Alexander Ressos博士对照瑞士论述新加坡数字资产法：MAS的监管方针、财产与信托、《支付服务法》与《证券与期货法》、反洗钱与制裁、税务、执法、架构设计以及实用工具包。法律截至2026年6月30日。
Alexander Ressos博士对照瑞士论述新加坡数字资产法：MAS的监管方针、财产与信托、《支付服务法》与《证券与期货法》、反洗钱与制裁、税务、执法、架构设计以及实用工具包。法律截至2026年6月30日。
本书每一节都作为单独的文章连同脚注按全书顺序在此发布。各篇文章均可单独阅读。各部分页面汇集了该部分的各章。
两大枢纽：为何是瑞士和新加坡
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读者是谁
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五项决策
Five decisions recur in almost every mandate, whatever the client's label. The first is where to incorporate. Read more Singapore · Two Hubs本书阅读指南
The book has seventeen parts and a set of annexes. Part A is the overview. Read more Singapore · Two Hubs截至2026年6月30日的法律状况
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本书不涉及的内容
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共同的逻辑
Switzerland and Singapore are often mentioned in the same breath, usually by people who have been to neither. Read more Singapore · Two Hubs两者的差异
The resemblance is real but it stops at the surface of the legal system. Read more Singapore · Two Hubs同一资产类别，两套术语
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瑞士枢纽的地理分布
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 Hubs2021年《DLT法》
Switzerland did not pass a crypto act. Read more Singapore · Two HubsFINMA的分类体系与牌照阶梯
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银行桥梁与市场基础设施
The feature that most distinguishes Switzerland from other crypto hubs is that its banks take part. Read more Singapore · Two Hubs一章读懂瑞士：税务
Swiss tax law treats a payment token as a movable capital asset. Read more Singapore · Two Hubs协议的基金会与社团
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一个监管机构，一座城市
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 Hubs2019年《支付服务法》与数字支付代币牌照
The Payment Services Act 2019 is the statute under which most Singapore crypto businesses are licensed. Read more Singapore · Two Hubs2022年的转向
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 Hubs2022年《金融服务与市场法》与DTSP制度
The Financial Services and Markets Act 2022 is MAS's umbrella statute. Read more Singapore · Two Hubs稳定币、代币化与Guardian项目
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零售限制
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税收中性
Singapore has no capital gains tax, no wealth tax and no inheritance tax. Read more Singapore · Two Hubs为何要进行比较
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各部分如何相互对应
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七个维度
Part O, Chapter I compares the two systems along seven axes. Read more Singapore · Two Hubs“套利”的正当含义
Clients often arrive with the word "arbitrage" in mind and advisers often use it loosely. Read more Singapore · Two Hubs方法的局限
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第一阶段：发现期（2013—2017年）
Regulation of digital assets in Switzerland and Singapore was not designed on a blank sheet. Read more Singapore · Two Hubs第二阶段：划定监管边界（2018—2021年）
The ICO boom produced the first failures and the first rules. In Switzerland the emblematic case was Envion. Read more Singapore · Two Hubs第三阶段：崩盘与转向（2022—2024年）
The year 2022 is the hinge of the story. Read more Singapore · Two Hubs第四阶段：整合期（2025—2026年）
By 2025 both hubs had decided what they wanted to be. Read more Singapore · Two Hubs每一次失败带来了什么改变
The following table pairs the principal failures with the rule or practice each produced. Read more Singapore · Two Hubs全球层面
Neither hub makes its rules alone. Five international bodies and one regional regulation set the frame within which Switzerland and Singapore legislate. Read more Singapore · Technology律师须知的技术与分类
A lawyer who advises on digital assets does not need to write code. She does need to know, with precision, which technical fact produces which legal consequence. Read more Singapore · Technology作为共享记录的账本
A distributed ledger is a database that many independent computers hold in identical copies and update by agreement. Nothing in that description is new. Read more Singapore · Technology区块、哈希与不可篡改性
Transactions are grouped into blocks. Each block carries a cryptographic hash of the preceding block, which is a fixed-length fingerprint computed from the block's entire content. Read more Singapore · Technology公钥与私钥
Every account on a distributed ledger is controlled by a key pair. The private key is a very large random number. The public key is derived from it by a one-way mathematical function. Read more Singapore · Technology地址与假名性
An address is a string of letters and digits. It carries no name. Anyone can generate as many addresses as he wishes at no cost. Read more Singapore · TechnologyUTXO模型与账户模型
Bitcoin tracks value as unspent transaction outputs (UTXOs). Each output is a discrete lump of value locked to a condition, usually a public key. Read more Singapore · Technology共识机制
Consensus is the procedure by which the participants settle on the next block. Two families dominate. Read more Singapore · Technology最终性与结算
Finality is the point after which a transaction cannot be reversed by the protocol's own rules. Bitcoin offers probabilistic finality. Read more Singapore · Technology智能合约
A smart contract is a programme stored on the ledger that executes when a transaction calls it. The word "contract" was chosen by Nick Szabo in 1994 and has misled lawyers ever since. Read more Singapore · Technology分叉
A fork occurs when the network's participants cease to agree on a single history. A soft fork tightens the rules in a way older software still accepts. Read more Singapore · Technology第二层网络
A layer-2 network processes transactions off the main chain and periodically posts a compressed record to it. Read more Singapore · Technology跨链桥与封装资产
A bridge is a mechanism that lets a token on one chain be represented on another. Read more Singapore · Technology预言机
An oracle feeds external information to a smart contract. Price oracles tell a lending protocol what collateral is worth, so that it can liquidate under-collateralised positions. Read more Singapore · Technology综合运用：解读一笔交易
Before giving any opinion on a token, obtain and record the following from a block explorer or the client's technical team: - The network and, if applicable, the layer-2 on which the token lives. -… Read more Singapore · Technology为什么托管是核心问题
Most of the legal risk in digital assets concentrates at one point: who holds the private key, and on what terms. Regulation in both hubs is organised around that point. Read more Singapore · Technology自托管
Self-custody means the holder controls the private key without an intermediary. Read more Singapore · Technology托管持有：综合钱包
In an omnibus model the custodian holds all client tokens in one or a few addresses that it controls. Read more Singapore · Technology隔离钱包
In a segregated model each client has her own on-chain address controlled by the custodian. The chain itself shows the client's balance, although the custodian holds the key. Read more Singapore · Technology热钱包、冷钱包与密钥管理谱系
The hot/cold distinction concerns connectivity. A hot wallet's key is on a system connected to the internet and can sign at once. Read more Singapore · Technology多方计算与多重签名
Two technologies have replaced the single private key in institutional custody. Multi-signature (multisig) is a feature of the ledger itself. Read more Singapore · Technology质押托管
Staking means committing tokens to a proof-of-stake network to earn validation rewards. Four models exist. In solo staking the holder runs her own validator with her own keys and bears all risk. Read more Singapore · Technology借贷、再抵押与托管的终点
Custody ends where lending begins. A custodian that may use client tokens for its own account, lend them to third parties or pledge them, holds a debt to the client and not the client's asset. Read more Singapore · Technology“控制”在法律上的含义
The chapter has used "control" in several senses, and it is worth separating them before the taxonomies of Chapter III rely on the word. Read more Singapore · Technology破产中的私钥：唯一重要的事实
A Singapore exchange with a Swiss subsidiary fails in 2026. Read more Singapore · Technology为什么分类是第一步
Every regulatory question in this book begins with a classification. Is the token a security, a payment instrument, a claim on money, a right to use a service, or none of these? Read more Singapore · TechnologyFINMA的分类体系
FINMA published its ICO Guidelines on 16 February 2018 and has not withdrawn them. Read more Singapore · Technology新加坡的分类体系
Singapore classifies by statute, with MAS guidance filling the gaps. Four categories carry legal weight. Read more Singapore · TechnologyMiCA的分类体系
Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) has applied to stablecoins since 30 June 2024 and to other crypto-assets and service providers since 30 December 2024. Read more Singapore · Technology疑难情形
The three taxonomies agree on Bitcoin, on a tokenised share and on a dollar stablecoin. They were written for those cases. Read more Singapore · Technology实务中的分类：决策步骤
Apply the following steps, in order, to any token and record the answer to each: 1. Does the holder have a claim against any identifiable person? If yes, go to step 2. Read more Singapore · Technology赎回承诺：法律核心
A stablecoin is a token designed to hold a constant value against a reference, almost always a fiat currency and overwhelmingly the US dollar. Read more Singapore · Technology法币支持型稳定币
In the dominant model an issuer holds reserves of fiat currency and short-dated government securities and issues tokens against them one for one. Read more Singapore · Technology加密资产支持型稳定币
A crypto-backed stablecoin is issued by a protocol against over-collateralised deposits of other crypto assets. MakerDAO's DAI, now rebranded as USDS under the Sky protocol, is the leading example. Read more Singapore · Technology算法稳定币
An algorithmic stablecoin maintains its peg through a mechanism that expands and contracts supply in response to price, with little or no collateral. Read more Singapore · Technology代币化存款
A tokenised deposit is a bank deposit recorded on a distributed ledger instead of the bank's core banking system. Read more Singapore · Technology央行数字货币
A central bank digital currency (CBDC) is a liability of the central bank in token form. Two varieties exist. Read more Singapore · Technology目的绑定货币
Purpose-bound money (PBM) is a Singapore design concept, published by MAS in a white paper of June 2023, under which a digital money token is wrapped in a programmable layer that restricts how,… Read more Singapore · Technology瑞士法郎稳定币
The Swiss franc stablecoin market has remained small because of the regulatory constraints described above. Three designs have been tried. Read more Singapore · Technology新加坡元稳定币
Singapore's dollar stablecoin market is dominated by StraitsX's XSGD, issued since 2020 by a company holding an MPI licence for e-money issuance and DPT services, and by Paxos Digital Singapore's… Read more Singapore · Technology制裁、冻结与承诺的技术现实
Every major fiat-backed stablecoin contract contains functions that let the issuer freeze or destroy tokens at specified addresses. Read more Singapore · Technology代币化的两种含义
"Tokenisation" describes two quite different operations. Most confusion in the field comes from failing to separate them. In the first, the ledger is the register. Read more Singapore · Technology账本即登记册：账本型证券
Switzerland is the only jurisdiction covered by this book that allows the ledger to be the register for securities as a matter of general law. Read more Singapore · Technology账本即记录：数字孪生
In the second model the token is a digital twin of an asset held elsewhere. A gold token represents gold bars in a vault. A tokenised fund unit represents a unit recorded in the fund's register. Read more Singapore · Technology代币化证券
Tokenised bonds have been the most active segment in both hubs. Read more Singapore · Technology代币化房地产
Real estate cannot be tokenised directly in either hub. Title passes by registration in the land register, which neither country has connected to any distributed ledger. Read more Singapore · Technology代币化大宗商品与艺术品
A gold token is a claim against the issuer for delivery of gold, or a representation of a share in gold the issuer holds. Read more Singapore · Technology私人信贷与应收账款
Tokenised private credit, in which loans to businesses are originated, funded and serviced through tokens, grew rapidly in 2024 and 2025 through protocols such as Centrifuge, Maple and Goldfinch and… Read more Singapore · Technology账本即登记册与账本即记录：决策步骤
For any tokenised real-world asset, record the following before advising on it: - The asset and the register that establishes title to it under the law of its location. - Whether the token is the… Read more Singapore · Technology什么是DeFi，以及法律为何难以应对
Decentralised finance (DeFi) is the collective name for financial services delivered by smart contracts on public ledgers without an intermediary holding customer assets. Read more Singapore · Technology自动做市商
