Crypto-assets: From the Payment Services Act to Project Guardian: summary

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Singapore brought cryptocurrency dealing and exchange under licence through the Payment Services Act 2019, in force since 28 January 2020, whose first purpose was to prevent money laundering and whose licensing process proved slow and selective. The collapses of 2022, from Terra and Three Arrows Capital to FTX and the loss of Temasek's investment, led the Monetary Authority to restrict retail access and to require segregation of customer assets in trust, while the extension of the Act to custody and to the facilitation of transfers took effect in 2024 and the courts recognised crypto-assets as property in ByBit Fintech Ltd v Ho Kai Xin in 2023. Since 30 June 2025, Part 9 of the Financial Services and Markets Act 2022 has required a licence for Singapore firms serving only foreign customers, a licence that the authority will generally not grant, which forced part of the industry to leave. The stablecoin framework of August 2023, with its requirements on reserves, capital, redemption at par and disclosure and its protected label, is being given statutory form through amendments to the Payment Services Act put to consultation in September 2026. Project Guardian, the wholesale central bank money trials and the BLOOM initiative express the other half of a consistent policy, which welcomes distributed ledger technology in the hands of regulated institutions while discouraging speculation and regulatory arbitrage.

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 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. 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 Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.