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Where the regimes diverge

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The following table sets out the points at which a group cannot apply one rule to both entities without choosing. In each row the group must decide whether to apply the stricter standard throughout or to run two standards with a documented boundary.

TopicSingapore (PSN02, CDSA)Switzerland (AMLA, AMLO-FINMA, SRO regulations)Group approach
CDD threshold for occasional exchange transactionsNone, CDD for every DPT transactionCHF 1,000 for exchange of crypto assets (Art. 51a AMLO-FINMA, SRO equivalents)Apply Singapore rule (no threshold) group-wide if systems permit
Beneficial owner thresholdControl-based, 25% as practiceControlling person 25% (Art. 2a para. 3 AMLA), Form K/A declarationsCommon 25% with control override, Swiss forms used in both entities
PEP definitionForeign PEP always EDD, domestic and international-organisation PEP risk-basedSame structure (Art. 2a paras 1–2 AMLA), foreign PEP always high riskCommon definition, common EDD
Record retention5 years10 years (Art. 7 para. 3 AMLA)10 years group-wide
Travel rule information setReduced set below S$ 1,500Full set alwaysFull set always
Unhosted walletsRisk-based, verification encouragedProof of control requiredProof of control required group-wide
Reporting standardKnowledge or reasonable grounds to suspect, s. 45 CDSAReasonable suspicion (begründeter Verdacht), Art. 9 AMLA, as lowered by BGE 147 IV 274Common escalation, two filing procedures
Freeze after reportNo automatic freeze, firm's risk decisionFreeze only once MROS notifies within 40 working days (Art. 10 AMLA, Art. 23 para. 5 AMLA)Jurisdiction-specific
Tipping-offs. 57 CDSA, no statutory group exceptionArt. 10a AMLA, with intra-group exception (para. 3)Protocol in Section 6 below
SanctionsUN plus Russia measures, OFAC commerciallyUN plus full EU alignmentJurisdiction-specific screening lists, common process
AML auditIndependent audit function plus annual auditor report to MASAnnual AML audit by SRO or licensed audit firmCoordinated audit calendar, shared findings register

The pattern is that Singapore is stricter at onboarding (no threshold, CDD for every transaction) and Switzerland is stricter on transfers and retention (full travel-rule set, proof of control, ten years).1 A group that adopts the stricter rule in each row ends with a programme that exceeds both regimes and can be defended before either regulator as such. The cost is borne by the customer in friction and by the firm in systems. In my experience most groups accept the cost, because the alternative, two standards with a boundary, produces exactly the inconsistencies that inspectors find first.

Notes

  1. AMLA, Art. 7 para. 3 (ten-year retention), Art. 2a paras 1–3 (definitions of politically exposed persons and controlling persons); AMLO-FINMA, Art. 51a (CHF 1,000 threshold for exchange transactions in crypto assets, lowered from CHF 5,000 with effect from 1 January 2021); VQF, Regulations and Forms A, K, S and T for the establishment of beneficial owners and controlling persons. ↩

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.

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.