A decentralised exchange of the traditional kind would need an order book and a matching engine. Automated market makers (AMMs) dispense with both. Read more Singapore · Technology借贷协议
Aave and Compound, the leading lending protocols, hold pools of tokens deposited by lenders and allow borrowers to draw against collateral they deposit. Read more Singapore · Technology流动性质押
Chapter II introduced staking and Chapter III classified the receipt tokens. Read more Singapore · Technology再质押
Restaking, introduced by EigenLayer in 2023 and 2024, allows staked ETH or liquid staking tokens to be committed as security to additional services (oracles, bridges, data layers) that need economic… Read more Singapore · Technology永续合约与衍生品
Perpetual futures (perps) are the dominant derivative in crypto markets. Read more Singapore · Technology作为DeFi基础设施的跨链桥
Chapter I described bridges technically. In the DeFi context they are the point of greatest loss. Read more Singapore · Technology谁是对手方：协议背后的法律主体
The preceding sections have repeatedly asked who the counterparty is. The question can be approached systematically. Every DeFi protocol has some combination of the following persons connected to it. Read more Singapore · Technology联邦委员会2022年的立场
The Federal Council published its report on decentralised finance on 16 December 2022 in response to a parliamentary postulate. Read more Singapore · TechnologyMAS的立场
MAS has never published a DeFi report comparable to the Federal Council's, but its position can be assembled from speeches, consultation papers and the design of the DTSP regime. Read more Singapore · Technology执法现实
Neither regulator has brought an enforcement action against a DeFi protocol as such. Both have acted against identifiable operators. Read more Singapore · Technology什么是DAO
A decentralised autonomous organisation (DAO) is a group of persons who coordinate through smart contracts and govern a shared treasury or protocol by voting with tokens. Read more Singapore · Technology瑞士法下DAO的法律性质
Swiss law has no DAO statute. Read more Singapore · Technology新加坡法下DAO的法律性质
Singapore's common law reaches a similar default by a different route. Read more Singapore · Technology瑞士基金会
The analysis above explains why no serious protocol operates an unwrapped DAO. The core team's advisers will have told them that they are personally liable for everything the DAO does. Read more Singapore · Technology瑞士社团
The association (Verein) under Art. 60 ff. CC has become the second Swiss wrapper and in some respects a better one for DAOs. An association has members, who may be the token holders. Read more Singapore · Technology新加坡的担保有限公司
Singapore has neither a foundation nor an association with legal personality in the Swiss sense. Read more Singapore · Technology代币持有人的责任
Protocol teams also use the Cayman Islands foundation company, the Marshall Islands DAO LLC, the Wyoming DAO LLC and the Liechtenstein foundation. Each has advantages. Read more Singapore · Technology资金库控制
A DAO's treasury is the assets the community governs. It may be held in a smart contract that executes votes automatically, in a multisig controlled by a committee, or by a legal wrapper. Read more Singapore · Technology2026年各中心的现状
Switzerland has, through the foundation and the association, the most developed practice in the world for giving protocols a legal home. Read more Singapore · Technology本书所用技术术语表
The following entries define the technical terms used throughout the book in the sense in which the book uses them, in alphabetical order. Read more Singapore · Legal Order新加坡（一）：基础与新加坡金融管理局的监管思路
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城市国家中的威斯敏斯特模式
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法律渊源及其引用方式
Singapore law has four layers. At the top stands the Constitution. Below it sit the Acts of Parliament. Read more Singapore · Legal Order普通法、衡平法与英国法的继受
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法院
The Supreme Court of Judicature Act 1969 structures the superior courts. Read more Singapore · Legal Order判例与如何阅读新加坡判决
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法律解释
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 OrderMAS通知、指引、通函和常见问题解答的法律效力
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律师行业与外国律师
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从整体上把握这一体系
For a lawyer from Zug the Singapore legal order presents a paradox. Read more Singapore · Legal Order一个机构，三重角色
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历任局长与机构的声音
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作为总括性法律的《2022年金融服务与市场法》
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 OrderMAS的监管理念
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与数字资产相关的牌照类别
The licence a digital-asset business needs depends on the function its product performs. Six regimes cover the field. Read more Singapore · Legal Order执法权力
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监管实务
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从楚格看新加坡金融管理局
A client who has dealt with FINMA will find MAS both more and less demanding. Read more Singapore · Legal Order为何历史至关重要
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第一阶段（2014–2016年）：观察与警示
MAS made its first public statement on virtual currencies on 13 March 2014. Read more Singapore · Legal Order第二阶段（2017–2019年）：ICO浪潮与《指南》
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第三阶段（2020–2021年）：发牌与币安事件
The Payment Services Act 2019 came into force on 28 January 2020. Read more Singapore · Legal Order第四阶段（2022年）：连环倒闭与政策原则
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第五阶段（2023–2024年）：构建新制度
MAS published its responses in stages. Read more Singapore · Legal Order第六阶段（2024–2026年）：仅服务境外客户的提供商
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截至2026年6月30日的现状
At the cut-off date of this book Singapore's digital-asset regulation rested on five pillars. Read more Singapore · Legal Order给执业者的启示
Four lessons follow from the history. Read more Singapore · Legal Order市场格局
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持牌交易所、经纪商和托管机构
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银行
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市场基础设施：新加坡交易所、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守护者项目、全球第一层与兰花项目
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家族办公室浪潮
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风险投资、主权基金与人才
Temasek, GIC and the venture arms of the banks have invested across the digital-asset industry. Read more Singapore · Legal Order在新加坡选择交易对手
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新加坡生态系统与加密谷之比较
The two ecosystems differ in origin and in texture. Crypto Valley grew from below. Read more Singapore · Legal Order区域竞争
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香港
Hong Kong is the comparison that matters for three reasons. Read more Singapore · Legal Order迪拜与阿拉伯联合酋长国
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日本
Japan regulated crypto exchanges earlier than anyone. Read more Singapore · Legal Order东盟背景
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客户为何比较新加坡与香港，以及我如何作答
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监管机构之间的合作
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选择亚洲中心的决策顺序
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区域版图与瑞士读者
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为何需要一张机构图
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从内部看新加坡金融管理局
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会计与企业管制局
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新加坡国内税务局
IRAS was established on 1 September 1992 by the Inland Revenue Authority of Singapore Act 1992. Read more Singapore · Legal Order商业事务局与可疑交易报告办公室（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相关机构：总检察署
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新加坡法学院
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行业协会与私营层面
The Blockchain Association Singapore (BAS), formed in 2018, is the principal industry body for digital-asset firms. Read more Singapore · Legal Order客户会接触到的其他公共机构
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与各方接触的顺序
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本部分结语
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 · Private Law新加坡之二：私法与判例法
Singapore has no statute that tells a court what a crypto asset is. The Payment Services Act 2019 defines a digital payment token for licensing purposes. Read more Singapore · Private Law财产问题为何重要
Whether a crypto asset is property is the question on which every other private-law consequence depends. Read more Singapore · Private Law四项判决
The first Singapore cryptocurrency trial arose from a malfunction on the Quoine exchange on 19 April 2017. Read more Singapore · Private Law“权利物”对托管、信托和破产意味着什么
The practitioner should resist reading ByBit as a technical footnote, because the classification has consequences. A thing in action is the archetypal subject matter of an express trust. Read more Singapore · Private Law法律委员会的第三类财产与新加坡是否跟随
The Law Commission of England and Wales published its final report on digital assets on 28 June 2023 and a supplemental report with a draft Bill on 30 July 2024. Read more Singapore · Private Law新加坡判例一览表
The table shows the shape of the law: not one of the property holdings was reached after contested argument between represented parties on the specific point, and the Court of Appeal has still not… Read more Singapore · Private Law对特定资产的影响
Bitcoin, ether and fiat-referenced stablecoins are all property on the authorities above. Stablecoins raise the additional question whether the holder also has a contractual claim against the issuer. Read more Singapore · Private Law反对观点及其局限
Two lines of criticism of the Singapore position deserve mention. Read more Singapore · Private Law信托：新加坡应对托管风险的答案
Singapore has no statutory segregation rule for crypto assets in insolvency. Read more Singapore · Private Law明示信托与三项确定性
An express trust arises only where the settlor manifests an intention that the trustee hold property for the benefit of another. No particular words are needed. Read more Singapore · Private LawQuistclose信托
A Quistclose trust arises where money or other property is transferred for a specified purpose on terms that it is not at the free disposal of the recipient. Read more Singapore · Private Law作为受托人的托管人
Until 2024 whether a Singapore crypto custodian was a trustee depended entirely on its terms. Read more Singapore · Private Law《1967年受托人法》与受托人的义务
A trustee of a Singapore-law trust has the general power of investment conferred by s 4 of the Trustees Act 1967, which allows the trustee to make any investment that an absolute owner could make,… Read more Singapore · Private Law《2005年信托公司法》
Carrying on trust business in Singapore requires a licence under the Trust Companies Act 2005 unless an exemption applies. Read more Singapore · Private Law推定信托与归复信托
Trusts arising by operation of law are the subject of Chapter IV, where they appear as remedies for fraud and mistake. One point belongs here. Read more Singapore · Private Law跨境信托
Singapore is not a party to the Hague Trusts Convention of 1 July 1985. Read more Singapore · Private Law陷阱与反对观点
Three recurring errors deserve a warning. The first is the belief that calling an arrangement "custody" makes it a trust. It does not. The word describes a service. Read more Singapore · Private Law合同：客户真正的保护
Most of what a customer of a Singapore crypto platform can expect is written in the platform's terms of service. The property analysis of Chapter I tells the customer that tokens can be owned. Read more Singapore · Private Law服务条款：合同订立与条款纳入
A customer who ticks a box marked "I agree to the Terms" when opening an account has assented to those terms under ordinary principles of offer and acceptance. Read more Singapore · Private Law单方错误与算法交易
Singapore's law of unilateral mistake is set by Chwee Kin Keong v Digilandmall. Read more Singapore · Private Law智能合约与《2010年电子交易法》
A smart contract is a program on a blockchain that executes predetermined actions when specified conditions are met. Read more Singapore · Private Law免责条款与《1977年不公平合同条款法》
Platform terms contain extensive exclusions and limitations of liability. Singapore's Unfair Contract Terms Act 1977, a re-enactment of the English statute, controls them in three ways. Read more Singapore · Private Law消费者保护
The Consumer Protection (Fair Trading) Act 2003 gives consumers remedies against suppliers who engage in unfair practices, including misleading representations, taking advantage of a consumer's… Read more Singapore · Private Law平台特有条款及法院的解读
The last row deserves comment. Read more Singapore · Private Law合同法与平台：与瑞士的比较
Swiss contract law reaches many of the same results by different means. The Code of Obligations does not know a general reasonableness test for exclusion clauses. Read more Singapore · Private Law问题所在与新加坡的应对
