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What each failure changed

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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.

FailureWhereWhenWhat changed
EnvionZug2018–2019Confirmed that repayable tokens are deposits; FINMA enforcement against Zug companies with foreign operations
Libra / DiemGeneva2019–2022FINMA stablecoin supplement; payment-system licence analysis; SNB attention to private money
Binance withdrawalSingapore2021Signalled the height of the PSA licensing bar
Terra / USTSingaporeMay 2022Stablecoin consultation; October 2022 framework proposals; 2023 final framework
Three Arrows CapitalSingaporeJune 2022Scrutiny of registered fund managers; AUM thresholds; FMC conditions tightened
Zipmex, Hodlnaut, VauldSingaporeJuly–Aug 2022Case law on customer assets in insolvency; retail ban on lending and staking; segregation rules
FTXBahamas / globalNov 2022Segregation and cold-storage rules; "digital asset hub" doctrine; Temasek write-down
Credit SuisseZürichMar 2023Banking Act review; stricter climate for bank-related licences
Staking uncertaintySwitzerlandDec 2023FINMA Guidance 08/2023; legislative clarification pending
FlowBankGenevaJune 2024First Swiss bank insolvency with crypto custody; test of Art. 16 BankA and Art. 242a DEBA
S$ 3 billion laundering caseSingaporeAug 2023Family-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.

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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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