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Regulation and Supervision

Regulation and Supervision

Financial regulation in Singapore is concentrated in one institution. The articles collected here explain the Westminster model in a city-state, the sources of law, the legal force of MAS notices, guidelines and FAQs, MAS's mandate and philosophy, the licensing categories, the Payment Services Act 2019, the Securities and Futures Act 2001, the Financial Services and Markets Act 2022, stablecoins, tokenisation and the steps of a licence application. The colonial origins of the legal order are told in the financial centre book.

One regulator

The Monetary Authority of Singapore began operations on 1 January 1971. Its Act gives it a mandate that a European reader would expect to find divided among a central bank, a prudential supervisor, a conduct regulator and a development agency. Section 4(1) includes both fostering a sound and reputable financial centre and growing Singapore as an internationally competitive one.

ACRA administers company registration, and IRAS the tax system. Each of them publishes guidance that a newcomer will read before long.

Which licence

Digital payment token services fall under the Payment Services Act 2019, and capital markets products and fund management under the Securities and Futures Act 2001. Overseas-only digital token providers fall under Part 9 of the Financial Services and Markets Act 2022 since 30 June 2025.

For a foreign firm the first questions are which licence the planned activity requires and how the application runs. The book takes the stages of an application one at a time.

In this section

Start with Singapore I on foundations and the MAS approach, one institution, three roles or the legal force of MAS notices.

Singapore · Origins

The Treaties of 1824 and the Legal Foundations of British Singapore

The treaty of 6 February 1819 gave the East India Company a trading post on an island whose legal status was contested. The Dutch disputed the authority of the sultan who had signed it. Read more
Singapore · Origins

The Anglo-Dutch Treaty of 1824

The dispute over Singapore was one of several questions that divided Britain and the Netherlands in Asia after the Napoleonic Wars. Both powers had an interest in a settlement. Read more
Singapore · Origins

The Treaty of Friendship and Alliance of 1824

The agreement of 7 June 1823 had already transferred the judicial powers and land rights of the sultan and the Temenggong to the British in exchange for lifelong monthly payments of 1,500 and 800… Read more
Singapore · Origins

The Straits Settlements and the Second Charter of Justice

In 1826, the East India Company combined its three possessions in the Strait – Penang, Malacca and Singapore – into a single administrative unit, the Straits Settlements. Read more
Singapore · Origins

The reception of English law

The Second Charter did more than establish a court. Read more
Singapore · Origins

Land, title and the security of property

A financial centre depends on secure property rights. Land is the most important form of collateral. A mortgage is worth only as much as the title on which it rests. Read more
Singapore · Origins

Practical consequences for today’s practitioner

The history examined in this chapter is not merely of antiquarian interest. Several of its consequences confront the practitioner who advises on Singapore matters today. Read more
Singapore · Origins

Legal foundations and the comparison with Geneva

Geneva and Singapore built their financial centres on different legal traditions. Read more
Singapore · Origins

The Treaties of 1824 and the Legal Foundations of British Singapore: summary

The Anglo-Dutch Treaty of 17 March 1824 ended the Dutch objection to British Singapore, exchanged Bencoolen for Malacca and drew a border through the Singapore Strait that still separates Singapore… Read more
Singapore · Colonial Economy

Crown Colony: Government, Courts and Commercial Law after 1867

On 1 April 1867 the Straits Settlements ceased to be a dependency of British India and became a Crown colony, governed from London through the Colonial Office. Read more
Singapore · Colonial Economy

The transfer to the Colonial Office in 1867

By the 1850s the merchants of Singapore had accumulated a long list of complaints against the government in Calcutta. The most serious concerned currency. Read more
Singapore · Colonial Economy

The Legislative Council and the ordinances

The Crown colony was governed by a Governor appointed by the Crown, advised by an Executive Council composed entirely of official members. Read more
Singapore · Colonial Economy

Courts, the Privy Council and the legal profession

The transfer was followed by a reorganisation of the courts. The Judicial Duties Act of 1867 created the office of Chief Justice. Read more
Singapore · Colonial Economy

Company law, insolvency and currency

During the first half-century of the settlement, commerce in Singapore was conducted by individuals and partnerships. Read more
Singapore · Colonial Economy

Revenue without customs: the fiscal constitution of the free port

The Crown colony inherited the fiscal model of the free port. It levied no customs duties on general trade and financed itself largely through excise revenue, above all from opium. Read more
Singapore · Colonial Economy

The colonial codes in today’s financial crime practice

The Penal Code enacted by the colonial legislature in 1871 is still in force in Singapore today under the title Penal Code 1871, although it has been amended many times. Read more
Singapore · Colonial Economy

Law as a commercial asset

For the merchants of Singapore, the legal infrastructure of the Crown colony was an asset. Read more
Singapore · Colonial Economy

