MAS's stance

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MAS has never published a DeFi report comparable to the Federal Council's, but its position can be assembled from speeches, consultation papers and the design of the DTSP regime. Three elements stand out. First, MAS has stated repeatedly that it regulates activities and persons, that a protocol without an operator is outside its remit and that it does not intend to regulate code. Second, MAS has treated the operators of front-ends and the developers who retain control as providing DPT services or operating markets, and has applied the PSA and SFA to them without hesitation. Third, MAS has been openly sceptical of DeFi's current form, describing much of it in 2022 and 2023 as neither decentralised nor finance in any useful sense. Its institutional tokenisation work in Project Guardian has focused on permissioned DeFi, in which known institutions use AMM and lending mechanics on permissioned ledgers with full KYC.¹

The practical difference from Switzerland is that Singapore's DTSP regime under Part 9 of the Financial Services and Markets Act 2022, in force since 30 June 2025, reaches any Singapore-based person providing digital token services to customers outside Singapore. A Singapore development team operating a DeFi front-end for a global user base is squarely within that regime and needs a DTSP licence, which MAS has said it will grant only in extremely limited circumstances. The consequence has been an exodus of DeFi teams from Singapore to Dubai, Hong Kong and elsewhere during 2025, which Part I, Chapter III and Part K, Chapter V record.²

Cross-border perspective

A team that wants to build and operate a DeFi protocol and its front-end has, in 2026, a clear structural answer across the two hubs. The protocol's governance and treasury can sit in a Swiss foundation or association in Zug, as Chapter VII explains. Swiss law tolerates a non-profit wrapper holding governance power over a protocol if the wrapper does not itself hold user assets or operate the front-end. The front-end, if it serves retail users anywhere, must be operated from a jurisdiction where that activity is either unlicensed or licensable. That excludes Singapore under the DTSP regime. Switzerland is possible only if the front-end does not facilitate transfers in a way that makes its operator a financial intermediary. The development company that employs the engineers can be anywhere. Singapore remains attractive for it provided it does not itself provide the service. Separate the three functions into three entities, document what each can do, and ensure that no entity holds an admin key that can move user assets.

Notes

MAS, Project Guardian: Enabling Open and Interoperable Networks, June 2023, section on institutional DeFi; Ravi Menon, "Yes to digital asset innovation, no to cryptocurrency speculation", speech at Green Shoots, 29 August 2022. Part I, Chapter III and Part K, Chapter IX. ↩
Financial Services and Markets Act 2022 (Singapore), Part 9 (digital token service providers), commenced 30 June 2025; MAS, Response to Feedback Received on Proposed Regulatory Approach for Digital Token Service Providers, 30 May 2025 (stating that licences would be granted in extremely limited circumstances). Part K, Chapter V. ↩

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.

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