Why Singapore has become a recovery hub

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A victim of token theft or fraud rarely knows at the outset who took the assets or where they are. What he knows is a transaction hash, a destination address and, after a few hours of blockchain analysis, the exchange deposit address at which the trail ends. The legal system that can convert that knowledge into a freeze at the exchange within days, compel the exchange to identify the account holder and then hold the assets until trial is the system in which recovery will happen. Since 2022 Singapore has been one of two or three such systems, alongside England and Hong Kong, for a combination of reasons. Its courts have held crypto assets to be property, have granted proprietary and worldwide freezing injunctions against persons unknown, have made disclosure orders against exchanges incorporated abroad but operating in Singapore and have permitted service by e-mail, social media and wallet message.¹ Many of the exchanges that matter have a Singapore licence or a Singapore office, so an order of the General Division of the High Court is obeyed without the delay of foreign enforcement.

The Swiss contrast frames this chapter. Switzerland has no proprietary injunction, no worldwide freezing order and no disclosure order against a third party outside pending proceedings. The civil attachment (Arrest) under Art. 271 ff. DEBA requires assets located in Switzerland and a prima facie claim, while the question whether a token is "located" anywhere remains open (see Part H, Chapter V). A Swiss claimant with a Singapore exchange at the end of the trail will therefore often litigate in Singapore first.

Notes

CLM v CLN and others [2022] SGHC 46 (Lee Seiu Kin J, 4 March 2022); Janesh s/o Rajkumar v Unknown Person ("CHEFPIERRE") [2022] SGHC 264 (Lee Seiu Kin J, 21 October 2022); ByBit Fintech Ltd v Ho Kai Xin and others [2023] SGHC 199 (Philip Jeyaretnam J, 25 July 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.

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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 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.

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