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: a part of the book Digital Assets Law in Singapore and Switzerland by Dr Alexander Ressos.
This part belongs to Digital Assets Law in Singapore and Switzerland by Dr Alexander Ressos, published here in full, section by section.
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 HubsWho 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 HubsThe five decisions
Five decisions recur in almost every mandate, whatever the client's label. The first is where to incorporate. Read more Singapore · Two HubsHow to read the book
The book has seventeen parts and a set of annexes. Part A is the overview. Read more Singapore · Two HubsThe 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 HubsWhat 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 HubsThe shared logic
Switzerland and Singapore are often mentioned in the same breath, usually by people who have been to neither. Read more Singapore · Two HubsWhere they differ
The resemblance is real but it stops at the surface of the legal system. Read more Singapore · Two HubsOne 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 HubsThe 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 HubsThe DLT Act of 2021
Switzerland did not pass a crypto act. Read more Singapore · Two HubsFINMA'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 HubsThe 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 HubsSwitzerland in one chapter: Tax
Swiss tax law treats a payment token as a movable capital asset. Read more Singapore · Two HubsFoundations 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 HubsOne 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 HubsThe 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 HubsThe 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 HubsThe 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 HubsStablecoins, 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 HubsRetail 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 HubsTax neutrality
Singapore has no capital gains tax, no wealth tax and no inheritance tax. Read more Singapore · Two HubsWhy 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 HubsHow 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 HubsThe seven axes
Part O, Chapter I compares the two systems along seven axes. Read more Singapore · Two HubsWhat "arbitrage" legitimately means
Clients often arrive with the word "arbitrage" in mind and advisers often use it loosely. Read more Singapore · Two HubsWhere 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 HubsPhase one: discovery, 2013–2017
Regulation of digital assets in Switzerland and Singapore was not designed on a blank sheet. Read more Singapore · Two HubsPhase 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 HubsPhase three: the crash and the pivot, 2022–2024
The year 2022 is the hinge of the story. Read more Singapore · Two HubsPhase four: consolidation, 2025–2026
By 2025 both hubs had decided what they wanted to be. Read more Singapore · Two HubsWhat each failure changed
The following table pairs the principal failures with the rule or practice each produced. Read more Singapore · Two HubsThe 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