A blockchain transfer cannot be reversed by the sender, by the recipient's bank or by a court. Read more Singapore · Private Law诉因
Where a fiduciary misappropriates assets entrusted to her, the assets are held on constructive trust for the principal from the moment of the misappropriation. Read more Singapore · Private Law临时救济
A proprietary injunction restrains the defendant from dealing with specific assets to which the claimant asserts title. Read more Singapore · Private Law追踪
Tracing is the process of identifying the asset into which the claimant's original asset has been converted. Following is the process of identifying the same asset as it moves from hand to hand. Read more Singapore · Private Law终局救济
At trial or on summary judgment the victim seeks four things: a declaration of constructive trust, an order for transfer of the assets still held, an account and a tracing order for assets that have… Read more Singapore · Private Law与刑事程序的相互作用
Victims of crypto fraud in Singapore almost always report to the police. Read more Singapore · Private Law错误转账与欺诈转账：与瑞士的比较
Switzerland's civil remedies are weaker and its criminal remedies stronger. A Swiss civil attachment (Arrest) under Art. 271 ff. DEBA requires assets located in Switzerland. Read more Singapore · Private Law2022年的倒闭潮与新加坡法院
The collapse of the Terra ecosystem in May 2022 and of Three Arrows Capital in June 2022 produced a chain of failures among lending platforms and exchanges with Singapore connections. Read more Singapore · Private Law《2018年破产、重组和解散法》
The Act, in force since 30 July 2020, consolidated Singapore's corporate and personal insolvency law and incorporated the restructuring reforms of 2017 that were designed to make Singapore a… Read more Singapore · Private Law破产与客户请求权：案例
Zipmex operated a retail exchange from Singapore with licensed subsidiaries in Thailand and Indonesia and a customer base of close to 70,000. Read more Singapore · Private Law受益人还是无担保债权人？
Whether a customer of a failed platform recovers in specie or receives a dividend depends on the characterisation of the relationship in the terms. The analysis has three stages. Read more Singapore · Private Law加密资产请求权的估值与转换
A creditor's claim in a Singapore liquidation is valued as at the commencement of the winding up and expressed in Singapore dollars for the purposes of proof and dividend. Read more Singapore · Private Law抵销、净额结算与撤销
Insolvency set-off applies in Singapore liquidations through the IRDA's incorporation of the bankruptcy rules on mutual credits and mutual dealings. Read more Singapore · Private Law跨境承认
Singapore's adoption of the Model Law allows foreign liquidators and administrators to obtain recognition and relief in Singapore. Read more Singapore · Private Law常见误区与反对观点
The recurring error of platform operators is to treat the moratorium as a solution. It is a stay. It buys time to propose a scheme. Read more Singapore · Private Law合同止步之处
Contract governs the relationship between a platform and its customer. Chapter III has shown how far the terms decide what the customer may expect. Tort matters where contract does not reach. Read more Singapore · Private Law新加坡注意义务的判断框架
Singapore applies a single test for the existence of a duty of care in negligence, set by the Court of Appeal in Spandeck Engineering v Defence Science and Technology Agency. Read more Singapore · Private Law托管人与交易所
A custodian owes its customer contractual duties under the custody agreement. Read more Singapore · Private Law开发者、验证者与协议
In Tulip Trading v van der Laan the English Court of Appeal held that it was seriously arguable that the developers who control the software of a bitcoin network owe fiduciary duties to the owners… Read more Singapore · Private Law专业人士：审计师、预言机与顾问
A smart-contract auditor who certifies code as free of critical vulnerabilities, and whose report is published to attract users, is in the position of any professional who makes a statement knowing… Read more Singapore · Private Law替代责任与员工欺诈
An employer is vicariously liable for the torts of an employee committed in the course of employment, including fraud, where the wrongful act is so closely connected with the employment that it is… Read more Singapore · Private Law侵权与过失：与瑞士的比较
An action in tort must be brought within six years of the accrual of the cause of action, which for negligence is the date of damage. Read more Singapore · Private Law控制权易手的两个时刻
Digital assets pass to other people at two predictable moments: divorce and death. Both expose the same structural feature of the asset class. Read more Singapore · Private Law离婚中的数字资产
On divorce the Family Justice Courts divide the matrimonial assets under s 112 of the Women's Charter 1961 in such proportions as the court thinks just and equitable. Read more Singapore · Private Law继承
A Singapore estate is administered under the Probate and Administration Act 1934. Where there is a will, the executor obtains a grant of probate. Read more Singapore · Private Law含有瑞士因素的跨境遗产
Singapore applies the common-law choice-of-law rules for succession. Succession to movables is governed by the law of the deceased's domicile at death. Read more Singapore · Private Law为何代币的问题更难回答
Every cross-border dispute raises three questions. Which court has jurisdiction? Which law applies? Will the resulting judgment be recognised where the assets or the defendant are? Read more Singapore · Private Law新加坡法院的管辖权
A defendant who is present in Singapore or submits to the jurisdiction can be sued there. Read more Singapore · Private Law法律选择
Singapore applies the common-law doctrine of the proper law of the contract. An express choice of law is given effect unless it is not bona fide or legal or is contrary to public policy. Read more Singapore · Private Law法院选择协议
The Choice of Court Agreements Act 2016 gives effect in Singapore to the Hague Convention on Choice of Court Agreements of 30 June 2005. Read more Singapore · Private Law判决的承认与执行
Singapore has two statutory regimes for foreign judgments. Read more Singapore · Private Law仲裁
Most token purchase agreements, custody agreements between institutions and software licences in the crypto sector contain arbitration clauses. Read more Singapore · Private Law公开账本与隐私法规之间的张力
A public blockchain records every transaction permanently and makes the record available to anyone. Read more Singapore · Private Law《2012年个人资料保护法》
The Act applies to every organisation that collects, uses or discloses personal data in Singapore. Public agencies and individuals acting in a personal capacity are excepted. Read more Singapore · Private Law作为个人资料的钱包地址与链上数据
The Commission published a guide on data protection considerations for blockchain design in July 2022. It takes three central positions. Read more Singapore · Private Law跨境传输
An organisation may transfer personal data outside Singapore only if it takes appropriate steps to ensure that the recipient is bound by legally enforceable obligations to provide a standard of… Read more Singapore · Private Law《2018年网络安全法》的叠加适用
The Cybersecurity Act 2018 established the Cyber Security Agency and a regime for critical information infrastructure, under which designated owners of systems essential to the delivery of essential… Read more Singapore · Private Law隐私与反洗钱义务
The sharpest conflict in practice is between the retention limitation and purpose limitation obligations on one side and the AML duties on the other. Read more Singapore · Private Law数据保护：与瑞士的比较
The Swiss and Singapore regimes are close in structure and differ in enforcement. Switzerland has no administrative fines against organisations. Read more Singapore · Regulation新加坡III：监管——PSA、SFA、FSMA/DTSP、稳定币、代币化
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该法的目的与架构
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数字支付代币的定义
Everything in the crypto limb of the Act depends on the statutory definition of a digital payment token (DPT). Read more Singapore · Regulation2021年修订后的数字支付代币服务
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标准支付机构与主要支付机构之比较
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豁免与“附带性”论点
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电子货币与数字支付代币的界限
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 · Regulation2020年1月以来的牌照发放历程
The Act commenced on 28 January 2020 with a grace period. Read more Singapore · Regulation牌照是什么，不是什么
A digital payment token licence is not a separate category of licence under the Payment Services Act 2019. Read more Singapore · Regulation申请材料的内容
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基本资本与财务要求
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客户代币的隔离与托管
The segregation regime is the single most important change to DPT regulation since the Act commenced. Read more Singapore · Regulation适当人选要求与新加坡居民管理层要求
MAS applies the Guidelines on Fit and Proper Criteria to every applicant, controller, director and chief executive. Read more Singapore · Regulation技术风险管理
The MAS Technology Risk Management Guidelines of January 2021 are guidelines, whereas the Notice on Technology Risk Management is binding. Read more Singapore · Regulation取得牌照后的持续义务
Licensing is the beginning of the compliance relationship, whose ongoing obligations are heavier than many applicants expect. Read more Singapore · Regulation时间表与结果
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与瑞士路径的比较
A Swiss reader will compare the DPT licence with the Swiss alternatives. Read more Singapore · Regulation2022年的政策转向
Until 2022 Singapore's approach to retail participation in crypto assets rested on disclosure. Read more Singapore · Regulation谁是零售客户
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风险认知评估
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禁止的诱因与信贷
Three prohibitions follow. First, a provider may not offer any incentive, monetary or otherwise, to prospective or existing retail customers. Read more Singapore · Regulation商业行为：利益冲突、上架与投诉
The conduct measures go beyond retail customers and apply to the provider's whole business. Read more Singapore · Regulation营销：PS-G02与“公共场所”规则
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措施的监管与执行
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 · Regulation2026年年中的悬而未决问题
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各项措施时间表
A timeline of the measures: a section of the book. Read more Singapore · Regulation消费者准入与商业行为措施：与瑞士的比较
Switzerland has no retail access regime for crypto assets. Read more Singapore · Regulation证券监管边界及其为何排在第二位
The Securities and Futures Act 2001 (SFA) is the older and larger statute. Read more Singapore · Regulation资本市场产品
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代币何时不属于资本市场产品
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招股说明书要求与豁免
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中介机构的牌照
The SFA regulates the intermediaries around a token as well as the offer. Read more Singapore · Regulation市场：获批准交易所与获认可市场运营者
A platform on which tokenised capital markets products are traded is operating an organised market. Read more Singapore · RegulationMAS的案例示例
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代币化资本市场产品与2025年指南
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与瑞士招股说明书法和登记权利证券法的比较
Switzerland and Singapore reach similar outcomes on the perimeter by different roads. Read more Singapore · Regulation一部设有加密专章的综合性法规
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谁是数字代币服务提供商
Part 9 applies to two kinds of person. Read more Singapore · Regulation“极其有限的情况”声明
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牌照条件与持续要求
For the few persons who are licensed, the regime is fully specified. Read more Singapore · Regulation哪些机构不得不撤离或重组
The population affected by Part 9 was larger than MAS's statements suggested. Three groups can be distinguished. Read more Singapore · Regulation与《支付服务法》和SFA的相互关系
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《金融服务与市场法》下的技术中立权力
Beyond Part 9, the FSMA gives MAS powers that affect every digital asset firm it regulates. Read more Singapore · Regulation处罚与执法
Carrying on a business of providing a digital token service without a Part 9 licence is an offence. Read more Singapore · Regulation评估
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新加坡为何另立框架
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各项要求
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牌照架构
MAS implemented the framework through the Payment Services Act by creating a new regulated payment service, the "stablecoin issuance service". Read more Singapore · Regulation立法实施及截至2026年6月30日的状况
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市场上的新加坡稳定币
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银行发行的代币化存款
The framework distinguishes an SCS from a tokenised bank deposit. Read more Singapore · Regulation与电子货币制度的相互作用
