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The crypto dimension

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The case was not a crypto case in the sense that the public assets were mostly real estate and bank balances. Its lessons for the digital-asset sector are nonetheless direct.

First, the predicate offences were crypto-adjacent. Online gambling syndicates and scam operations in South-East Asia collect from victims in crypto, settle between themselves in crypto and convert to fiat through over-the-counter desks and exchanges in the region before the money reaches a private bank. A Singapore DPT licensee that serves regional corporate customers in payments, remittances or "treasury management" is at the point in the chain where this conversion happens. The case told MAS where to look.

Second, the authorities had to seize and realise crypto assets at scale for the first time. The procedures developed, including the transfer of seized tokens to police-controlled wallets and their realisation through licensed exchanges under court supervision, are now the template used in every Singapore crypto seizure. Part N, Chapter III describes them.

Third, the banks' reaction hit the sector. In the eighteen months after the arrests Singapore's banks reviewed their foreign-wealth books, exited customers with weak source-of-wealth documentation and raised the bar for new accounts. Customers whose wealth derived from digital assets were among the most affected, because crypto wealth is the hardest to corroborate by conventional documents. Several DPT licensees reported difficulty in maintaining or opening operating accounts, and family offices with crypto holdings found that banks declined to act as the MAS-regulated institution required under the SFO framework. MAS responded publicly that it did not expect blanket de-risking of any sector and that banks should assess customers individually, but the market's behaviour was slower to change than the regulator's statements.1

Client question

"Our family's wealth is from an exchange business sold in 2021. We want a Singapore single family office with a crypto allocation. Which bank will take us and what will they ask?" The number of banks that will take a crypto-derived family is small. The process takes months. The file must be of a quality that would have survived the 2023 case. The bank will ask for the sale documents and proof of receipt of the proceeds, together with the exchange's licensing history and audited accounts for the years before the sale. It will want evidence of tax compliance in the family's residence country for those years. If any of the proceeds were in tokens, it will want a blockchain-analytics report on the wallets that held the business's treasury. It will ask for an explanation of every passport the principals hold. It will also ask what the crypto allocation will be held through, and will expect a MAS-licensed custodian. A family that assembles this file before approaching the bank, through counsel who have seen what banks accept, has a reasonable prospect. One that approaches with a one-page wealth narrative does not.

Notes

  1. MAS, statements on de-risking in response to parliamentary questions and in the Enforcement Report, 2024–2025; MAS Guidelines to Notice 626, section on the risk-based approach discouraging wholesale exit of customer categories. ↩

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. As a Singapore law practice, KGP Legal LLC is authorised under the Legal Profession Act 1966 to advise on Singapore law and to represent clients before the Singapore courts; foreign law practices with an office in Singapore are, as a rule, not permitted to do either. 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.