Crown Colony: Government, Courts and Commercial Law after 1867: summary

The merchants of Singapore, frustrated by currency policy, convicts, weak policing and neglect from Calcutta, petitioned in 1857 for Crown rule and obtained it when the Straits Settlements became a… Read more
Singapore · Independence

The Founding of the Monetary Authority of Singapore

On 1 January 1971 a new statutory body opened its doors in Singapore. Read more
Singapore · Independence

Monetary functions before 1971

Singapore entered independence with a monetary system inherited from the colonial period. Read more
Singapore · Independence

The Monetary Authority of Singapore Act 1970

The legislation came before Parliament in 1970, in a session that also dealt with the reform of banking law. Read more
Singapore · Independence

The Board of Commissioners of Currency

The Board of Commissioners of Currency, Singapore operated under the Currency Act 1967. Read more
Singapore · Independence

Exchange-rate-centred monetary policy

The Authority was born in turbulent times for the international monetary system. In August 1971, months after it opened, the United States suspended the convertibility of the dollar into gold. Read more
Singapore · Independence

Supervisory philosophy: prudence and reputation

The supervisory approach of the young Authority was shaped by its lack of a track record. Read more
Singapore · Independence

The Founding of the Monetary Authority of Singapore: practical consequences

For institutions and their advisers, the founding design of the Authority has lasting consequences. Read more
Singapore · Independence

The Founding of the Monetary Authority of Singapore: the comparison with Geneva and Hong Kong

Switzerland followed a sequence that reverses Singapore's. Read more
Singapore · Independence

The Founding of the Monetary Authority of Singapore: summary

Before 1971 the functions of a central bank in Singapore were scattered across a currency board and several departments, an arrangement that Goh Keng Swee called “an untidy system of units” and that… Read more
Singapore · Wealth Management

The Regulatory Architecture: MAS, the Banking Act, the SFA, the FAA and the FSMA

A financial centre that manages wealth for clients from many countries sells, among other things, the quality of its supervision. Read more
Singapore · Wealth Management

The Monetary Authority of Singapore as integrated regulator

After Parliament had passed the Monetary Authority of Singapore Act in 1970, MAS was formed on 1 January 1971. Read more
Singapore · Wealth Management

The Banking Act and private banking

The Banking Act has a longer history than its date suggests. A banking bill was first introduced in Parliament in 1962, although questions surrounding a new currency delayed the legislation. Read more
Singapore · Wealth Management

The Securities and Futures Act and capital markets services

Before 2002, Singapore’s capital markets were governed by several statutes, including the Securities Industry Act and the Futures Trading Act. Read more
Singapore · Wealth Management

The Financial Advisers Act

The Financial Advisers Act came into force together with the SFA on 1 October 2002. Read more
Singapore · Wealth Management

The Financial Services and Markets Act 2022

By the early 2020s, MAS’s powers were scattered across many statutes. Read more
Singapore · Wealth Management

Individual accountability and conduct

On 10 September 2020 MAS issued Guidelines on Individual Accountability and Conduct. They set five outcomes that financial institutions are expected to achieve. Read more
Singapore · Wealth Management

The Regulatory Architecture: MAS, the Banking Act, the SFA, the FAA and the FSMA: practical consequences

For a foreign group that wants to serve wealthy clients from Singapore, the architecture described in this chapter translates into a series of concrete decisions. The first concerns the vehicle. Read more
Singapore · Wealth Management

The Regulatory Architecture: MAS, the Banking Act, the SFA, the FAA and the FSMA: Comparison with Geneva and Hong Kong

The Swiss framework described in the Geneva volume rests on the Banking Act, the Financial Institutions Act, the Financial Services Act, the Collective Investment Schemes Act, the Financial Market… Read more
Singapore · Wealth Management

The Regulatory Architecture: MAS, the Banking Act, the SFA, the FAA and the FSMA: summary

The Monetary Authority of Singapore, founded on 1 January 1971, gradually took over the supervision of insurance, securities and currency issue and now acts as both central bank and integrated… Read more
Singapore · Wealth Management

Fund Management, External Asset Managers and Licensing

A wealthy family that moves its assets to Singapore rarely deals with a single institution. Read more
Singapore · Wealth Management

Licensing of fund management companies

For most of the period after the Securities and Futures Act 2001 came into force, a large part of Singapore’s fund management industry operated without a licence. Read more
Singapore · Wealth Management

Accredited and institutional investors

The distinction between retail and A/I managers rests on the classes of investors defined in section 4A of the Securities and Futures Act. Read more
Singapore · Wealth Management

External asset managers and custodian banks

An external asset manager, often called an independent asset manager, manages the portfolios of private clients without holding their assets. Read more
Singapore · Wealth Management

Compliance functions and the external compliance officer

MAS expects every manager to have compliance arrangements that match the nature, scale and complexity of its business. Read more
Singapore · Wealth Management

