Where the method reaches its limits

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Three cautions apply to every comparison in this book. The first is that the two systems are moving at different speeds and in slightly different directions. Switzerland has been slowly tightening, through FINMA guidance and the AML reform, from a permissive starting point. Singapore tightened sharply between 2022 and 2025 and is now consolidating around tokenisation and institutional activity. A comparison true on 30 June 2026 may need revision within a year on the Singapore side and within three on the Swiss side.

The second is that practice differs from text more in some areas than others. In licensing and tax the text is a reliable guide in both systems. In banking access, in the willingness of a court to grant an unusual remedy and in the attitude of a prosecutor to a particular kind of victim, practice matters more than text and only experience tells. Where this book relies on practice it says so.

The third is that the global layer is changing both systems from outside. The FATF's standards, the FSB's 2023 framework, the Basel Committee's prudential treatment of crypto exposures, IOSCO's 2023 recommendations, the OECD's Crypto-Asset Reporting Framework and the European Union's MiCA each land in Swiss and Singapore law in a different way. A comparison that ignores them will mistake a global rule for a local one.¹ Part O, Chapters II to V set out that layer so that the reader can tell the two apart.

Practice note

When you compare a Swiss and a Singapore rule for a client, write down four things for each. Record the text of the rule with its source, the purpose the rule serves, how the regulator or court has applied it in practice and which way it is moving. Only when all four are on the page for both systems is the comparison safe to act on. Most errors in cross-border advice come from comparing the first line only. The tables in this book give the first line. The text gives the other three.

Notes

Financial Stability Board, "High-level Recommendations for the Regulation, Supervision and Oversight of Crypto-asset Activities and Markets", 17 July 2023; Basel Committee on Banking Supervision, "Prudential treatment of cryptoasset exposures" (SCO60), December 2022, amended July 2024; IOSCO, "Policy Recommendations for Crypto and Digital Asset Markets", 16 November 2023; Regulation (EU) 2023/1114 on markets in crypto-assets, OJ L 150 of 9 June 2023. ↩

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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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.