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One regulator, one city

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Singapore's regulatory architecture for digital assets can be understood from a single fact: the central bank is also the sole financial regulator, the licensing authority, the AML supervisor for the financial sector and the government's principal fintech promoter. The Monetary Authority of Singapore was established in 1971 and combines functions that in Switzerland are divided between the SNB, FINMA, the State Secretariat for International Finance, the self-regulatory organisations and the cantonal economic development offices.1 The practical result is coherence. When MAS decides on a policy it can implement it through legislation that it drafts, through notices that bind licensees directly, through guidelines that set out its expectations and through the licensing conditions it attaches to each approval. There is no cantonal layer, no self-regulatory tier and no separate conduct regulator with a different view. Part I, Chapter II analyses MAS as an institution.

The other side of coherence is concentration. A business that falls out of favour with MAS has no alternative regulator to turn to, no canton that will take a different view and limited judicial review of licensing decisions in practice. The history described in Section 3 shows MAS using this concentration twice in a decade, first to welcome the industry and then to narrow it. A client who establishes in Singapore is therefore making a bet on the continuity of MAS policy, which has in practice been high. The client should understand that the policy is set by MAS and announced in its speeches and consultation papers before it reaches the statute book.

Notes

  1. Monetary Authority of Singapore Act 1970 (2020 Rev. Ed.), ss. 4 and 5 (functions and objects of the Authority). ↩

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.

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 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.