Fund Management, External Asset Managers and Licensing: practical consequences

A client who entrusts assets to a Singapore manager should first establish its regulatory status. Read more
Singapore · Wealth Management

Comparison with the Swiss regime for portfolio managers

Switzerland brought its independent asset managers under prudential supervision only with the Financial Institutions Act of 15 June 2018, which entered into force on 1 January 2020 together with the… Read more
Singapore · Wealth Management

Fund Management, External Asset Managers and Licensing: summary

Every company that carries on business in fund management in Singapore needs a capital markets services licence under the Securities and Futures Act, and since the repeal of the registered regime on… Read more
Singapore · Singapore 2035

Sustainable Finance and Carbon Markets

Sustainable finance came late to Singapore. Read more
Singapore · Singapore 2035

The green finance action plan

Singapore’s turn to green finance was announced as policy before the market demanded it. Read more
Singapore · Singapore 2035

Taxonomy and disclosure

A taxonomy is a classification system that states which economic activities count as sustainable. It is the dictionary on which green labels, grant eligibility and disclosure depend. Read more
Singapore · Singapore 2035

Carbon tax and carbon credits

Singapore introduced Southeast Asia’s first carbon tax on 1 January 2019. The legal basis is the Carbon Pricing Act 2018 and its regulations. Read more
Singapore · Singapore 2035

Transition finance in Asia

The transition question in Asia is above all a question of coal. Asia accounts for about half of global greenhouse gas emissions, roughly a third of which come from coal-fired power plants. Read more
Singapore · Singapore 2035

Greenwashing and liability

Greenwashing, the presentation of products or activities as more sustainable than they are, is the legal risk that accompanies the growth of the field. Read more
Singapore · Singapore 2035

Sustainable Finance and Carbon Markets: practical consequences

For banks, insurers and asset managers in Singapore, sustainable finance has become a matter of risk management and conduct, and only in the second place a business opportunity. Read more
Singapore · Singapore 2035

Singapore and Geneva: two routes to sustainable finance

Geneva and Singapore have both made sustainable finance a strategic field, from different starting points and with different instruments. Read more
Singapore · Singapore 2035

Sustainable Finance and Carbon Markets: summary

Singapore turned sustainable finance into a strategic field of its financial centre through the Green Finance Action Plan of 2019 and the Finance for Net Zero Action Plan of 2023, using grants,… Read more
Singapore · Legal Order

Singapore I: Foundations and the MAS Approach

A Swiss or German lawyer who opens the Payment Services Act 2019 for the first time meets a text that looks familiar and behaves differently. Read more
Singapore · Legal Order

The Westminster model in a city state

Singapore is a unitary republic with a written Constitution that declares itself the supreme law of the land. Parliament is unicameral. Read more
Singapore · Legal Order

Sources of law and how to cite them

Singapore law has four layers. At the top stands the Constitution. Below it sit the Acts of Parliament. Read more
Singapore · Legal Order

Common law, equity and the reception of English law

The civil lawyer's hardest adjustment is the idea that a large part of the applicable law has never been enacted. The Application of English Law Act 1993 settles the matter in two sentences. Read more
Singapore · Legal Order

The courts

The Supreme Court of Judicature Act 1969 structures the superior courts. Read more
Singapore · Legal Order

Precedent and how to read a Singapore judgment

The doctrine of binding precedent operates vertically. Decisions of the Court of Appeal bind the Appellate Division, the General Division and the State Courts. Read more
Singapore · Legal Order

Statutory interpretation

Section 9A(1) of the Interpretation Act 1965 directs that an interpretation which would promote the purpose or object underlying a written law is to be preferred to one that would not. Read more
Singapore · Legal Order

The legal force of MAS notices, guidelines, circulars and FAQs

The instrument that most confuses foreign readers is the MAS Notice. A notice is a written direction issued by MAS under a statutory power to a class of financial institutions. Read more
Singapore · Legal Order

The legal profession and the foreign lawyer

Legal practice in Singapore is governed by the Legal Profession Act 1966. Advocates and solicitors admitted to the Singapore Bar may practise Singapore law. Read more
Singapore · Legal Order

Reading the system as a whole

For a lawyer from Zug the Singapore legal order presents a paradox. Read more
Singapore · Legal Order

One institution, three roles

The Monetary Authority of Singapore was established by the Monetary Authority of Singapore Act 1970 and began operations on 1 January 1971. Read more
Singapore · Legal Order

The Managing Directors and the institutional voice

Ravi Menon served as Managing Director from 2011 until 31 December 2023 and shaped the digital-asset policy described in Chapter III. Read more
Singapore · Legal Order

The Financial Services and Markets Act 2022 as umbrella

Singapore's financial legislation grew Act by Act. The Banking Act 1970, the Insurance Act 1966, the Securities and Futures Act 2001 and the Financial Advisers Act 2001 each regulate one sector. Read more
Singapore · Legal Order

