Markets: approved exchanges and recognised market operators

Read the PDF edition (1 page)

A platform on which tokenised capital markets products are traded is operating an organised market. Section 6 SFA prohibits the establishment or operation of an organised market unless the operator is an approved exchange or a recognised market operator (RMO), or is exempt.¹ The approved exchange status is reserved for systemically important markets, in practice the Singapore Exchange. The RMO status is the route for tokenised securities platforms. ADDX (formerly iSTOX) obtained RMO status together with a CMS licence in 2020 after a MAS sandbox period, and other platforms followed.² MAS introduced a three-tier RMO framework in 2018 with lighter requirements for smaller markets, which has helped tokenisation platforms with limited volumes.

The RMO regime requires the operator to have rules governing admission, trading, clearing and settlement, to ensure fair and orderly trading, to manage conflicts of interest and to notify MAS of material changes. For a tokenised securities venue the settlement question is central. If the platform settles trades on the ledger, it is performing a clearing or settlement function that may require separate approval as a clearing house or a depository, a point addressed in Chapter VII.

Notes

SFA, Part 2, Division 1, ss 6 to 9, on the prohibition on operating an organised market and the approval of exchanges and recognition of market operators. ↩
MAS press and licensing records on the recognition of iSTOX (now ADDX) as a recognised market operator in 2020 following the FinTech Regulatory Sandbox. ↩

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.

English

Contact

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.

Get in touch →

Articles and Insights

Setting up or expanding in Singapore?

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 legal, tax and fiduciary services in Switzerland, see helveticaregister.com.