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稳定币：与瑞士的比较
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新加坡的战略押注
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 · RegulationProject 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 · RegulationGlobal Layer One与2024年11月的框架
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代币化证券的监管处理
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交易场所
Singapore has three principal regulated venues and infrastructures for tokenised securities, each with a different model. Read more Singapore · Regulation代币化存款与批发型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 · Regulation2025–2026年路线图
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代币化与市场基础设施：与瑞士的比较
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收益产品带来的问题
Every yield product in the token economy rests on the same structure. A customer hands tokens to a provider. Read more Singapore · Regulation零售禁令
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面向机构客户和认可投资者的质押
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借贷
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作为集体投资计划或结构性产品的收益产品
The third category of yield product packages tokens into an instrument. Read more Singapore · RegulationHodlnaut与Vauld的教训
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新加坡的质押、借贷与收益：与瑞士的比较
Switzerland reached a different equilibrium through its banking law. Read more Singapore · Regulation监管边界上的三个问题
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去中心化金融
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非同质化代币
MAS stated its position on NFTs in a Parliamentary reply in February 2022, at the height of the NFT market. Read more Singapore · RegulationDAO与新加坡的“基金会”
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新加坡的DeFi、NFT与DAO：与瑞士的比较
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申请流程概览
Chapters II, IV and V have described what each Singapore licence requires. Read more Singapore · Regulation第一阶段：准备与申请前沟通
The preparation stage decides the outcome. MAS does not run a pre-application meeting as of right. Read more Singapore · Regulation第二阶段：提交申请
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第三阶段：实质审查
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常见缺陷
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第四阶段：独立评估
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第五阶段：原则性批准
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第六阶段：发牌及获牌后的义务
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资本市场服务牌照与第9部分牌照
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瑞士集团如何取得新加坡牌照
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新加坡集团如何取得瑞士牌照
The reverse route is shorter at the first step and longer at the last. Read more Singapore · AML and Sanctions新加坡之四：反洗钱/反恐怖融资与合规
Anti-money-laundering law is the part of Singapore's digital-asset regime that decides whether a business survives contact with its own customers. Read more Singapore · AML and Sanctions三部法令与一个监管机构
Singapore's AML/CFT regime rests on three statutes, each of which does a different job. Read more Singapore · AML and SanctionsMAS通告：PSN01、PSN02与DTSP通告
The operational AML/CFT duties of a DPT business are set out in MAS notices issued under the PSA. Read more Singapore · AML and SanctionsFATF层面
Singapore has been a member of the Financial Action Task Force (FATF) since 1992 and held the FATF Presidency from July 2022 to June 2024 through T. Raja Kumar. Read more Singapore · AML and Sanctions国家风险评估与数字资产行业风险
Singapore published its first money-laundering national risk assessment in January 2014 and its first terrorism-financing assessment in 2020. Read more Singapore · AML and Sanctions从整体上理解这一制度
The compliance officer of a Singapore DPT firm works with five layers at once. The criminal statutes set the offences and the personal exposure. The MAS notice sets the duties. Read more Singapore · AML and SanctionsPSN02的结构
MAS Notice PSN02 is organised in the same sequence as every other MAS AML/CFT notice, from the Banking Act notice (MAS Notice 626) to the notices for capital markets intermediaries, trust companies… Read more Singapore · AML and Sanctions全企业风险评估
Before any customer is onboarded, PSN02 requires the firm to identify and assess the money-laundering and terrorism-financing risks it faces across customers, countries, products, services,… Read more Singapore · AML and Sanctions标准CDD：识别、核实与目的
The core of PSN02 is the duty to identify the customer, to verify that identity using reliable and independent sources and to identify and take reasonable measures to verify the beneficial owner. Read more Singapore · AML and Sanctions简化CDD
PSN02 allows simplified CDD where the firm has assessed the risk of a customer, product or transaction as low, provided the assessment is documented and consistent with the enterprise-wide risk… Read more Singapore · AML and Sanctions强化CDD
Enhanced CDD is mandatory for three categories and discretionary for a fourth. Read more Singapore · AML and Sanctions筛查
PSN02 requires the firm to screen customers, natural persons appointed to act, connected parties and beneficial owners against relevant lists at onboarding, on a periodic basis and when lists are… Read more Singapore · AML and Sanctions持续监控
CDD is not complete at onboarding. Read more Singapore · AML and Sanctions依赖第三方
PSN02 permits a firm to rely on a third party to perform the identification, verification and purpose elements of CDD. Three conditions apply. Read more Singapore · AML and Sanctions记录保存与个人数据
Records of CDD, account files, business correspondence and transaction data must be kept for at least five years after the end of the business relationship or the completion of the occasional… Read more Singapore · AML and Sanctions起源与目的
The travel rule is the requirement that information about the originator and the beneficiary of a transfer accompany the transfer itself, so that each institution in the chain and any investigator… Read more Singapore · AML and Sanctions新加坡规则：PSN02关于价值转移的规定
PSN02 applies the value-transfer requirements to every DPT transfer that a licensee makes or receives on behalf of a customer, whatever the amount. The information set depends on value. Read more Singapore · AML and Sanctions非托管钱包
The hardest case is the transfer to or from a wallet whose keys are held by a private person without any institution behind it. The FATF calls these "unhosted" or "self-hosted" wallets. Read more Singapore · AML and Sanctions对手方尽职调查
The travel rule only works if the firm knows which institution stands behind the beneficiary address. Read more Singapore · AML and Sanctions“日出”问题
The FATF borrowed the "sunrise" image to describe the period during which the travel rule has dawned in some jurisdictions and not in others. Read more Singapore · AML and Sanctions不完整及不合规的转账
A Singapore licensee that receives a DPT transfer lacking the required information has three lawful responses: execute and follow up, suspend pending information, or reject and return. Read more Singapore · AML and Sanctions旅行规则中的数据保护
Transmitting a customer's name, address and identification number to a foreign institution is a cross-border transfer of personal data. Read more Singapore · AML and Sanctions旅行规则的发展方向
Three developments were visible at the state-of-law date. Read more Singapore · AML and Sanctions法定报告义务
The duty to report sits in s. 45 of the CDSA and binds every person in Singapore, whether or not they are regulated. Read more Singapore · AML and SanctionsPSN02的叠加要求
For a DPT licensee the statutory duty is supplemented by PSN02. Read more Singapore · AML and Sanctions形成怀疑：数字支付代币的典型模式
What makes a DPT transaction suspicious? Read more Singapore · AML and Sanctions报告的时效与质量
The statute says "as soon as is reasonably practicable". Read more Singapore · AML and Sanctions提交报告之后
Filing an STR does not end the firm's obligations or its exposure. Four questions arise. Read more Singapore · AML and Sanctions律师的处境
Lawyers in Singapore are not exempt from s. 45. The duty applies to knowledge acquired in the course of a profession, of which the profession of law is no exception. Read more Singapore · AML and Sanctions集团内部的报告
Where a Singapore DPT licensee is part of a group, the firm must decide how much of an STR may be shared with affiliates. Read more Singapore · AML and Sanctions为何一宗案件独占一章
On 15 August 2023 some four hundred officers of the Singapore Police Force conducted simultaneous raids across the island and arrested ten foreign nationals on charges of money laundering, forgery… Read more Singapore · AML and Sanctions案件事实
The ten accused, nine men and one woman, were born in Fujian province in China and had acquired the citizenship of other countries, among them Cambodia, Cyprus, Vanuatu, Turkey, Dominica and Saint… Read more Singapore · AML and Sanctions问题出在哪里
The Inter-Ministerial Committee established in October 2023 to review the case published its report on 4 October 2024. Read more Singapore · AML and Sanctions政策应对
The response came in four waves between late 2023 and mid-2025. Read more Singapore · AML and Sanctions加密资产层面
The case was not a crypto case in the sense that the public assets were mostly real estate and bank balances. Its lessons for the digital-asset sector are nonetheless direct. Read more Singapore · AML and Sanctions数字支付代币持牌机构应从该案中汲取的教训
The committee's report and the 2025 penalties define the standard that MAS now applies to every supervised institution, including DPT licensees. Six points translate directly. Read more Singapore · AML and Sanctions比较视野下的该案
Switzerland has had its own formative cases, from the Abacha and Montesinos funds to 1MDB and Petrobras, and has reacted in each instance with a tightening of due-diligence rules, the most recent… Read more Singapore · AML and Sanctions新加坡的制裁立场
Singapore's sanctions policy differs from Switzerland's in a way that a dual-hub compliance programme must take into account from the first day. Read more Singapore · AML and Sanctions联合国制裁：法律机制
The United Nations Act 2001 empowers the Minister to make regulations to give effect to decisions of the United Nations Security Council under Article 41 of the Charter. Read more Singapore · AML and Sanctions2022年3月的对俄措施
On 5 March 2022 Singapore announced sanctions against Russia in response to the invasion of Ukraine, acting for the first time in decades without a Security Council mandate. Read more Singapore · AML and SanctionsOFAC与商业现实
No Singapore law requires a Singapore DPT licensee to comply with United States sanctions administered by the Office of Foreign Assets Control (OFAC). Read more Singapore · AML and Sanctions数字支付代币持牌机构的筛查实务
Sanctions screening at a DPT licensee has three components that a fiat institution's screening lacks or has in simpler form. Read more Singapore · AML and Sanctions扩散融资
The FATF added a proliferation-financing risk-assessment requirement to Recommendation 1 in October 2020. Read more Singapore · AML and Sanctions制裁与律师
A lawyer advising a DPT licensee on sanctions in Singapore must hold three jurisdictions in view at once. The Singapore layer determines what is unlawful and what must be frozen and reported. Read more Singapore · AML and SanctionsMAS所期望的治理架构
PSN02 closes with the requirements that make everything before it work: internal policies, procedures and controls approved by senior management, a compliance function with adequate resources and… Read more Singapore · AML and Sanctions合规官
PSN02 requires the appointment of an AML/CFT compliance officer at management level, with sufficient resources, independence and access to information to perform the role. Read more Singapore · AML and Sanctions技术风险与网络卫生
A DPT licensee's AML/CFT controls run on technology, and MAS regulates that technology through two notices and one set of guidelines that are in practice inseparable from the AML programme. Read more Singapore · AML and Sanctions外包与第三方风险
Most DPT licensees outsource core parts of their compliance stack: identity verification, sanctions screening, transaction monitoring, blockchain analytics and travel-rule messaging are all… Read more Singapore · AML and Sanctions独立审计
PSN02 requires an independent audit function to assess the adequacy and effectiveness of the AML/CFT programme regularly. Read more Singapore · AML and SanctionsMAS检查
MAS supervises DPT licensees through off-site monitoring of returns and STR copies, through thematic reviews across groups of licensees and through on-site inspections of individual firms. Read more Singapore · AML and Sanctions针对数字支付代币持牌机构的执法
MAS's enforcement toolkit under the PSA and the FSMA comprises supervisory directions, licence conditions, composition of offences and reprimands. Read more Singapore · AML and Sanctions员工培训、筛查与合规文化