MAS's regulatory philosophy

MAS describes its approach with a set of phrases that recur in every consultation paper and that a practitioner should learn to decode. Read more
Singapore · Legal Order

Licensing categories relevant to digital assets

The licence a digital-asset business needs depends on the function its product performs. Six regimes cover the field. Read more
Singapore · Legal Order

Enforcement powers

MAS enforces through a graduated set of tools that it describes in its Enforcement Monograph and reports on in a periodic Enforcement Report. Read more
Singapore · Legal Order

Supervision in practice

Supervision of a digital payment token licensee is conducted by the department responsible for payments, with the anti-money-laundering department and the technology risk specialists involved as… Read more
Singapore · Legal Order

Reading MAS from Zug

A client who has dealt with FINMA will find MAS both more and less demanding. Read more
Singapore · Legal Order

Why the history matters

A regulator's current rules are the sediment of its past decisions, and nowhere is this truer than in Singapore's treatment of digital assets. Read more
Singapore · Legal Order

Phase one, 2014–2016: watching and warning

MAS made its first public statement on virtual currencies on 13 March 2014. Read more
Singapore · Legal Order

Phase two, 2017–2019: the ICO wave and the Guide

The initial coin offering boom of 2017 reached Singapore quickly, and several of the largest token sales of that year were conducted through Singapore entities. MAS responded in two steps. Read more
Singapore · Legal Order

Phase three, 2020–2021: licensing and the Binance episode

The Payment Services Act 2019 came into force on 28 January 2020. Read more
Singapore · Legal Order

Phase four, 2022: the collapses and the doctrine

The year 2022 changed Singapore's policy more than any other. In May the Terra ecosystem collapsed. Its developer, Terraform Labs, was a Singapore-incorporated company. Read more
Singapore · Legal Order

Phase five, 2023–2024: building the new regime

MAS published its responses in stages. Read more
Singapore · Legal Order

Phase six, 2024–2026: the overseas-only providers

The last building block addressed a problem that had embarrassed MAS since the Three Arrows and Terraform collapses: entities incorporated in Singapore that served no Singapore customers and… Read more
Singapore · Legal Order

The state of play at 30 June 2026

At the cut-off date of this book Singapore's digital-asset regulation rested on five pillars. Read more
Singapore · Legal Order

Lessons for the practitioner

Four lessons follow from the history. Read more
Singapore · Legal Order

The shape of the market

Singapore's digital-asset market is small in the number of licensed firms and large in the weight of the institutions behind them. Read more
Singapore · Legal Order

Licensed exchanges, brokers and custodians

The first full licences for digital payment token services were granted in late 2021 to Independent Reserve, an Australian-founded exchange, and to DBS Vickers, the brokerage arm of DBS Bank. Read more
Singapore · Legal Order

The banks

Singapore's three domestic banks, DBS, OCBC and UOB, are all participants in the digital-asset market in a way no Swiss systemic bank was before 2024. Read more
Singapore · Legal Order

Market infrastructure: SGX, ADDX, Marketnode

Singapore Exchange has approached digital assets through investments and joint ventures. It holds the stake in DBS Digital Exchange mentioned above. Read more
Singapore · Legal Order

Project Guardian, Global Layer One and Project Orchid

Project Guardian was launched on 31 May 2022 by MAS with DBS, J.P. Morgan and Marketnode as the first pilot participants. Read more
Singapore · Legal Order

The family-office wave

The rise of the Singapore single family office is the second large development of the period and the one most relevant to the private-client reader. Read more
Singapore · Legal Order

Venture capital, sovereign funds and talent

Temasek, GIC and the venture arms of the banks have invested across the digital-asset industry. Read more
Singapore · Legal Order

Choosing a counterparty in Singapore

The ecosystem just described presents a client with choices that did not exist in 2020, and the choices carry legal consequences that the marketing material does not mention. Read more
Singapore · Legal Order

How the ecosystem compares with Crypto Valley

The two ecosystems differ in origin and in texture. Crypto Valley grew from below. Read more
Singapore · Legal Order

The regional contest

Singapore does not choose its digital-asset policy in isolation. Within a six-hour flight lie Hong Kong, Tokyo, Dubai, Bangkok, Kuala Lumpur and Jakarta, each with a regime of its own. Read more
Singapore · Legal Order

Hong Kong

Hong Kong is the comparison that matters for three reasons. Read more
Singapore · Legal Order

Dubai and the United Arab Emirates

Dubai created in 2022 the first regulator in the world devoted solely to virtual assets. Law No. 4 of 2022 Regulating Virtual Assets in the Emirate of Dubai was issued on 28 February 2022. Read more
Singapore · Legal Order

Japan

Japan regulated crypto exchanges earlier than anyone. Read more
Singapore · Legal Order

