Table of regulator guidance

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Regulator guidance has no force of law in either hub, yet it governs daily practice in both. In Switzerland, FINMA guidance and circulars state how the authority reads the statutes it enforces. A firm that departs from them must be ready to argue the point in an enforcement proceeding. In Singapore, MAS notices issued under the Payment Services Act 2019 or the Financial Services and Markets Act 2022 bind the persons to whom they are addressed. MAS guidelines, FAQs and consultation responses set out expectations that MAS applies in licensing and inspection. The tables below list the documents cited in the book by identifier, date and subject, with the part in which each is discussed.

The FINMA items dated 16 February 2018, 26 August 2019, 11 September 2019 and 20 December 2023 were confirmed from the FINMA press releases of those dates.¹ The FTA working paper is listed with the dates shown on the FTA's page for cryptocurrencies, which gives 3 August 2022 as the current version replacing the paper of 27 August 2019.² The MAS stablecoin response of 15 August 2023 was confirmed from the MAS media release.³ The remaining references are to the MAS, IRAS and SECO publications listed below.⁴

Guidance changes more often than legislation does, sometimes several times in a year. Each table gives the date of the version on which the book relies, so the reader should check for later revisions before acting on a threshold, a timeline or a list of permitted activities.

Notes

FINMA press releases of 16 February 2018 (ICO Guidelines), 26 August 2019 (FINMA Guidance 02/2019 "Payments on the blockchain"), 11 September 2019 (Supplement to the ICO Guidelines on stable coins) and 20 December 2023 (FINMA Guidance 08/2023 on staking services), www.finma.ch. ↩
Eidgenössische Steuerverwaltung, "Arbeitspapier: Kryptowährungen und Initial Coin/Token Offerings (ICO/ITO) als Gegenstand der Vermögens-, Einkommens- und Gewinnsteuer, der Verrechnungssteuer und der Stempelabgaben", version of 3 August 2022, replacing the version of 27 August 2019, www.estv.admin.ch, page "Kryptowährungen". ↩
MAS media release "MAS Finalises Stablecoin Regulatory Framework" of 15 August 2023, www.mas.gov.sg. ↩
MAS Notice PSN02 "Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service" of 5 December 2019, as amended; MAS Guidelines PS-G02 "Guidelines on Provision of Digital Payment Token Services to the Public" of 17 January 2022, as revised; IRAS e-Tax Guide "Income Tax Treatment of Digital Tokens" of 17 April 2020; IRAS e-Tax Guide "GST: Digital Payment Tokens" of 19 November 2019. ↩

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.

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