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The roadmap in outline

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A token launch is the event around which most of the structuring in this Part is organised. It is also the event that generates most of the enforcement cases in Parts H and N. The things that go wrong at a launch (an unregistered security, an unlicensed intermediary, a market-manipulation scheme dressed as market-making, an unexpected tax bill) are visible on the chain for ever. The legal roadmap that follows has twelve stages. Not every launch needs every stage, but every launch that skips one should do so by decision and with a note in the file.

  1. Classification of the token under Swiss and Singapore law, with a written opinion.
  2. Choice and formation of the issuing entity and the treasury vehicle.
  3. Pre-launch fundraising through SAFTs, token warrants or equity with token rights.
  4. Offer documentation: white paper, prospectus or exemption analysis under FinSA and the SFA.
  5. AML onboarding of participants and the travel-rule set-up.
  6. The token generation event and the distribution mechanics.
  7. Listing agreements with centralised exchanges.
  8. Lock-ups and vesting for team, investors and foundation.
  9. Market-making agreements and the market-abuse perimeter.
  10. Tax of the sale for the issuer and of the receipt for participants.
  11. Post-launch governance and the transition to the community.
  12. Incident planning: what happens if the token is reclassified, delisted or exploited.

Part E (Chapter I) together with Part K (Chapter IV) sets out the substantive law of classification and offering. This chapter assumes those analyses and concentrates on sequence, documents and the decisions a founder must take.

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.