The ASEAN context

Singapore's immediate neighbours have each taken a position, and together they define the regional market that a Singapore-licensed firm serves. Read more
Singapore · Legal Order

Why clients compare Singapore and Hong Kong, and how I answer

In my experience the question arrives in one of three forms. A founder asks where to put the Asian headquarters of an exchange or a stablecoin issuer. Read more
Singapore · Legal Order

Cooperation among the regulators

Competition between the hubs coexists with cooperation among their regulators, and a client who structures across them should know how much the regulators tell each other. Read more
Singapore · Legal Order

A decision sequence for the Asian hub

The analysis of this chapter can be reduced to a sequence of questions that a Swiss group should answer in order. Read more
Singapore · Legal Order

The regional map and the Swiss reader

For a Swiss practitioner the lesson of this chapter is that Singapore's regulatory severity is a chosen position within a competitive region. Read more
Singapore · Legal Order

Why a map of institutions is needed

The civil-law reader who has absorbed Chapters I to V knows that Singapore regulates through one legislature, one regulator and one court hierarchy. Read more
Singapore · Legal Order

The Monetary Authority of Singapore from the inside

MAS is organised in groups and departments whose names change from time to time, but whose functions have been stable since the reorganisation that followed the 2015 creation of the FinTech and… Read more
Singapore · Legal Order

The Accounting and Corporate Regulatory Authority

ACRA was formed on 1 April 2004 by the Accounting and Corporate Regulatory Authority Act 2004 through the merger of the Registry of Companies and Businesses and the Public Accountants Board. Read more
Singapore · Legal Order

The Inland Revenue Authority of Singapore

IRAS was established on 1 September 1992 by the Inland Revenue Authority of Singapore Act 1992. Read more
Singapore · Legal Order

The Commercial Affairs Department and STRO

The Commercial Affairs Department (CAD) is the specialist white-collar crime unit of the Singapore Police Force and the body that investigates fraud, cheating, criminal breach of trust, market… Read more
Singapore · Legal Order

Who the actors are: the Attorney-General's Chambers

The Attorney-General is appointed under Article 35 of the Constitution and is both the Government's chief legal adviser and the Public Prosecutor, with control of all criminal prosecutions. Read more
Singapore · Legal Order

The Singapore Academy of Law

The Singapore Academy of Law (SAL) is a statutory body established by the Singapore Academy of Law Act 1988 of which every advocate and solicitor, every judge and every legal officer of the… Read more
Singapore · Legal Order

Industry associations and the private layer

The Blockchain Association Singapore (BAS), formed in 2018, is the principal industry body for digital-asset firms. Read more
Singapore · Legal Order

Other public bodies a client will meet

Each of these bodies appears in a later Part. The point of listing them here is to show the civil-law reader that "one regulator" does not mean "one authority". Read more
Singapore · Legal Order

Approaching the actors: a sequence

A Swiss or German group establishing a regulated digital-asset business in Singapore meets the actors in roughly this order, which should be planned. - Singapore counsel, admitted under the Legal… Read more
Singapore · Legal Order

Closing the Part

This Part has described the legal order, the regulator, the policy history, the market, the region and the actors. The remaining Singapore Parts build on it. Read more
Singapore · Regulation

Singapore III: Regulation — PSA, SFA, FSMA/DTSP, Stablecoins, Tokenisation

Singapore regulates digital assets through three statutes that were written at different times for different purposes and that now overlap on the same business models. Read more
Singapore · Regulation

Purpose and architecture of the Act

The Payment Services Act 2019 (PSA) replaced the Payment Systems (Oversight) Act and the Money-changing and Remittance Businesses Act with a single licensing statute for payment services. Read more
Singapore · Regulation

The definition of a digital payment token

Everything in the crypto limb of the Act depends on the statutory definition of a digital payment token (DPT). Read more
Singapore · Regulation

The digital payment token service after the 2021 amendments

The original 2019 definition of a DPT service covered two activities: dealing in DPTs, meaning buying or selling DPTs in exchange for money or other DPTs, and facilitating the exchange of DPTs where… Read more
Singapore · Regulation

Standard and major payment institutions compared

The two licence classes share the same scope of permitted services but differ in volume, capital, safeguarding and ongoing cost. The table summarises the position as at 30 June 2026. Read more
Singapore · Regulation

Exemptions and the "incidental" argument

The Act exempts certain persons entirely, beginning with banks, merchant banks, finance companies and certain licensed insurers, which are exempt payment service providers under s. 13. Read more
Singapore · Regulation

The e-money and digital payment token boundary

E-money is defined in s. 2(1) of the Act as electronically stored monetary value that is denominated in or pegged to a currency, has been paid for in advance to enable payment transactions, is… Read more
Singapore · Regulation

The licensing timeline since January 2020

The Act commenced on 28 January 2020 with a grace period. Read more
Singapore · Regulation

