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Sanctions and the lawyer

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A lawyer advising a DPT licensee on sanctions in Singapore must hold three jurisdictions in view at once. The Singapore layer determines what is unlawful and what must be frozen and reported. The United States layer determines what will cause the dollar system to close. The Swiss or EU layer, where the client has an affiliate there, determines what the group's other entity may not do. The advice that results is often that a transaction lawful in Singapore should be declined because of its consequences elsewhere. Clients accept that advice more readily when it is framed as a commercial decision supported by documented policy than when it is presented as a legal prohibition that does not exist. Precision about which layer forbids what is the lawyer's contribution. Part O, Chapter IV and Chapter VI place these questions in the wider international context.

Practice note

You can reduce your Singapore DPT licensee's sanctions risk to a manageable level with five controls. - Screen names against the UN, Singapore, OFAC, EU and UK lists on every update, with transliteration handling tested. - Screen every on-chain counterparty address against designated addresses and attributed clusters, with documented thresholds for indirect exposure. - Treat any DPRK-attributed exposure as a mandatory freeze and report, whatever the hop count. - Monitor the freeze lists of the stablecoin issuers whose tokens you hold and allocate issuer-freeze risk to the customer in your custody terms. - Keep a sanctions decision log that records every hit, the list it came from, the legal basis for the action taken and the person who took it. The log is what MAS asks for first.

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 legal, tax and fiduciary services in Switzerland, see helveticaregister.com.