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Digital Assets: The Two Hubs: Why Switzerland and Singapore

Digital Assets: The Two Hubs: Why Switzerland and Singapore

The Two Hubs: Why Switzerland and Singapore — a part of the book Digital Assets Law in Singapore and Switzerland by Dr Alexander Ressos.

The Two Hubs: Why Switzerland and Singapore

The Two Hubs: Why Switzerland and Singapore: a part of the book Digital Assets Law in Singapore and Switzerland by Dr Alexander Ressos.

About the book

This part belongs to Digital Assets Law in Singapore and Switzerland by Dr Alexander Ressos, published here in full, section by section.

Singapore · Two Hubs

The Two Hubs: Why Switzerland and Singapore

Two small countries, one at the centre of Europe and one at the tip of the Malay peninsula, have become the places where serious digital-asset businesses choose to live. Read more
Singapore · Two Hubs

Who the reader is

A practitioner's handbook is only as good as its picture of the person holding it. This book assumes six kinds of reader, each with a different decision in front of them. Read more
Singapore · Two Hubs

The five decisions

Five decisions recur in almost every mandate, whatever the client's label. The first is where to incorporate. Read more
Singapore · Two Hubs

How to read the book

The book has seventeen parts and a set of annexes. Part A is the overview. Read more
Singapore · Two Hubs

The state of the law on 30 June 2026

A book about a fast-moving field must choose a date and keep to it. This book states the law as of 30 June 2026. The choice is deliberate. Read more
Singapore · Two Hubs

What the book does not do

The book does not describe the law of the European Union, the United States or any third jurisdiction except to the extent needed to understand a Swiss or Singapore rule or to advise a client who… Read more
Singapore · Two Hubs

The shared logic

Switzerland and Singapore are often mentioned in the same breath, usually by people who have been to neither. Read more
Singapore · Two Hubs

Where they differ

The resemblance is real but it stops at the surface of the legal system. Read more
Singapore · Two Hubs

One asset class, two vocabularies

The last difference is one of language. It is the one most likely to cause an error in a cross-border mandate. Read more
Singapore · Two Hubs

The geography of the Swiss hub

Switzerland's digital-asset industry has a capital, Zug, and three further centres with distinct profiles. Zug is where the protocols, the foundations and the early service providers settled. Read more
Singapore · Two Hubs

The DLT Act of 2021

Switzerland did not pass a crypto act. Read more
Singapore · Two Hubs

FINMA's taxonomy and the licence cascade

FINMA classifies tokens by their economic function into payment tokens, utility tokens and asset tokens, with hybrids possible, a scheme it announced in its ICO Guidelines of 16 February 2018 and… Read more
Singapore · Two Hubs

The banking bridge and the market infrastructure

The feature that most distinguishes Switzerland from other crypto hubs is that its banks take part. Read more
Singapore · Two Hubs

Switzerland in one chapter: Tax

Swiss tax law treats a payment token as a movable capital asset. Read more
Singapore · Two Hubs

Foundations and associations for protocols

Swiss private law offers two legal forms that have become standard wrappers for decentralised protocols. The foundation under Art. 80 ff. Read more
Singapore · Two Hubs

One regulator, one city

Singapore's regulatory architecture for digital assets can be understood from a single fact: the central bank is also the sole financial regulator, the licensing authority, the AML supervisor for… Read more
Singapore · Two Hubs

The Payment Services Act 2019 and the digital payment token licence

The Payment Services Act 2019 is the statute under which most Singapore crypto businesses are licensed. Read more
Singapore · Two Hubs

The pivot of 2022

Between 2017 and 2021 Singapore presented itself as a crypto hub and MAS was among the first regulators to publish a guide to token offerings, in November 2017, and to bring exchanges within a… Read more
Singapore · Two Hubs

The Financial Services and Markets Act 2022 and the DTSP regime

The Financial Services and Markets Act 2022 is MAS's umbrella statute. Read more
Singapore · Two Hubs

Stablecoins, tokenisation and Project Guardian

MAS finalised its framework for single-currency stablecoins on 15 August 2023. The framework applies to stablecoins pegged to the Singapore dollar or to a G10 currency and issued in Singapore. Read more
Singapore · Two Hubs

Retail restrictions

MAS began restricting retail access in January 2022 with Guidelines PS-G02, which told DPT service providers that trading in DPTs was not suitable for the general public. Read more
Singapore · Two Hubs

Tax neutrality

Singapore has no capital gains tax, no wealth tax and no inheritance tax. Read more
Singapore · Two Hubs

Why compare at all

A book about two legal systems could simply describe each in turn and leave the comparison to the reader. This book does not, for a practical reason. Read more
Singapore · Two Hubs

How the parts mirror each other

The Swiss and Singapore parts of this book follow the same sequence: foundations and institutions, private law, financial market regulation, AML and sanctions, taxation, and criminal law together… Read more
Singapore · Two Hubs

The seven axes

Part O, Chapter I compares the two systems along seven axes. Read more
Singapore · Two Hubs

What "arbitrage" legitimately means

Clients often arrive with the word "arbitrage" in mind and advisers often use it loosely. Read more
Singapore · Two Hubs

Where the method reaches its limits

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. Read more
Singapore · Two Hubs

Phase one: discovery, 2013–2017

Regulation of digital assets in Switzerland and Singapore was not designed on a blank sheet. Read more
Singapore · Two Hubs

Phase two: perimeter building, 2018–2021

The ICO boom produced the first failures and the first rules. In Switzerland the emblematic case was Envion. Read more
Singapore · Two Hubs

Phase three: the crash and the pivot, 2022–2024

The year 2022 is the hinge of the story. Read more
Singapore · Two Hubs

Phase four: consolidation, 2025–2026

By 2025 both hubs had decided what they wanted to be. Read more
Singapore · Two Hubs

What each failure changed

The following table pairs the principal failures with the rule or practice each produced. Read more
Singapore · Two Hubs

The global layer

Neither hub makes its rules alone. Five international bodies and one regional regulation set the frame within which Switzerland and Singapore legislate. Read more