What the licence is and what it is not

A digital payment token licence is not a separate category of licence under the Payment Services Act 2019. Read more
Singapore · Regulation

Application contents

MAS publishes the application form and a licensing guide on its website. The form for the digital payment token service is longer than for any other service. Read more
Singapore · Regulation

Base capital and financial requirements

The base capital for a standard payment institution is S$ 100,000 and for a major payment institution S$ 250,000. Read more
Singapore · Regulation

Segregation and custody of customers' tokens

The segregation regime is the single most important change to DPT regulation since the Act commenced. Read more
Singapore · Regulation

Fit and proper and the Singapore-resident management requirement

MAS applies the Guidelines on Fit and Proper Criteria to every applicant, controller, director and chief executive. Read more
Singapore · Regulation

Technology risk management

The MAS Technology Risk Management Guidelines of January 2021 are guidelines, whereas the Notice on Technology Risk Management is binding. Read more
Singapore · Regulation

Ongoing obligations after licensing

Licensing is the beginning of the compliance relationship, whose ongoing obligations are heavier than many applicants expect. Read more
Singapore · Regulation

Timelines and outcomes

MAS does not commit to a processing time for payment licence applications and states only that the time depends on the completeness of the application and the complexity of the business. Read more
Singapore · Regulation

Comparison with the Swiss route

A Swiss reader will compare the DPT licence with the Swiss alternatives. Read more
Singapore · Regulation

The policy turn of 2022

Until 2022 Singapore's approach to retail participation in crypto assets rested on disclosure. Read more
Singapore · Regulation

Who is a retail customer

The measures apply to retail customers, who are defined as persons who are neither accredited investors nor institutional investors within the meaning of the Securities and Futures Act 2001. Read more
Singapore · Regulation

The risk awareness assessment

A DPT provider must assess whether a retail customer has sufficient knowledge of the risks of DPT services before providing any such service. Read more
Singapore · Regulation

Prohibited inducements and credit

Three prohibitions follow. First, a provider may not offer any incentive, monetary or otherwise, to prospective or existing retail customers. Read more
Singapore · Regulation

Business conduct: conflicts, listing and complaints

The conduct measures go beyond retail customers and apply to the provider's whole business. Read more
Singapore · Regulation

Marketing: PS-G02 and the "public spaces" rule

The Part 2 response extended the Notice on Technology Risk Management (PSN05) to DPT service providers, with a nine-month transition from early 2024. Read more
Singapore · Regulation

Supervision and enforcement of the measures

The restriction on lending and staking of retail customers' tokens is formally part of the segregation regime in the Payment Services Regulations. Read more
Singapore · Regulation

Open questions at mid-2026

Three questions remained unsettled on 30 June 2026. The first is whether the risk awareness assessment will acquire a validity period. Read more
Singapore · Regulation

A timeline of the measures

A timeline of the measures: a section of the book. Read more
Singapore · Regulation

Consumer Access and Business Conduct Measures: the Swiss comparison

Switzerland has no retail access regime for crypto assets. Read more
Singapore · Regulation

The securities perimeter and why it comes second

The Securities and Futures Act 2001 (SFA) is the older and larger statute. Read more
Singapore · Regulation

Capital markets products

The SFA defines capital markets products in s. 2(1) as securities, units in a collective investment scheme, derivatives contracts, spot foreign exchange contracts for the purposes of leveraged… Read more
Singapore · Regulation

When a token is not a capital markets product

The Guide's case studies and the 2025 revision confirm that a token conferring only a right to use a service is outside the SFA, provided it carries no claim to profits, no debt and no pooled… Read more
Singapore · Regulation

Prospectus requirements and exemptions

An offer of securities or of units in a CIS to persons in Singapore must be made with a prospectus registered by MAS unless an exemption applies. Read more
Singapore · Regulation

Licensing of intermediaries

The SFA regulates the intermediaries around a token as well as the offer. Read more
Singapore · Regulation

Markets: approved exchanges and recognised market operators

A platform on which tokenised capital markets products are traded is operating an organised market. Read more
Singapore · Regulation

MAS case examples

The case studies in the Guide give the clearest view of MAS's reasoning. Several are summarised here in anonymised form, as they appear in the published document. Read more
Singapore · Regulation

Tokenised capital markets products and the 2025 Guide

The 2025 Guide addresses the questions that the tokenisation of conventional securities raises and that the ICO-era Guide did not. Read more
Singapore · Regulation

Comparison with Swiss prospectus and ledger-based securities law

Switzerland and Singapore reach similar outcomes on the perimeter by different roads. Read more
Singapore · Regulation

An umbrella statute with a crypto-specific Part

The Financial Services and Markets Act 2022 (FSMA) was enacted as No. 18 of 2022 and assented to on 25 April 2022. Read more
Singapore · Regulation

