Singapore's strategic bet

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Singapore's regulators drew a sharp line in 2022 between crypto speculation, which they set out to contain, and the tokenisation of regulated financial assets, which they set out to lead. The line runs through every policy document since. The consumer access measures of Chapter III restrict retail access to DPTs. The stablecoin framework of Chapter VI builds a settlement asset. Part 9 of the FSMA pushes out firms that serve only foreign speculators. The tokenisation programme, by contrast, invites the largest banks and asset managers in the world to build the next generation of market infrastructure in Singapore under MAS's supervision. A practitioner who advises on digital assets in Singapore spends an increasing share of the time on this programme and a decreasing share on exchanges.

The programme has a legal premise that the earlier chapters have established. Singapore has no special statute for tokenised securities and does not intend to create one. A tokenised bond is a debenture, a tokenised fund unit is a unit in a collective investment scheme and a tokenised deposit is a deposit. The SFA, the Banking Act 1970 and the Payment Services Act apply to each as they would to its conventional form. The Guide on the Tokenisation of Capital Markets Products of late 2025 confirms the point for the whole value chain (see Chapter IV).¹ The work of the programme is therefore not legislative. It is the development of standards, networks and settlement assets that make tokenised instruments usable at scale within the existing law.

Notes

Rajah & Tann, "MAS Issues Revised Guide on Tokenisation of Capital Markets Products", 8 December 2025, on the technology-neutral application of the SFA and FAA to tokenised capital markets products and their intermediaries. ↩

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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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.

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