PSN02 requires the firm to screen employees for integrity before hiring and to train them on AML/CFT at induction and regularly thereafter, with content tailored to their roles. Read more Singapore · AML and Sanctions问题的提出
The typical client of a Swiss–Singapore digital-asset practice is a group. Read more Singapore · AML and Sanctions集团计划的法律依据
Both regimes require or assume a group-wide approach, but with different reach. Read more Singapore · AML and Sanctions两种制度的分歧所在
The following table sets out the points at which a group cannot apply one rule to both entities without choosing. Read more Singapore · AML and Sanctions实体之间的依赖
The most common operational question is whether one entity may rely on the CDD performed by the other, so that a customer onboarded in Zug can open an account in Singapore without repeating the… Read more Singapore · AML and Sanctions由哪个实体服务哪类客户
Reliance solves the onboarding question but not the structural one: which entity should have the customer relationship at all? Three rules of thumb have emerged. Read more Singapore · AML and Sanctions信息共享及其限制
A group programme depends on the two entities knowing what each other knows about shared customers. Four legal constraints shape what may be shared. Read more Singapore · AML and Sanctions集团协议范本
The following elements constitute a group AML protocol that in my experience satisfies both regulators. Read more Singapore · AML and Sanctions拥有新加坡MPI的瑞士SRO成员：三个反复出现的问题
Three questions arise so often in this configuration that they deserve direct answers. Read more Singapore · Tax新加坡V：税收与激励措施
Tax is the reason many clients first look at Singapore and the reason some of them later leave. Read more Singapore · Tax课税范围及其属地逻辑
Singapore income tax is charged under section 10(1) of the Income Tax Act 1947 on income "accruing in or derived from Singapore or received in Singapore from outside Singapore". Read more Singapore · Tax支付型代币：易货、估值与处置
Because IRAS treats a payment token as property and not as money, a payment in tokens is a barter transaction. A business that sells goods for Bitcoin is taxed on the value of the goods supplied. Read more Singapore · Tax贸易标志在加密资产中的适用
The badges of trade are the test IRAS applies to decide whether disposals of tokens are revenue in nature. Read more Singapore · Tax代币发行：发行人所得的ICO款项
The treatment of proceeds from an initial coin offering follows the token type. The Guide's position on each type is one of the more useful statements of Singapore tax practice for a founder. Read more Singapore · Tax空投、硬分叉、质押、挖矿与NFT
The Guide treats each of the common ways of acquiring tokens without payment. Read more Singapore · Tax损失与扣除
Trading losses from token dealing are deductible against other income of the same year under section 37, carried forward indefinitely against future income subject to the shareholding test for… Read more Singapore · Tax新加坡与瑞士所得税处理的比较
The two hubs reach similar results for companies and different results for individuals. Read more Singapore · Tax不课税的原则及其三项限定
Singapore has no capital gains tax. The statement is accurate and is repeated in every pitch deck for a Singapore holding structure, yet it describes an absence in the statute and nothing more. Read more Singapore · Tax交易者与投资者界线的实务
For an individual the line is drawn by the badges of trade and the Comptroller's practice. Read more Singapore · Tax汇入原则：第10(1)条与第10(25)条
Singapore taxes income "received in Singapore from outside Singapore". Read more Singapore · Tax第10L条：2024年以来的境外来源处置收益
Section 10L was inserted by the Income Tax (Amendment) Act 2023 with effect from 1 January 2024 as Singapore's response to the European Union's Code of Conduct Group, which had listed Singapore's… Read more Singapore · Tax第10L条之外的实质要求
Economic substance has become the universal condition of Singapore tax planning, and digital-asset structures feel it from three directions at once. Read more Singapore · Tax与瑞士的对比
Switzerland exempts private capital gains for individuals (Art. 16 para. 3 DFTA) and taxes capital gains of companies as ordinary profit, subject to the participation relief for qualifying… Read more Singapore · Tax税制概况与2020年的转折点
Singapore's goods and services tax is a value added tax charged under the Goods and Services Tax Act 1993 on supplies of goods and services made in Singapore by a taxable person in the course of… Read more Singapore · Tax消费税法上数字支付代币的定义
The GST definition is narrower than the Payment Services Act definition and narrower than the income tax Guide's notion of a payment token. Read more Singapore · Tax稳定币：不属于DPT定义，但仍享受豁免
The exclusion of currency-pegged tokens from the DPT definition surprises many clients, because a stablecoin is the token most often used as a means of payment. Read more Singapore · Tax兑换服务、中介机构与代理问题
The exemption covers the supply of the token itself. It does not cover the services of the exchange, broker or custodian who makes the transaction possible. Those services remain taxable. Read more Singapore · Tax进项税抵扣与部分豁免
A business that makes both taxable and exempt supplies may recover only the input tax attributable to taxable supplies. Read more Singapore · Tax挖矿、验证与质押服务
Mining is generally not a supply for GST purposes. Read more Singapore · Tax反向征收与瑞士供应商
Since 1 January 2020 Singapore has applied a reverse charge to imported services acquired by businesses that are not entitled to full input tax recovery. Read more Singapore · TaxGST下的NFT与实用型代币
An NFT is not fungible and therefore cannot be a DPT. Its GST treatment depends on what it is. Read more Singapore · TaxGST合规的组织安排
The GST return of a digital-asset business is only as good as the data that feeds it. Read more Singapore · Tax基金税收优惠为何对数字资产至关重要
Singapore's fund industry rests on three statutory exemptions. Read more Singapore · Tax三项计划
Section 13D exempts a non-resident fund that has no presence in Singapore other than its Singapore fund manager. Read more Singapore · Tax指定投资与代币问题
The exemption covers only specified income from designated investments. The designated investments list is set out in the regulations and expanded by successive circulars. Read more Singapore · Tax可变资本公司
The Variable Capital Companies Act 2018 came into force on 14 January 2020 and gave Singapore a fund vehicle built for the purpose. Read more Singapore · Tax基金经理的牌照与税务
A fund manager in Singapore must hold a capital markets services licence for fund management under the Securities and Futures Act 2001 or qualify for an exemption. Read more Singapore · Tax管理新加坡基金的瑞士经理
A Swiss portfolio manager or manager of collective assets licensed under the Financial Institutions Act (FinIA; FINIG) who wishes to manage a Singapore fund has three routes. Read more Singapore · Tax管理瑞士L-QIF的新加坡经理
The reverse case has become possible since 1 March 2024, when the limited qualified investor fund (L-QIF) was introduced into the Collective Investment Schemes Act (CISA; KAG). Read more Singapore · Tax在新加坡基金与瑞士基金之间作选择
The decision depends on investors, strategy and the token problem described above. The following table summarises the points that decide most mandates. Read more Singapore · Tax新加坡家族办公室模式
A single family office in Singapore is a company that manages the assets of one family and nothing else. The structure that MAS and IRAS have in mind has two layers. Read more Singapore · Tax牌照豁免与2023年类别豁免提案
A family office that manages only the assets of a single family does not need a capital markets services licence. Read more Singapore · Tax单一家族办公室的税收优惠条件
Single family office funds obtain their exemption under section 13O or 13U, but the conditions are stricter than for commercial funds and have been tightened twice. Read more Singapore · Tax家族办公室资产配置中的加密资产
The designated investments problem of Chapter IV strikes a crypto family office harder than a commercial fund, because the family's wealth often consists largely of the tokens that made it. Read more Singapore · Tax2023年8月案件与实务收紧
In August 2023 the Singapore Police Force arrested ten foreign nationals and seized or froze assets eventually valued at more than S$ 3 billion in what became the largest money-laundering case in… Read more Singapore · Tax全球投资者计划
The Global Investor Programme, administered by the Economic Development Board, grants permanent residence to investors who commit capital to Singapore. Read more Singapore · Tax与楚格州定额课税的比较
The Singapore family office is often weighed against the Swiss lump-sum regime described in Part G, Chapter VI, although the two instruments are built on different logics. Read more Singapore · Tax以代币作为报酬
Most digital-asset businesses pay part of their people in tokens. Read more Singapore · Tax第10(6)条及适用于代币的股份计划规则
Singapore has a specific regime for employee share plans. Section 10(6) taxes gains from rights to acquire shares, meaning options and share awards, at the time of exercise or vesting. Read more Singapore · Tax视同行权规则与QEEBR递延
Two features of the share plan regime are relevant to a mobile crypto workforce. Read more Singapore · Tax个人的税务居民身份
An individual is resident in Singapore for a year of assessment if he resides in Singapore in the preceding calendar year, except for temporary absences, or if he is physically present or exercises… Read more Singapore · Tax准证制度
Nobody lives and works in Singapore without a pass. The pass system is in practice a filter that decides which founders and employees Singapore wants. Read more Singapore · Tax从瑞士迁往新加坡
A founder who moves from Zug to Singapore faces a sequence of questions on each side. Read more Singapore · Tax从新加坡迁往瑞士
The reverse move is less common but increasingly seen as families return to Europe. Singapore has no exit tax other than the deemed exercise rule, so the founder leaves with his tokens untaxed. Read more Singapore · Tax从保密到自动交换
Singapore and Switzerland were the two financial centres whose bank secrecy the OECD's transparency project was designed to end. Read more Singapore · Tax共同申报准则在新加坡的实施
Singapore implemented the CRS through the Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) Regulations 2016, with due diligence from 1 January 2017 and first… Read more Singapore · Tax加密资产申报框架
CARF requires a Reporting Crypto-Asset Service Provider (RCASP) to identify its users and determine their tax residence. Read more Singapore · TaxCARF对在两个中心均持有资产的客户意味着什么
The arrival of CARF changes the risk profile of three types of client. The first is the Singapore resident with tokens on a Swiss exchange or with a Swiss bank's digital-asset custody. Read more Singapore · Tax新加坡RCASP的义务
A Singapore RCASP must determine whether it is within scope, which for a licensed DPT service provider or DTSP licensee is almost always yes. Read more Singapore · TaxFATCA
Both hubs apply the United States Foreign Account Tax Compliance Act through intergovernmental agreements. Read more Singapore · Tax合规周期与IRAS的信息调取权
Singapore taxes on a preceding-year basis. Income of the calendar year 2025 is assessed in the year of assessment 2026. Individuals file by 18 April. Read more Singapore · Tax罪行与处罚
The Income Tax Act grades its offences by culpability. Section 94 is the general penalty for failing to file or to comply, with a fine up to S$ 5,000 and a penalty of double the tax. Read more Singapore · Tax自愿披露计划
IRAS operates a voluntary disclosure programme that reduces penalties for taxpayers who come forward before IRAS has begun an audit or investigation. Read more Singapore · Tax异议、复核与上诉
A taxpayer who disagrees with an assessment lodges a notice of objection within two months stating the grounds. Read more Singapore · Tax预先裁定
IRAS issues advance rulings on the application of the Income Tax Act to a proposed arrangement under section 108 and the Seventh Schedule. Read more Singapore · Tax逃税作为洗钱的上游犯罪
Since 1 July 2013 serious tax offences have been predicate offences for money laundering under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992. Read more Singapore · Tax与瑞士披露制度的比较
Switzerland offers a penalty-free voluntary disclosure once in a lifetime under Art. 175 para. 3 of the Direct Federal Tax Act, provided the authority has no knowledge of the evasion, the taxpayer… Read more Singapore · Tax协定及其沿革
The Agreement between the Republic of Singapore and the Swiss Confederation for the Avoidance of Double Taxation with respect to Taxes on Income was signed in Singapore on 24 February 2011. Read more Singapore · Tax居民身份与加比规则
A person is resident of a contracting state if he is liable to tax there by reason of domicile, residence, place of management or any similar criterion. Read more Singapore · Tax常设机构
Article 5 defines a permanent establishment as a fixed place of business through which the business of an enterprise is wholly or partly carried on. Read more Singapore · Tax股息、利息与特许权使用费
