The shape of the market

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Singapore's digital-asset market is small in the number of licensed firms and large in the weight of the institutions behind them. Switzerland counts several hundred crypto firms affiliated to self-regulatory organisations and a dozen with FINMA licences. Singapore had by mid-2026 a few dozen holders of payment services licences for digital payment token services, a handful of capital markets services licensees active in tokens and three domestic banks running their own tokenisation programmes. The population is small because MAS licenses slowly and refuses often, as Chapter II explained. It is weighty because the firms that passed are the global names, because the banks and the sovereign wealth funds are participants and because MAS itself runs the largest tokenisation programme of any regulator.¹

The practitioner must read this market with the licensing structure in mind. A firm that calls itself a "Singapore exchange" may hold a major payment institution licence, a standard payment institution licence, an in-principle approval, an exemption under the transitional provisions of 2024, a capital markets services licence for a different activity or nothing at all. The MAS Financial Institutions Directory lists every licensee by name and licence type, while the Investor Alert List names firms that MAS believes to be operating without a licence. Checking both takes five minutes and is the first act of due diligence on any Singapore counterparty.

Checklist

Before your client deposits assets with, contracts with or invests in a Singapore digital-asset firm you should establish the following. - The exact legal entity, from ACRA's BizFile register, with its unique entity number. - Whether that entity appears in the MAS Financial Institutions Directory, under which Act and for which services, and whether the licence is full or in-principle. - Whether the entity or any affiliate appears on the MAS Investor Alert List. - Whether the services your client will use fall within the licensed activities, because a licence for dealing in digital payment tokens does not cover the custody of tokens that are capital markets products. - Whether the entity is the contracting party in the terms of service or merely the local affiliate of an offshore operator, a distinction that decided the outcome for customers of several 2022 failures (Part J, Chapter V).

Notes

MAS, Financial Institutions Directory (searchable register of licensees by licence type, including payment services licensees with "digital payment token service" authorisation), consulted for the period to June 2026; precise licensee counts change monthly. ↩

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.

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.

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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.