intelligence, the Egmont Group of financial intelligence units to which both STRO and the Swiss Money Laundering Reporting Office belong.

The consequence is that a group licensed in two of these places cannot tell each regulator a different story. A licence application in Singapore asks for the group structure, the licences held elsewhere and any regulatory action taken against any group entity anywhere. The same question appears in a FINMA application and in an SFC application. The answers are compared. In my practice I have seen an application delayed by a year because a group's Singapore filing described a Swiss affiliate as unregulated while the affiliate was in fact under SRO supervision, a discrepancy MAS discovered by asking FINMA. The lesson is to prepare one group narrative, checked by counsel in each jurisdiction, before the first application is filed.

Notes

MAS and FINMA, Cooperation Agreement on FinTech, signed 12 September 2016; MAS's FinTech cooperation agreements are listed on the MAS website; on supervisory cooperation in enforcement see Part H, Chapter VI and Part N, Chapter II. ↩

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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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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