Prohibited inducements and credit

Read the PDF edition (1 page)

Three prohibitions follow. First, a provider may not offer any incentive, monetary or otherwise, to prospective or existing retail customers. The prohibition covers sign-up bonuses, referral rewards, trading fee rebates offered as promotions, "learn and earn" programmes that pay tokens for completing tutorials, and gifts of tokens or merchandise.¹ Second, a provider may not offer a retail customer any credit facility to finance the purchase of DPTs or to maintain a position, and may not enter into a leveraged DPT transaction with a retail customer. Margin trading, futures and perpetual contracts on DPTs are therefore unavailable to retail customers of a licensed Singapore provider. Third, a provider may not accept payment by credit card or charge card issued in Singapore for the purchase of DPTs. Cards issued outside Singapore may be accepted.²

The prohibition on leveraged transactions has a significant consequence for the perimeter. Many token derivatives are capital markets products under the SFA and fall outside the DPT service under the Payment Services Act. A provider that wants to offer perpetual futures on bitcoin to Singapore customers therefore needs a capital markets services licence and must treat the product as a derivative. Even with that licence, MAS has indicated that it does not expect to permit such products to be offered to retail customers. The retail derivatives business that exists in Hong Kong and in parts of Europe therefore has no Singapore equivalent.

Notes

Morgan Lewis, November 2023 (above): providers are prohibited from offering incentives, monetary or otherwise, including sign-up, referral and trading incentives and "learn-and-earn" programmes. ↩
Morgan Lewis, November 2023 (above): no credit facility or leveraged DPT transaction with a retail customer; no acceptance of credit or charge card payments except from foreign-issued cards. ↩

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.