The treaty reduces Swiss withholding tax on dividends from 35 per cent to 5 per cent where the beneficial owner is a company holding at least 10 per cent of the paying company's capital, and to 15… Read more Singapore · Tax资本利得
Article 13 allocates gains from the alienation of immovable property to the state where the property is situated. Read more Singapore · Tax跨两个中心的受雇所得
Article 15 allocates employment income to the state where the employment is exercised. Read more Singapore · Tax相互协商与信息交换
The mutual agreement procedure is open to a taxpayer who considers that the actions of one or both states result in taxation not in accordance with the agreement. Read more Singapore · Tax写给必须作出决定的读者：结语比较
This Part has shown a tax system that is generous to the investor, demanding of the trader, indifferent to the token as such and increasingly insistent on substance. Read more Singapore · Enforcement新加坡之六：执法、破产与争议解决
The five preceding Singapore parts describe how digital assets are owned, licensed, taxed and kept clean. This part describes what happens when something goes wrong. Read more Singapore · Enforcement法律架构
Singapore has no digital-asset criminal statute. Offences involving tokens are prosecuted under general legislation drafted for other purposes and read, with some strain, onto a new asset class. Read more Singapore · Enforcement欺骗罪
Cheating under s 415 requires deception of a person and inducement by that deception, followed either by a dishonest or fraudulent delivery of property or by a damaging act or omission of the person… Read more Singapore · Enforcement刑事背信与侵占
Criminal breach of trust under s 405 requires that a person was entrusted with property or with dominion over it. Read more Singapore · Enforcement第424A条规定的欺诈罪
The Criminal Law Reform Act 2019 introduced s 424A, modelled on the English Fraud Act 2006, in force from 1 January 2020. Read more Singapore · Enforcement滥用电脑
The Computer Misuse Act 1993 criminalises unauthorised access to computer material (s 3), access with intent to commit an offence (s 4) and unauthorised modification (s 5). Read more Singapore · EnforcementCDSA下的洗钱罪
Part 6 of the CDSA contains the laundering offences. Read more Singapore · Enforcement无牌经营
Section 5 of the Payment Services Act 2019 prohibits carrying on a business of providing any type of payment service in Singapore without a licence or exemption. Read more Singapore · Enforcement市场不当行为
Part 12 of the Securities and Futures Act prohibits false trading and market rigging (s 197), market manipulation (s 198) and false or misleading statements (s 199). Read more Singapore · Enforcement公司及高管责任
Singapore statutes use a consistent technique for attributing offences to companies and their officers. Read more Singapore · Enforcement塑造新加坡实务的四宗案件
Terraform Labs Pte Ltd was a Singapore company. Read more Singapore · Enforcement比较总结
The table shows a system that punishes dishonesty more heavily than Switzerland and that reaches negligent participation in laundering, which Swiss law leaves to administrative sanction. Read more Singapore · Enforcement执法版图
A Swiss lawyer accustomed to cantonal prosecutors, a federal Office of the Attorney General with a defined catalogue of competences and a separate FINMA enforcement division will find Singapore's… Read more Singapore · Enforcement商业事务局
CAD is the principal white-collar crime investigation agency. Read more Singapore · Enforcement可疑交易报告办公室
STRO receives the suspicious transaction reports that the CDSA requires of every person in the course of business, together with cash movement reports and cash transaction reports. Read more Singapore · EnforcementMAS执法
CPIB reports directly to the Prime Minister's Office and investigates offences under the Prevention of Corruption Act 1960. Its relevance to digital assets is narrow but real. Read more Singapore · Enforcement反诈骗指挥部与零售欺诈
The great majority of crypto-related police reports in Singapore are retail scams. Read more Singapore · Enforcement调查机构：总检察署
AGC's Crime Division prosecutes, its Financial and Technology Crime Division handles complex commercial cases and its International Affairs Division is the central authority for mutual legal… Read more Singapore · Enforcement刑事司法协助
The Mutual Assistance in Criminal Matters Act 2000 (MACMA) governs Singapore's incoming and outgoing requests. Read more Singapore · Enforcement加密案件调查的实际运作
A typical CAD investigation into a collapsed platform begins with a report, often from a creditor, followed by a request for documents to the company and its officers. Read more Singapore · Enforcement调查机关：比较观察
Three differences between the Swiss and Singapore investigative systems have practical consequences for structuring. Read more Singapore · Enforcement新加坡为何成为资产追回中心
A victim of token theft or fraud rarely knows at the outset who took the assets or where they are. Read more Singapore · Enforcement财产属性的基础
Every proprietary remedy depends on the asset being property. The Singapore position developed in three steps. Read more Singapore · Enforcement临时救济工具箱
A proprietary injunction restrains the defendant from dealing with specific assets over which the claimant asserts a proprietary claim. Read more Singapore · Enforcement终局救济与推定信托
The ByBit decision shows the full arc. An employee of a payroll contractor caused about 4.2 million USDT and some fiat to be paid to wallets and accounts she controlled. Read more Singapore · Enforcement起诉前阶段与交易所
Singapore-licensed exchanges are bound by the Payment Services Act, by MAS Notice PSN02 on anti-money laundering and by their own terms of service. Read more Singapore · Enforcement针对代币执行判决
A judgment for a sum of money is enforced under O 22 of the Rules of Court 2021 by an enforcement order for seizure and sale of property, for attachment of debts or for delivery of movable property. Read more Singapore · Enforcement与瑞士扣押程序的配合
A cross-border recovery between the hubs typically needs both legal systems. The Singapore court supplies the disclosure and the proprietary freeze at the exchanges. Read more Singapore · Enforcement费用、融资与现实考量
Interim relief in Singapore is expensive. Read more Singapore · Enforcement塑造法律的十八个月
Between July 2022 and the end of 2023 the General Division of the High Court, in almost every case through Aedit Abdullah J, dealt with five digital-asset insolvencies. Read more Singapore · EnforcementIRDA工具箱
A company that proposes or intends to propose a compromise or arrangement with its creditors may apply under s 64 IRDA for orders restraining winding-up resolutions, the appointment of receivers,… Read more Singapore · Enforcement破产与重组：案例
Vauld, a crypto lending platform serving mainly Indian and South-East Asian retail customers, suspended withdrawals on 4 July 2022 and, through its Singapore operating entity Defi Payments Pte Ltd,… Read more Singapore · Enforcement客户的请求：是否构成信托
In every platform insolvency the customer's recovery depends on one question. Read more Singapore · Enforcement平台的债务偿还安排计划
A scheme of arrangement under s 210 of the Companies Act 1967, as modified by Part 5 IRDA, binds all creditors in a class if a majority in number representing three-quarters in value of those voting… Read more Singapore · Enforcement跨境维度
A Swiss creditor of a Singapore platform may prove in the Singapore liquidation or scheme without any Swiss proceeding. Read more Singapore · Enforcement临近破产时的董事义务
Singapore directors who continue to trade while the company is insolvent face liability for wrongful trading under s 239 IRDA, which applies where the company incurs debts without reasonable… Read more Singapore · Enforcement法院的选择
A digital-asset dispute with a Singapore connection can be heard in three places within the Singapore court system. Read more Singapore · Enforcement高等法院普通庭
The General Division has jurisdiction over a defendant who is served in Singapore or who submits. Read more Singapore · Enforcement新加坡国际商业法庭
The SICC was established in 2015 as a division of the General Division to hear international commercial disputes. Read more Singapore · Enforcement诉因与救济
Most platform disputes are contract claims: failure to return deposited tokens, wrongful liquidation of a margin position, refusal to honour a withdrawal, breach of a token purchase agreement or SAFT. Read more Singapore · Enforcement程序实务
A contested commercial claim in the General Division runs from filing to judgment in about twelve to eighteen months, with the single application pending trial heard within the first six months and… Read more Singapore · Enforcement针对瑞士被告的执行
A Singapore judgment against a Swiss-domiciled defendant is recognised in Switzerland under Arts 25–27 PILA if the Singapore court had jurisdiction under Swiss indirect-jurisdiction rules, the… Read more Singapore · Enforcement起诉平台、协议与DAO
A claim against a licensed Singapore exchange is a claim against a Pte Ltd with a registered office, an MAS licence and auditors. It is served at the registered office and defended by counsel. Read more Singapore · Enforcement民事诉讼：比较观察
Singapore civil procedure gives a digital-asset claimant three things that Swiss procedure does not: interim relief against third parties on short notice, compelled disclosure from parties and… Read more Singapore · Enforcement仲裁为何主导代币文件
Most token purchase agreements, SAFTs, market-making agreements, custody agreements for institutional clients and the terms of service of the larger exchanges provide for arbitration. Read more Singapore · Enforcement法律框架
The International Arbitration Act 1994 (IAA) gives effect to the UNCITRAL Model Law on International Commercial Arbitration for international arbitrations seated in Singapore and to the New York… Read more Singapore · EnforcementSIAC与《2025年仲裁规则》
SIAC was established in 1991 and has grown into one of the five most-used institutions in the world, with more than 600 new cases a year in recent years, a majority of them with no Singapore party. Read more Singapore · Enforcement对瑞士当事人的执行
Switzerland and Singapore are both parties to the New York Convention without the reciprocity or commercial reservations. Read more Singapore · Enforcement调解
The Singapore International Mediation Centre (SIMC) was established in 2014 and offers mediation under its own rules, often in combination with SIAC arbitration through the Arb-Med-Arb protocol. Read more Singapore · Enforcement两大中心之间的争议解决条款
A party drafting a dispute clause for a Swiss–Singapore digital-asset contract has four realistic options: the Zürich Handelsgericht, the SICC, SIAC arbitration seated in Singapore and Swiss Rules… Read more Singapore · Enforcement在线与链上争议解决
Decentralised dispute-resolution protocols such as Kleros and Aragon Court resolve disputes by juries of token holders who stake tokens and vote, with the smart contract executing the outcome. Read more Singapore · Enforcement作为执法者的MAS
MAS enforces the statutes it administers with a graduated set of tools: supervisory warnings and reprimands, directions and conditions, composition of offences, civil penalties, prohibition orders… Read more Singapore · Enforcement制裁措施
Most MAS statutes allow MAS to compound an offence by accepting a sum not exceeding half the maximum fine, or a prescribed amount, in return for not prosecuting. Read more Singapore · Enforcement持牌机构群体及其执法记录
MAS publishes the Financial Institutions Directory, a searchable register of all licensed and exempt financial institutions. Read more Singapore · Enforcement《金融服务与市场法》的监管边界
The Financial Services and Markets Act 2022 added to MAS's enforcement powers in three ways that matter for digital assets. It created the harmonised prohibition-order regime described above. Read more Singapore · Enforcement正当程序与司法审查
MAS enforcement is administrative, so the safeguards are those of administrative law. Read more Singapore · Enforcement2023至2026年执法报告及其揭示的情况
The MAS Enforcement Report covering July 2022 to December 2023 recorded the Three Arrows actions, the composition of several licensees for anti-money-laundering failures and the prohibition orders… Read more Singapore · Enforcement与瑞士监管的互动
A Swiss–Singapore group will be supervised on both sides by supervisors who talk to each other. Read more Singapore · Enforcement结语：比较评述
The enforcement systems of the two hubs reflect the character of each legal order. Read more Singapore · Comparative比较分析与更广阔的背景
The preceding twelve parts describe Switzerland and Singapore one at a time. This part puts the two systems side by side. Read more Singapore · Comparative方法与比较的局限
Comparative law between a civil-law federation and a common-law city state carries a known risk: the comparison flattens differences of method into differences of outcome. Read more Singapore · Comparative维度一：资产的法律性质
