What each failure changed
The following table pairs the principal failures with the rule or practice each produced. It is a simplification, because most changes had several causes, but it is the simplification that practitioners use.
| Failure | Where | When | What changed |
|---|---|---|---|
| Envion | Zug | 2018–2019 | Confirmed that repayable tokens are deposits; FINMA enforcement against Zug companies with foreign operations |
| Libra / Diem | Geneva | 2019–2022 | FINMA stablecoin supplement; payment-system licence analysis; SNB attention to private money |
| Binance withdrawal | Singapore | 2021 | Signalled the height of the PSA licensing bar |
| Terra / UST | Singapore | May 2022 | Stablecoin consultation; October 2022 framework proposals; 2023 final framework |
| Three Arrows Capital | Singapore | June 2022 | Scrutiny of registered fund managers; AUM thresholds; FMC conditions tightened |
| Zipmex, Hodlnaut, Vauld | Singapore | July–Aug 2022 | Case law on customer assets in insolvency; retail ban on lending and staking; segregation rules |
| FTX | Bahamas / global | Nov 2022 | Segregation and cold-storage rules; "digital asset hub" doctrine; Temasek write-down |
| Credit Suisse | Zürich | Mar 2023 | Banking Act review; stricter climate for bank-related licences |
| Staking uncertainty | Switzerland | Dec 2023 | FINMA Guidance 08/2023; legislative clarification pending |
| FlowBank | Geneva | June 2024 | First Swiss bank insolvency with crypto custody; test of Art. 16 BankA and Art. 242a DEBA |
| S$ 3 billion laundering case | Singapore | Aug 2023 | Family-office and single-family-office reforms; bank de-risking; AML Act 2024 |
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.