Prime brokerage, ETPs and the family-office fund

Read the PDF edition (2 pages)

Prime brokerage for digital assets exists in both hubs in a thin form. Swiss banks offer margin lending against bitcoin and ether and settlement across venues. Singapore has a smaller set of providers after the 2022 collapses, while the retail-facing restrictions of Part K, Chapter III, have kept credit away from the retail segment. A fund that needs borrowed funds will find them more readily in Zürich than in Singapore. Chapter IX returns to the banking relationships.

Exchange-traded products on SIX Swiss Exchange are the alternative to a fund for a manager who wants a listed, retail-accessible product. An ETP is a debt instrument collateralised by the underlying tokens, issued by a special-purpose vehicle and listed under the SIX rules, with no CISA authorisation because the product is a structured product and not a collective investment scheme.¹ More than two hundred crypto ETPs were listed on SIX by 2025, issued by 21Shares, CoinShares, WisdomTree and others. Singapore has no equivalent, because the SGX does not list crypto ETPs and MAS has not permitted retail access to spot crypto products. A manager with a retail ambition therefore issues an ETP in Switzerland and sells it to institutional and accredited investors in Singapore under the SFA exemptions.

The family-office fund is the last combination. A single family that wants to hold its digital assets through a fund vehicle for governance, reporting and succession reasons can use a VCC in Singapore. The VCC is managed by the family's own single-family-office manager, which is either licensed or exempt from licensing under the single-family-office exemption. The VCC then obtains the s. 13O or s. 13U exemption under the family-office conditions.² In Switzerland the same family can use an L-QIF only if it engages a fund management company, so single-family vehicles in Zug are more often holding companies or foundations, which Chapter VII describes. The Singapore route is cheaper for a family that wants a fund. The Swiss route is cheaper for a family that wants a holding structure.

Cross-border perspective

A manager deciding between the L-QIF and the VCC can use three tests. If the investors are Swiss or European and want a transparent vehicle with Swiss reporting, the L-QIF wins and the cost is the fund management company. If the investors are Asian or want an opaque corporate vehicle with no withholding tax and a tax exemption on the fund's gains, the VCC wins and the cost is Singapore substance for the manager. If the strategy is crypto-only, the Singapore licensing gap makes the VCC easier today under a platform manager, with the caveat that MAS has signalled the gap will close. Many managers end up with both vehicles, as the example shows, because the investor bases differ and the operational cost of a second vehicle is low once the first is running.

Notes

CISA, SR 951.31, Art. 5 (structured products are not collective investment schemes; distribution to retail clients requires a prospectus or KID under FinSA); SIX Exchange Regulation, Additional Rules for the Listing of Exchange Traded Products, as revised. Part E, Chapter VI. ↩
Securities and Futures (Licensing and Conduct of Business) Regulations, reg. 4 and MAS FAQs on the exemption from licensing for single family offices; MAS, conditions for ss. 13O and 13U for family offices as revised 5 July 2023 (minimum fund size, local investment, business spending, professionals). Part M, 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.

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. As a Singapore law practice, KGP Legal LLC is authorised under the Legal Profession Act 1966 to advise on Singapore law and to represent clients before the Singapore courts; foreign law practices with an office in Singapore are, as a rule, not permitted to do either. 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.