The Financial Stability Board's 2023 framework

Read the PDF edition (1 page)

The FSB published its Global Regulatory Framework for Crypto-asset Activities on 17 July 2023, in two parts. The first contains high-level recommendations for the regulation, supervision and oversight of crypto-asset activities and markets. The second contains revised high-level recommendations for global stablecoin arrangements, which updated the FSB's October 2020 text after the Terra collapse. The framework rests on the principle of "same activity, same risk, same regulation" and asks jurisdictions to ensure that crypto-asset activities with the same economic function as traditional financial activities are regulated to the same outcome. The recommendations cover regulatory powers, a comprehensive framework, cross-border cooperation, governance, risk management, data, disclosure, interconnections and multi-function intermediaries. For stablecoins they require a clearly identified governance body, redemption at par, reserve quality and prudential standards, asking jurisdictions to prohibit a stablecoin from operating unless it meets them.¹

The FSB's instrument is peer review. Its October 2024 status report on implementation found that most member jurisdictions had taken or planned steps but that cross-border gaps and the treatment of multi-function intermediaries remained open. A thematic peer review in 2025 examined the stablecoin recommendations in detail.² For Switzerland the framework's effect is visible in the Federal Council's stablecoin work and in FINMA's 2024 guidance, which adopted the FSB's insistence on a clearly identified issuer with redemption obligations. For Singapore the effect is visible in MAS's 2022 and 2023 consultations, which cite the FSB's draft recommendations. It is also visible in the structure of the single-currency stablecoin framework, which tracks the FSB's stablecoin recommendations point for point. The "multi-function intermediary" concern, aimed at exchanges that combine trading, custody, lending and proprietary activity, appears in MAS's segregation rules of 2023 and in Hong Kong's prohibition of proprietary trading by VATPs. Switzerland has not yet acted on it beyond the general organisational requirements of FinIA.

Notes

FSB, Global Regulatory Framework for Crypto-asset Activities, 17 July 2023, comprising the High-level Recommendations for the Regulation, Supervision and Oversight of Crypto-asset Activities and Markets and the revised High-level Recommendations for the Regulation, Supervision and Oversight of Global Stablecoin Arrangements. The FSB and the sectoral standard-setters agreed a shared workplan for 2023 and beyond. ↩
FSB, "G20 Crypto-asset Policy Implementation Roadmap: Status report", 22 October 2024. FSB, Thematic Peer Review on the FSB Global Regulatory Framework for Crypto-asset Activities, 2025. ↩

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.

English

Contact

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.

Get in touch →

Articles and Insights

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. 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.