Data protection in the travel rule

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Transmitting a customer's name, address and identification number to a foreign institution is a cross-border transfer of personal data. In Singapore the PDPA's transfer-limitation obligation requires the transferring organisation to ensure that the recipient is bound by legally enforceable obligations to protect the data to a standard comparable to the PDPA, unless an exception applies.¹ The exception for transfers required by law covers the transmission itself where PSN02 requires it. It does not cover the choice of an insecure channel or the transmission to a counterparty that cannot protect the data. Firms should ensure that their travel-rule network's terms impose data-protection obligations on all participants and should record the assessment. On the Swiss side the Federal Act on Data Protection (FADP; DSG) of 2023 imposes comparable requirements, discussed in Part D, Chapter X.

Notes

Personal Data Protection Act 2012, s. 26 (transfer of personal data outside Singapore) and Personal Data Protection Regulations 2021, reg. 10 (conditions for transfer). ↩

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.

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.

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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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