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Incident response after a hack

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The first hours after a security incident decide whether assets are recovered and whether the firm survives the regulatory aftermath. The checklist is written for a licensed or SRO-affiliated business whose hot wallet or smart contract has been exploited. It covers the first 24 hours and points to the asset-tracing checklist for what follows.1

Checklist

  • Activate the incident response team named in the business continuity plan and open a single incident log with timestamps.
  • Contain: pause the affected smart contract if a pause function exists, revoke compromised keys, move remaining hot wallet assets to new cold storage, suspend withdrawals and deposits as needed.
  • Preserve evidence: snapshot systems, preserve logs, record the attacker addresses and transaction hashes, do not wipe or rebuild compromised machines before forensic imaging.
  • Engage: forensic firm, blockchain analytics provider, external counsel in each affected jurisdiction, public relations adviser.
  • Notify regulators within the deadlines: FINMA under the cyber-incident rules (initial notification within 24 hours), the SRO, MAS under PSN05 (within one hour of discovery for relevant incidents), and the data protection authorities if personal data is affected.
  • Notify law enforcement: cantonal police or prosecutor in Zug or Zürich, the Singapore Police Force (CAD or the Anti-Scam Command), with the transaction details and addresses.
  • Notify exchanges and stablecoin issuers that may receive the stolen assets, requesting freezes, with the police report reference.
  • Communicate with clients: factual, timely, consistent with regulatory notifications, without promises of compensation before the facts are known.
  • Assess the client asset position: whether client or proprietary assets were taken, whether segregation survives, and whether the firm remains solvent.
  • Consider the insurance notification deadlines and the policy's requirements on cooperation and consent to settlements.
  • Begin the asset-tracing sequence in the next checklist.
  • Record every decision and the reason for it; the regulator will ask.

Notes

  1. FINMA Circular 2023/1 on operational risks and resilience and the cyber-incident reporting duty under Art. 29 para. 2 FINMASA; MAS Notice PSN05 and the Technology Risk Management Guidelines on incident reporting within one hour; see Part E, Chapter XII and Part L, Chapter VII. ↩

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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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.