How each standard lands: the implementation map

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Standard	Date	Swiss landing	Singapore landing	Open at 30 June 2026
FATF R.15 and INR 15 (VASPs, travel rule)	October 2018; June 2019; guidance October 2021	Art. 2 para. 3 AMLA; AMLO-FINMA Art. 10 and 51a; FINMA Guidance 02/2019; SRO rules	PSA 2019 and 2021 amendments; MAS Notice PSN02; FSMA Part 9 (DTSP)	Fifth-round mutual evaluations; DeFi "control" test; unhosted wallets
FSB global framework	17 July 2023	Federal Council stablecoin work; FINMA Guidance 06/2024	MAS SCS framework (August 2023); 2023 segregation rules	FSB peer review follow-up; multi-function intermediaries in Switzerland
BCBS SCO60	16 December 2022; amended 17 July 2024	CAO revision and FINMA circulars (Basel III final)	MAS Notice 637 amendments	Confirmation of implementation dates; infrastructure add-on
IOSCO recommendations	16 November 2023 (crypto); December 2023 (DeFi)	FinMIA DLT trading facility rules for securities only	MAS 2023 customer-protection measures; PS-G03	Conflicts rules for non-security tokens in Switzerland
OECD CARF and amended CRS	October 2022; MCAA November 2023	AEOI Act amendments in force 1 January 2026; partner-state decree suspended November 2025; data collection from 2027 at the earliest, first exchange 2028	ITA Part 20B regulations; first exchanges 2027 or 2028	Swiss partner-state list; Singapore regulations; Union DAC8 recognition

Two observations close the chapter. First, Singapore's implementations are statutory and dated, Switzerland's are often administrative and derived from existing law. That difference reflects the two legal traditions discussed in Chapter I and explains why a Singapore compliance officer can point to a notice paragraph while a Swiss one points to a FINMA practice. Second, the standards converge. The FATF's VASP, MiCA's CASP, Singapore's DPT service provider, the OECD's RCASP and the FSB's crypto-asset service provider describe the same business from four angles. A firm that designs its compliance architecture around the FATF definition and the CARF reporting unit will find that the other regimes map onto it with small adjustments, which is the design principle Part P, Chapter IV, applies to the dual-hub group.

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.

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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.

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.