Swiss law reached its answer by legislative and doctrinal route. A crypto asset is not a thing (Sache) within Art. 641 ff. of the Civil Code (CC; ZGB), because it lacks physical substance. Read more Singapore · Comparative维度二：牌照监管边界与门槛
Switzerland regulates by activity and by statute, with FINMA's token classification as the entry point. Read more Singapore · Comparative维度三：托管与破产保护
The third axis decides whether a customer gets its tokens back when its custodian fails. It is the axis on which the two hubs have converged most visibly since 2022. Switzerland's answer is statutory. Read more Singapore · Comparative维度四：反洗钱义务与旅行规则
Both hubs implement the FATF standards for virtual asset service providers in full, having done so earlier than most. The differences lie in architecture and in thresholds. Read more Singapore · Comparative维度五：个人、公司与基金的税收
Taxation is the axis on which the two hubs differ most in method and least in result for the typical holder. Read more Singapore · Comparative维度六：执法工具
Enforcement divides into the state's tools against wrongdoers and the victim's tools to recover assets. On the state side both hubs have a full criminal and regulatory arsenal. Read more Singapore · Comparative维度七：传承规划
Succession is the axis clients neglect and the one where the two systems diverge most in substance. Swiss succession law is codified in Art. 457 ff. Read more Singapore · Comparative综合解读七个维度
No reader will choose a hub on one axis. The axes interact, with the interactions often mattering more than the cells. Three patterns recur in practice. Read more Singapore · Comparative为什么瑞士或新加坡公司必须研读MiCA
Neither Switzerland nor Singapore is in the European Union, yet almost every digital-asset business established in Zug or Singapore has customers, counterparties or token holders in the Union. Read more Singapore · Comparative适用范围与架构
MiCA regulates "crypto-assets", defined as digital representations of value or rights able to be transferred and stored electronically using distributed ledger or similar technology. Read more Singapore · Comparative向公众发售与白皮书
Title II applies to any offeror of a crypto-asset other than an ART or EMT in the Union and to any person seeking admission to trading. Read more Singapore · Comparative加密资产服务提供商
Title V lists ten crypto-asset services: custody and administration on behalf of clients, operation of a trading platform, exchange of crypto-assets for funds, exchange for other crypto-assets,… Read more Singapore · Comparative反向招揽
The only route by which a non-Union firm may serve a Union client without authorisation is Art. 61, the reverse-solicitation exemption. Read more Singapore · ComparativeMiCA下的稳定币
Titles III and IV have applied since 30 June 2024 and are the part of MiCA with the sharpest practical edge. An e-money token references one official currency. Read more Singapore · Comparative过渡期及其于2026年7月1日结束
Art. 143 governs the transition. Offers that ended before 30 December 2024 need no white paper. Read more Singapore · Comparative欧盟子公司问题
Once reverse solicitation is excluded, the Swiss or Singapore group has three options for the Union market. It can abandon the market and geo-block. Read more Singapore · Comparative列支敦士登作为通往欧洲经济区的桥梁
Liechtenstein offers a Swiss group a route into the Union market that no other jurisdiction can. It is in the European Economic Area and in a customs and currency union with Switzerland. Read more Singapore · ComparativeDAC8与税务申报层面
MiCA regulates conduct. Council Directive (EU) 2023/2226 of 17 October 2023, the eighth amendment to the Directive on administrative cooperation and known as DAC8, regulates information. Read more Singapore · ComparativeMiCA、瑞士与新加坡之比较
The three regimes answer the same questions with different instruments. The table sets out the main points at 30 June 2026. Read more Singapore · Comparative为何一部瑞士—新加坡专著要论及香港
Hong Kong is the jurisdiction that clients raise most often when they discuss Singapore and the one that Swiss private banks raise most often when they discuss Asia. Read more Singapore · Comparative监管架构
Hong Kong has no single integrated financial regulator. Read more Singapore · Comparative2023年6月以来的VATP发牌制度
Before 2023 the SFC could regulate only platforms that traded at least one security token, through an opt-in regime announced in November 2019 under which OSL and HashKey obtained Type 1 and Type 7… Read more Singapore · Comparative证监会的更广泛计划
Since 2024 the SFC has extended the regime in three directions. Read more Singapore · Comparative《稳定币条例》
The Stablecoins Ordinance (Cap. 656) was passed by the Legislative Council on 21 May 2025 and came into operation on 1 August 2025. Read more Singapore · Comparative香港的反洗钱与旅行规则
Hong Kong's AML regime for virtual assets sits in the same ordinance as the licensing regime. Read more Singapore · Comparative大事年表
The following table places the Hong Kong milestones against the Singapore and Swiss dates discussed in Parts A, C and I. Read more Singapore · Comparative私法与法院
Hong Kong's courts reached the property question at the same time as Singapore's. Read more Singapore · Comparative香港：税务
Hong Kong has no capital gains tax, no wealth tax, no dividend tax and, since 2006, no estate duty. Read more Singapore · Comparative香港与新加坡之比较
The following table sets the two Asian hubs side by side as at 30 June 2026, with Switzerland in a third column where the comparison helps. Read more Singapore · Comparative香港如何融入瑞士—新加坡战略
The honest comparison between Hong Kong and Singapore turns on four factors that no table captures. The first is China. Read more Singapore · Comparative三个未被选中却塑造市场的司法管辖区
The United States, the United Kingdom and the United Arab Emirates appear in almost every Swiss or Singapore mandate without being candidates for the client's headquarters. Read more Singapore · Comparative美国
Until January 2025 the United States regulated digital assets through enforcement. Read more Singapore · Comparative英国
The United Kingdom regulated crypto assets through anti-money-laundering registration for five years before it regulated them as financial services. Read more Singapore · Comparative阿拉伯联合酋长国
The Emirates present a complexity that clients underestimate. There are four regulators and three legal regimes. Read more Singapore · Comparative四个制度一览
When a client asks about one of these three jurisdictions, resist the urge to compare regimes and ask what the client wants from it. Read more Singapore · Comparative成为硬法的软法
None of the five bodies discussed in this chapter can bind Switzerland or Singapore. Read more Singapore · ComparativeFATF第15项建议与旅行规则
The FATF amended Recommendation 15 in October 2018 to require countries to regulate virtual asset service providers (VASPs) for anti-money-laundering and counter-terrorist-financing purposes, and… Read more Singapore · Comparative金融稳定理事会2023年框架
The FSB published its Global Regulatory Framework for Crypto-asset Activities on 17 July 2023, in two parts. Read more Singapore · Comparative巴塞尔委员会对加密资产风险敞口的审慎处理
The BCBS published its standard on the prudential treatment of cryptoasset exposures on 16 December 2022 as a new chapter SCO60 of the consolidated Basel Framework, for implementation by 1 January… Read more Singapore · ComparativeIOSCO的建议
IOSCO's Board published its Policy Recommendations for Crypto and Digital Asset Markets as a final report on 16 November 2023. The eighteen recommendations address six areas. Read more Singapore · Comparative经合组织《加密资产报告框架》
The OECD approved the Crypto-Asset Reporting Framework (CARF) in August 2022 and published it with amendments to the Common Reporting Standard in October 2022, after a G20 mandate. Read more Singapore · Comparative各项标准如何落地：实施对照图
Two observations close the chapter. First, Singapore's implementations are statutory and dated, Switzerland's are often administrative and derived from existing law. Read more Singapore · Comparative同一个词的两种含义
Regulators use "regulatory arbitrage" as an accusation. Founders use it as a strategy. Both are describing the act of choosing where to be regulated. Read more Singapore · Comparative两地监管机构都处罚什么
The first target is the entity with a Swiss or Singapore address and nothing else. Swiss financial-market law requires effective management in Switzerland for every licensed institution. Read more Singapore · Comparative实质：法律实际要求什么
Substance is the condition of legitimate arbitrage. It has three layers that a client should distinguish: regulatory, tax and corporate. Read more Singapore · Comparative域外效力
Singapore's rules reach in two directions. Read more Singapore · Comparative十种商业模式的决策矩阵
The matrix below applies the comparison of this part to the ten business models that recur in practice. Read more Singapore · Comparative两个中心的边界
The comparison that this part has drawn permits one general conclusion. Switzerland and Singapore are complementary, which is the reason this book treats them together. Read more Singapore · Structuring在两个中心之间进行架构设计
The preceding parts describe the two legal orders separately and then compare them axis by axis. This Part changes the perspective. Read more Singapore · Structuring为什么自然人要放在首位
Founders tend to begin with the entity. Read more Singapore · Structuring在瑞士居住：两种税制
A founder who takes up residence in the canton of Zug and is taxed in the ordinary way pays federal, cantonal and communal income tax on worldwide income and cantonal and communal wealth tax on… Read more Singapore · Structuring在新加坡居住：属地税制
Singapore taxes individuals on income accruing in or derived from Singapore and on foreign income received in Singapore, with the latter exempt for resident individuals under s. 13(7A) of the Income… Read more Singapore · Structuring数字对比
The following example sets the three regimes against one another on simplified facts. Read more Singapore · Structuring居留许可与居留权
Tax residence is useless without a right of residence. Read more Singapore · Structuring家庭、教育与生活质感
Tax and permits decide whether a move is possible. Family decides whether it lasts. Read more Singapore · Structuring离开原居住国
The tax a founder saves by moving can be lost to the state they leave. Four home jurisdictions dominate my practice. Read more Singapore · Structuring围绕迁居安排代币事件的时间
The sequence that produces the best result is set out below. It assumes a founder who holds an unvested allocation and moves from a high-tax state to Zug or Singapore. Read more Singapore · Structuring两个中心的反避税规则
Neither hub tolerates a residence that exists only on paper. Read more Singapore · Structuring五种备选载体
Swiss law offers a digital-asset venture five vehicles that are used in practice: the company limited by shares (Aktiengesellschaft, AG), the limited liability company (Gesellschaft mit beschränkter… Read more Singapore · Structuring股份有限公司（AG）与有限责任公司（GmbH）
An AG requires share capital of at least CHF 100,000, of which at least CHF 50,000 or 20 per cent, whichever is higher, must be paid in at formation. Read more Singapore · Structuring作为协议金库的基金会
A foundation is created by the endowment of assets for a particular purpose, by public deed or by testamentary disposition, and acquires legal personality on registration. Read more Singapore · Structuring适用于DAO的社团
An association acquires legal personality once its intention to exist as a corporate body is expressed in written articles that state its purpose, resources and organisation, with no notarial act… Read more Singapore · Structuring分支机构
A foreign company that wishes to have an office in Switzerland without a subsidiary registers a branch (Zweigniederlassung) in the commercial register of the canton where the branch is located. Read more Singapore · Structuring楚格模式：GmbH、基金会与新加坡运营公司
The structure that most protocol projects in Zug end up with has three legs. Read more Singapore · Structuring比较视角：瑞士载体与新加坡对应载体
The reader who has read Chapter III will see that each Swiss vehicle has a Singapore analogue of similar shape and different texture. Read more Singapore · Structuring候选载体与登记机关
Singapore's company law is administered by the Accounting and Corporate Regulatory Authority (ACRA) through the BizFile portal, and incorporation of a private company can be completed online within… Read more Singapore · Structuring股份有限私人公司
A Pte. Ltd. can be formed with one shareholder, one director and a paid-up capital of S$ 1. Read more Singapore · Structuring作为“基金会”的担保有限公司
Singapore has no foundation law. Read more Singapore · Structuring有限责任合伙
An LLP under the Limited Liability Partnerships Act 2005 is a body corporate whose partners are not personally liable for its obligations beyond their contribution, taxed transparently so that each… Read more Singapore · Structuring注册外国公司
A foreign company that establishes a place of business or carries on business in Singapore must register under Part 11 of the Companies Act within one month, appointing at least one authorised… Read more Singapore · Structuring用于亚洲业务的新加坡控股公司
