Where the rule is heading

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Three developments were visible at the state-of-law date. First, the FATF had signalled in its 2024 and 2025 updates that it would press jurisdictions on travel-rule implementation and on the treatment of unhosted wallets. That pressure may lead MAS to tighten its risk-based approach towards something closer to the Swiss proof-of-control requirement.¹ Second, the European Union's Transfer of Funds Regulation, applicable from 30 December 2024, applies the travel rule to crypto-asset service providers without a threshold and requires verification of ownership for self-hosted wallets above EUR 1,000. The EU standard is therefore close to the Swiss one, which increases pressure on Singapore to converge.² Third, the industry protocols were consolidating, with IVMS 101 universally adopted for content and a small number of networks interoperating, which reduces the operational excuse for non-compliance.

Notes

FATF, Targeted Update on Implementation of the FATF Standards on Virtual Assets and VASPs, June 2025, recommendations on travel-rule enforcement. ↩
Regulation (EU) 2023/1113 of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets, Art. 14 ff., applicable from 30 December 2024; see Part O, Chapter II. ↩

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

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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.

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