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Retail restrictions

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MAS began restricting retail access in January 2022 with Guidelines PS-G02, which told DPT service providers that trading in DPTs was not suitable for the general public. Providers were told not to market their services in public spaces, through public transport, broadcast media, third-party websites or influencers.1 The consumer-access and business-conduct measures that followed the 2022 consultations were issued in guideline form in 2023 and 2024 and took effect in two phases, on 4 October 2024 for the safeguarding of customer assets and on 19 June 2025 for the remainder. They require DPT service providers to assess a retail customer's risk awareness before providing services and to refuse incentives such as sign-up bonuses and referral rewards. Providers must refuse credit and margin to retail customers, accept no payment by credit card and bar retail customers from lending or staking their DPTs through the provider.2 Accredited and institutional investors are outside these restrictions. Part K, Chapter III treats the measures and their interaction with the licensing conditions.

MeasureSwitzerlandSingapore
Marketing of crypto trading to the publicPermitted, subject to FinSA conduct rulesRestricted since January 2022 (PS-G02)
Retail risk-awareness assessmentNone required by lawRequired since June 2025
Incentives for retail sign-upPermittedProhibited
Credit or margin to retailPermitted within banking and consumer-credit rulesProhibited
Retail staking or lending through the providerPermitted; FINMA Guidance 08/2023 on insolvency protectionProhibited for retail
Segregation of customer tokensArt. 242a/242b DEBA; Art. 16 BankAStatutory trust under PSA regulations; 90 % cold storage

Notes

  1. MAS, Guidelines PS-G02 on Provision of Digital Payment Token Services to the Public, 17 January 2022. ↩
  2. MAS, Guidelines on Consumer Protection Measures by Digital Payment Token Service Providers (PS-G03), revised 19 September 2024, Chapter 4 (consumer access measures) and Chapter 6 (business conduct), in effect from 19 June 2025; MAS, "Response to Feedback Received on Proposed Regulatory Measures for Digital Payment Token Services (Part 1)", 3 July 2023, and "(Part 2)", 23 November 2023. ↩

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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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.