The position of a Swiss SRO member with a Singapore MPI: three recurring questions

Three questions arise so often in this configuration that they deserve direct answers.

The first is whether the Swiss SRO will accept the Singapore programme as the group standard. The SROs assess their members' compliance against their own regulations and do not supervise foreign affiliates. They do, however, review the member's organisation. A member that presents a group programme exceeding the SRO's requirements, with the Swiss annex demonstrating compliance with each regulation, will pass its audit. The point to watch is the Swiss forms. The SRO auditor will look for the Form K or equivalent in every file, so a Singapore-designed onboarding flow that captures the same information in a different format may be queried. Building the Swiss form into the shared process avoids the discussion.

The second is whether MAS will accept Swiss-generated CDD for Singapore customers. It will, under the reliance provision, provided the Singapore entity's file shows its own screening, rating and approval. MAS will not accept a Singapore file that consists of a pointer to the Zug system. The data and documents must be on the Singapore entity's systems, accessible to MAS on inspection without the cooperation of the Swiss entity, which in practice means a replicated record with Singapore-side access control.

The third is what happens when the two entities reach different conclusions about the same customer. The Zug AG may regard a customer as acceptable under the Swiss standard while the Singapore MPI, applying the post-2023 source-of-wealth expectations of Chapter V, declines. The group protocol should provide that a decline by either entity is notified to the other and that the other entity reviews its own relationship in light of the reasons. Continued service by one entity after the other's decline should require a documented decision by the group compliance committee. Divergent outcomes are not unlawful. Unexplained divergent outcomes are what inspectors treat as evidence that the group programme is a paper exercise.

Cross-border perspective

You can run a Zug custodian and a Singapore exchange under one compliance programme. Doing so will strengthen your position before both FINMA's SRO system and MAS. The programme must take the stricter rule on each point of divergence and must generate the documentation each regulator expects from a single data collection. It must keep the two entities' screening, monitoring and reporting separate while sharing risk outcomes under a protocol that respects both tipping-off regimes. A group that builds this at the start spends perhaps a fifth more on compliance systems than one that runs two silos. It recovers the difference the first time one regulator's finding is already remediated in the other entity before the second regulator asks.

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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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.

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