Who is a digital token service provider

Part 9 applies to two kinds of person. Read more
Singapore · Regulation

The "extremely limited circumstances" statement

MAS consulted on the Part 9 licensing framework in February 2022 and again on the detailed requirements in October 2024, with the second consultation closing on 4 November 2024. Read more
Singapore · Regulation

Licence conditions and ongoing requirements

For the few persons who are licensed, the regime is fully specified. Read more
Singapore · Regulation

Who had to leave or restructure

The population affected by Part 9 was larger than MAS's statements suggested. Three groups can be distinguished. Read more
Singapore · Regulation

Interaction with the Payment Services Act and the SFA

The three statutes form a hierarchy. The Payment Services Act and the SFA are the main Acts and apply to services provided in Singapore or to persons in Singapore. Read more
Singapore · Regulation

Technology-neutral powers under the FSMA

Beyond Part 9, the FSMA gives MAS powers that affect every digital asset firm it regulates. Read more
Singapore · Regulation

Penalties and enforcement

Carrying on a business of providing a digital token service without a Part 9 licence is an offence. Read more
Singapore · Regulation

Assessment

Part 9 is the clearest statement of Singapore's policy on digital assets since the 2022 collapses. The regime does not seek to attract firms. Read more
Singapore · Regulation

Why Singapore built a separate framework

A stablecoin is a token whose issuer or protocol promises that it will hold its value against a reference asset, usually a fiat currency. Singapore's interest in stablecoins is not speculative. Read more
Singapore · Regulation

The requirements

An SCS issuer must hold reserve assets whose value is at least 100 per cent of the par value of the SCS in circulation at all times. The reserve assets must consist of very low-risk instruments. Read more
Singapore · Regulation

The licensing construction

MAS implemented the framework through the Payment Services Act by creating a new regulated payment service, the "stablecoin issuance service". Read more
Singapore · Regulation

Legislative implementation and the state at 30 June 2026

The August 2023 response stated that the detailed requirements, the legislative amendments and the transitional arrangements would be published at a date to be confirmed. Read more
Singapore · Regulation

Singapore stablecoins in the market

The leading Singapore-dollar stablecoin is XSGD, issued by StraitsX, a company within the Fazz group that holds an MPI licence for e-money issuance and DPT services. Read more
Singapore · Regulation

Bank-issued tokenised deposits

The framework distinguishes an SCS from a tokenised bank deposit. Read more
Singapore · Regulation

Interaction with the e-money regime

Until the stablecoin issuance service is enacted, an SCS issuer is licensed for e-money issuance, because an SCS pegged to a currency with a redemption claim meets the definition of e-money in s.… Read more
Singapore · Regulation

Stablecoins: the Swiss comparison

Switzerland has no stablecoin statute. FINMA classifies stablecoins under existing law in its 2019 supplement to the ICO Guidelines and in Guidance 06/2024. Read more
Singapore · Regulation

Singapore's strategic bet

Singapore's regulators drew a sharp line in 2022 between crypto speculation, which they set out to contain, and the tokenisation of regulated financial assets, which they set out to lead. Read more
Singapore · Regulation

Project Guardian

MAS launched Project Guardian on 31 May 2022 as a collaborative initiative with the financial industry to test the feasibility of asset tokenisation and decentralised finance applications while… Read more
Singapore · Regulation

Global Layer One and the frameworks of November 2024

In November 2023 MAS announced Global Layer One (GL1), an initiative to develop a shared ledger infrastructure for tokenised assets that regulated financial institutions could use across borders. Read more
Singapore · Regulation

The regulatory treatment of tokenised securities

The SFA applies to a tokenised security as to the security it represents, which produces four regulatory questions for every tokenised issuance. Read more
Singapore · Regulation

The venues

Singapore has three principal regulated venues and infrastructures for tokenised securities, each with a different model. Read more
Singapore · Regulation

Tokenised deposits and wholesale CBDC

The settlement asset for tokenised securities has been the open question of the programme. A tokenised bond that settles against a conventional bank transfer loses the benefit of atomic settlement. Read more
Singapore · Regulation

The 2025–2026 roadmap

The programme's stated aim for 2025 and 2026 was commercialisation: the transition from pilots funded by participants to products offered to clients at scale. Three developments mark the period. Read more
Singapore · Regulation

Tokenisation and Market Infrastructure: the Swiss comparison

Switzerland and Singapore have taken opposite approaches to the same problem and have, so far, arrived at different market structures. Switzerland changed its private law. Read more
Singapore · Regulation

The problem that yield products present

Every yield product in the token economy rests on the same structure. A customer hands tokens to a provider. Read more
Singapore · Regulation

The retail prohibition

MAS announced in its Part 1 response of 3 July 2023 that it would restrict DPT service providers from facilitating the lending and staking of tokens by their retail customers. Read more
Singapore · Regulation

Staking for institutional and accredited customers

Staking remains available to accredited and institutional investors. The question for a provider is how the activity is classified under the Acts. Read more
Singapore · Regulation

