Statutory interpretation

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Section 9A(1) of the Interpretation Act 1965 directs that an interpretation which would promote the purpose or object underlying a written law is to be preferred to one that would not. The Court of Appeal in Tan Cheng Bock v Attorney-General [2017] SGCA 50 set out a three-step method: ascertain the possible interpretations of the text, ascertain the legislative purpose from the text and from admissible extrinsic material, then compare the interpretations against that purpose.¹² Extrinsic material includes the Explanatory Statement to the Bill and the Minister's second reading speech in Parliament. For the Payment Services Act 2019 that speech, delivered on 14 January 2019, is the single most useful document for understanding the Act's design. It explains why the Act regulates digital payment token services for money-laundering and terrorism-financing risk and why it stopped short of regulating them for investor protection at that stage.³

The purposive method cuts both ways for the crypto industry. It allowed MAS to argue, with the 2021 amendments confirming the point, that "facilitating the exchange of digital payment tokens" catches a non-custodial matching engine even though the operator never touches the tokens. It also allows a licensee to argue that an activity falls outside the perimeter when regulating it would serve none of the Act's stated purposes. Swiss readers accustomed to the Federal Supreme Court's pluralism of methods, with the grammatical, systematic, historical and teleological elements weighed together, will find the Singapore method narrower in theory and similar in result.

Notes

Interpretation Act 1965, s. 9A(1), text as published on Singapore Statutes Online. ↩
Tan Cheng Bock v Attorney-General, Court of Appeal, 2017 SGCA 50, at paras 37–54 (three-step framework for purposive interpretation). ↩
Payment Services Bill, Second Reading, Singapore Parliamentary Debates, Official Report (14 January 2019), speech of Mr Ong Ye Kung, Minister for Education, on behalf of the Minister in charge of MAS. ↩

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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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.

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