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The end of the story

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A digital-asset business in either hub ends in one of four ways: it is sold, it is merged into a larger group, it is wound down in an orderly fashion, or it fails. The first three are the subject of this chapter. The fourth is the subject of Part H (Chapter VII) together with Part N (Chapter IV). The distinction between an orderly wind-down and a failure is often a matter of timing. A business that begins its wind-down while it can still pay its creditors and return its customers' assets chooses the manner of its ending. One that waits has the manner chosen for it by a court or a regulator.

The feature that distinguishes the sale or closure of a digital-asset business from that of any other is the customer asset. A custodian, an exchange or a payment institution holds tokens that belong to its customers. Those tokens must be returned, transferred to a successor or carved out before the business can change hands or close. Both regulators treat the handling of customer assets as the test of whether a transaction or a closure will be approved. A buyer who understands that will structure the deal around it. A seller who understands it will have prepared the assets for transfer long before the sale.

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.