Lending

Token lending takes two forms that regulation treats differently. In the first, the customer lends tokens to the provider, which uses them as it sees fit and promises a return. Read more
Singapore · Regulation

Yield products as collective investment schemes or structured products

The third category of yield product packages tokens into an instrument. Read more
Singapore · Regulation

The Hodlnaut and Vauld lessons

The insolvency proceedings of 2022 and 2023 are examined in Part J, Chapter V and Part N, Chapter IV. Three regulatory lessons belong here. Read more
Singapore · Regulation

Staking, Lending and Yield in Singapore: the Swiss comparison

Switzerland reached a different equilibrium through its banking law. Read more
Singapore · Regulation

Three problems at the edge of the perimeter

The three subjects of this chapter share one feature. Each presents an activity that the statutes were not written for and that the regulator must either fit into an existing category or leave alone. Read more
Singapore · Regulation

Decentralised finance

MAS has approached decentralised finance from two directions at once. Through Project Guardian it has actively tested DeFi mechanisms among regulated institutions. Read more
Singapore · Regulation

Non-fungible tokens

MAS stated its position on NFTs in a Parliamentary reply in February 2022, at the height of the NFT market. Read more
Singapore · Regulation

DAOs and the Singapore "foundation"

A decentralised autonomous organisation has no legal personality under Singapore law. It is a set of smart contracts and a group of token holders who vote on proposals. Read more
Singapore · Regulation

DeFi, NFTs and DAOs in Singapore: the Swiss comparison

Switzerland and Singapore have reached the same place on DeFi by different routes. Both ask whether an identifiable person controls the protocol and profits from it. Read more
Singapore · Regulation

The shape of the process

Chapters II, IV and V have described what each Singapore licence requires. Read more
Singapore · Regulation

Stage one: preparation and pre-application engagement

The preparation stage decides the outcome. MAS does not run a pre-application meeting as of right. Read more
Singapore · Regulation

Stage two: submission

Applications are submitted electronically through the MAS licensing portal, with the applicant's Corppass credentials, using the prescribed form for a payment institution licence and the… Read more
Singapore · Regulation

Stage three: substantive review

The substantive review is conducted by a case officer in the payments licensing team, with input from the AML, technology risk and legal functions. Read more
Singapore · Regulation

Common deficiencies

Applications stall for predictable reasons. The list below is drawn from the matters that have delayed or ended the applications I have seen. Read more
Singapore · Regulation

Stage four: the independent assessment

The independent assessment is a report by an external party, usually an audit firm or a specialist consultancy, on the adequacy of the applicant's AML/CFT framework and, for DPT applicants, of its… Read more
Singapore · Regulation

Stage five: in-principle approval

MAS grants in-principle approval (IPA) when it is satisfied with the application subject to conditions that must be met before the licence is issued. The IPA letter lists the conditions. Read more
Singapore · Regulation

Stage six: grant and post-licence obligations

On satisfaction of the IPA conditions MAS issues the licence, which specifies the licence class, the payment services covered and the conditions attached. Read more
Singapore · Regulation

The capital markets services licence and the Part 9 licence

The process for a CMS licence under the SFA follows the same stages with different content. The application form is the SFA form for the regulated activities sought. Read more
Singapore · Regulation

How a Swiss group obtains a Singapore licence

A Swiss group that holds SRO affiliation, a FinIA licence or a banking licence and wants to serve Asian customers from Singapore has a head start in three respects and a handicap in one. Read more
Singapore · Regulation

How a Singapore group obtains a Swiss licence

The reverse route is shorter at the first step and longer at the last. Read more
Singapore · Reference

Table of legislation

This table lists the statutes, ordinances and international instruments cited in the book. Read more
Singapore · Reference

Switzerland: federal acts

Switzerland: federal acts: a section of the book. Read more
Singapore · Reference

Switzerland: ordinances

Switzerland: ordinances: a section of the book. Read more
Singapore · Reference

Table of legislation: Singapore

Table of legislation: Singapore: a section of the book. Read more
Singapore · Reference

European Union

European Union: a section of the book. Read more
Singapore · Reference

International instruments and standards

International instruments and standards: a section of the book. Read more
Singapore · Reference

Table of regulator guidance

Regulator guidance has no force of law in either hub, yet it governs daily practice in both. In Switzerland, FINMA guidance and circulars state how the authority reads the statutes it enforces. Read more
Singapore · Reference

FINMA

FINMA: a section of the book. Read more
Singapore · Reference

MAS

MAS: a section of the book. Read more
Singapore · Reference

FTA/ESTV and cantonal tax administrations

FTA/ESTV and cantonal tax administrations: a section of the book. Read more
Singapore · Reference

IRAS

IRAS: a section of the book. Read more
Singapore · Reference

SECO

SECO: a section of the book. Read more