A second use of the Pte. Ltd. is as an intermediate holding company for a group's Asian subsidiaries. Read more Singapore · Structuring如何选择：决策顺序
A Zug AG that provides institutional custody technology wants an Asian sales and support presence and, within two years, a Singapore licence to provide custodial services to Asian clients. Read more Singapore · Structuring关于匿名性、成本与速度的比较说明
Founders from civil-law jurisdictions sometimes expect Singapore to offer the opacity of older offshore centres. It does not. Read more Singapore · Structuring功能分配问题
Once the founder has chosen a residence and the group has its entities, the remaining design question is which function sits where. Read more Singapore · Structuring哪种牌照设在哪里
The two licensing perimeters differ in shape. A group should exploit the difference by placing each activity where it is regulated proportionately. Part O, Chapter I, sets the perimeters side by side. Read more Singapore · Structuring知识产权与金库
A protocol's code is usually open source, so the question of intellectual property is about the things that are not open: trademarks, domain names, proprietary tooling, front-end code, data and the… Read more Singapore · Structuring集团内部服务与转让定价
Every function that one entity performs for another must be paid for at arm's length. Switzerland has no transfer-pricing statute. Read more Singapore · Structuring员工、雇佣与代币计划
Swiss employment law is codified in the Code of Obligations and supplemented by the Labour Act. Singapore's is in the Employment Act 1968 with a common-law overlay. Read more Singapore · Structuring数据、系统与合规体系
A dual-hub group runs one technology stack and must satisfy two data-protection laws and two sets of regulatory technology requirements. Read more Singapore · Structuring两种参考模式
A Zug foundation or AG issues a token or a tokenised security. The Singapore subsidiary markets it to Asian investors, onboards them and provides customer support. Read more Singapore · Structuring路线图概要
A token launch is the event around which most of the structuring in this Part is organised. It is also the event that generates most of the enforcement cases in Parts H and N. Read more Singapore · Structuring第一阶段：定性
Everything else follows from the classification, so it must be done before the entity is formed and before any investor is approached. Read more Singapore · Structuring第二阶段：发行实体与金库
Chapters II and III have set out the vehicles. For the launch the question is which entity is the issuer, because the issuer carries the prospectus liability, the AML duties and the tax on the sale. Read more Singapore · Structuring第三阶段：发行前融资
Most launches are preceded by private rounds in which investors pay now for tokens to be delivered later. Read more Singapore · Structuring第四阶段：发行文件
An offer of a security token to the public in Switzerland requires a prospectus approved by a reviewing body, unless an exemption under Art. 36 or Art. 37 FinSA applies. Read more Singapore · Structuring第五阶段：反洗钱开户审查与旅行规则
An issuer of payment tokens in Switzerland is a financial intermediary under the AMLA from the moment the tokens are transferable, and must identify the participants in the sale, establish… Read more Singapore · Structuring第六阶段：代币生成事件与分配
The token generation event is a technical act with legal consequences. Read more Singapore · Structuring第七至第九阶段：上市、锁定期与做市
Centralised exchanges list tokens under agreements that are drafted by the exchange, are rarely negotiable in their core terms and impose obligations on the issuer that the issuer's legal team… Read more Singapore · Structuring第十阶段：发售的税务处理
The issuer's tax on the sale depends on the entity and the classification. A Zug foundation that is tax-exempt pays nothing. Read more Singapore · Structuring第十一和第十二阶段：治理与突发事件
The transition from a founder-controlled launch to community governance is where the securities analysis is tested over time. Read more Singapore · Structuring基金载体：L-QIF与VCC之比较
A manager who wants to run pooled digital-asset capital from one or both hubs has to answer three questions in order. Where is the fund vehicle? Where is the manager licensed? Read more Singapore · Structuring跨境发售基金份额
The vehicle in one hub will often be sold to investors in the other. A Singapore VCC offered to Swiss investors is a foreign collective investment scheme under Swiss law. Read more Singapore · Structuring两地的管理人牌照
A manager who runs an L-QIF or any other Swiss collective investment scheme is a manager of collective assets under the Financial Institutions Act and needs a FINMA licence, unless the de minimis… Read more Singapore · Structuring两种组合方式
A FINMA-authorised portfolio manager or manager of collective assets in Zug acts as investment adviser or delegated manager to a VCC managed by a licensed Singapore fund management company. Read more Singapore · Structuring托管人的选择
A fund's custody decision follows its vehicle and its regulator. Read more Singapore · Structuring主经纪业务、ETP与家族办公室基金
Prime brokerage for digital assets exists in both hubs in a thin form. Swiss banks offer margin lending against bitcoin and ether and settlement across venues. Read more Singapore · Structuring四种持有方式
A private client with a material digital-asset position has four ways to hold it: personally, through a company, through a foundation or through a trust. Each hub favours a different combination. Read more Singapore · Structuring个人持有
Personal holding is the default and, for a tax resident of either hub, often the best. Read more Singapore · Structuring通过公司持有
A Swiss holding company for personal digital assets is rarely tax-efficient. The company pays profit tax on realised gains at just under 12 per cent in Zug. Read more Singapore · Structuring通过基金会持有
Swiss law permits family foundations only for the limited purposes of Art. 335 CC: the costs of upbringing, endowment, support or similar purposes of family members. Read more Singapore · Structuring通过信托持有
Singapore is a mature trust jurisdiction. The Trustees Act 1967 provides the default powers and the Trust Companies Act 2005 licenses professional trustees. Read more Singapore · Structuring接受加密资产的银行和托管人
A private client needs three relationships: a bank for fiat, a custodian for tokens and, often, a bank that will do both. Switzerland is further ahead. Read more Singapore · Structuring保险
Insurance for digital assets exists in two forms. The custodian's own crime and specie cover protects the custodian's balance sheet and indirectly the client. Read more Singapore · Structuring有瑞士成员的新加坡家族办公室
The Singapore family-office wave of 2019 to 2023 brought several hundred single-family offices to Singapore under the s. 13O and s. 13U incentives, many of them with substantial digital-asset… Read more Singapore · Structuring申报：CRS、CARF与数字资产财富清单
Every structure in this chapter is reported. Under the Common Reporting Standard, banks and custodians in both hubs report accounts of non-resident clients to their home tax administrations. Read more Singapore · Structuring为何数字资产会打破常规规划
An ordinary estate plan assumes that the assets can be found and that someone other than the deceased can get at them. Read more Singapore · Structuring财产清册
The inventory is the digital-asset wealth statement of Chapter VII, extended for the succession case. Read more Singapore · Structuring用于传递的密钥管理
Four arrangements are used to make keys available after death, each with a trade-off between security during life and accessibility after it. Read more Singapore · Structuring瑞士法律文书
A Swiss will may be made by public deed, in holographic form (handwritten, dated and signed) or orally in emergency. Read more Singapore · Structuring新加坡法律文书
A Singapore will must be in writing, signed by the testator at the foot or end and witnessed by two or more witnesses present at the same time, under the Wills Act 1838. Read more Singapore · Structuring跨境遗产
A deceased domiciled in Switzerland is subject to Swiss succession law and Swiss jurisdiction for the whole estate, including assets abroad, under Arts 86 and 90 PILA, unless the deceased, being a… Read more Singapore · Structuring十点方案
A plan that works in both hubs, for a client with assets in both, has ten points. Read more Singapore · Structuring瓶颈
Every structure in this Part fails without a bank account. The Zug GmbH cannot be registered until its capital is deposited at a Swiss bank. The Singapore Pte. Read more Singapore · Structuring在瑞士开立银行账户
Swiss banks distinguish two kinds of digital-asset client. Read more Singapore · Structuring在新加坡开立银行账户
Singapore's three local banks (DBS, OCBC, UOB) and the licensed foreign banks apply a sector risk assessment to digital-asset businesses that has, since the 2022 collapses, been among the most… Read more Singapore · Structuring愿意说“是”的银行
The institutions below were, to my knowledge, open to digital-asset businesses or to private clients with digital-asset wealth on 30 June 2026. Read more Singapore · Structuring资金库的法币出金
A protocol treasury that needs fiat for salaries, rent and taxes has to convert tokens. Four routes exist. The first is sale on a centralised exchange and withdrawal to the entity's bank account. Read more Singapore · Structuring稳定币资金库管理
Many groups keep part of their treasury in stablecoins because they avoid the volatility of their own token and the friction of fiat. Read more Singapore · Structuring以代币支付款项和薪资
Paying staff and contractors in tokens is lawful in both hubs within limits. Read more Singapore · Structuring银行长期希望看到什么
An account that is opened can be closed. Banks in both hubs review digital-asset clients annually and close relationships that have drifted from the business described at opening. Read more Singapore · Structuring故事的结局
A digital-asset business in either hub ends in one of four ways: it is sold, it is merged into a larger group, it is wound down in an orderly fashion, or it fails. Read more Singapore · Structuring出售持牌瑞士企业
A Swiss crypto business is sold in one of two ways. A transfer of the shares in the AG or GmbH leaves the licences, contracts and customer relationships in place. Read more Singapore · Structuring出售持牌新加坡企业
A payment institution licensed under the Payment Services Act 2019 cannot change hands without MAS's prior approval. Read more Singapore · Structuring卖方的税负
The founder who sells shares in a Swiss AG or GmbH held as private wealth realises a tax-free private capital gain, subject to two traps that Swiss practice has refined for decades and that apply… Read more Singapore · Structuring尽职调查的特殊事项
Due diligence on a digital-asset business adds a layer to the ordinary legal, financial and tax review. The additional items are these. Read more Singapore · Structuring客户资产的剥离
A buyer that wants the business without the custody book, or a seller that wants to close the custody book before a sale, must carve out the customer assets. Read more Singapore · Structuring妥善结束持牌业务
A business that closes must be released from supervision. In Switzerland, a FinIA institution that ceases its licensed activity applies to FINMA for release from supervision. Read more Singapore · Structuring跨中心重组
A group that wants to move functions between the hubs, merge its entities or change its licensing footprint faces the same approvals as a sale, with the added question of what happens to the… Read more Singapore · Toolkit实务工具包
The sixteen parts before this one explain the law of digital assets in Switzerland and Singapore in the order a lawyer thinks: nature of the asset, regulatory perimeter, anti-money-laundering… Read more Singapore · Toolkit决策指南
The eight guides in this chapter share a format. Read more Singapore · Toolkit我需要瑞士牌照吗？
The question arrives in many forms. Read more Singapore · Toolkit我需要新加坡牌照吗？
Singapore's answer is reached through fewer statutes but with wider reach. Read more Singapore · Toolkit我的代币是证券吗？
The question is the pivot of both regulatory systems, because a security attracts prospectus duties, dealer licensing and market-abuse rules that a payment or utility token does not. Read more Singapore · Toolkit私人财富还是职业交易？瑞士的税务问题
For an individual resident in Switzerland the question decides whether gains on crypto assets are tax-free private capital gains under Art. 16 para. 3 of the Direct Federal Tax Act (DFTA) or taxable… Read more Singapore · Toolkit交易者还是投资者？新加坡的税务问题
Singapore has no capital gains tax, which means that the question of whether a disposal gain is capital or revenue decides whether it is taxed at all. Read more Singapore · Toolkit我的托管资产具有破产隔离效果吗？
The question matters for every client who leaves crypto assets with a third party: exchange users, funds using a custodian, family offices using a private bank's crypto desk, trustees. Read more Singapore · Toolkit我是否须依CARF进行申报？
The OECD Crypto-Asset Reporting Framework (CARF) obliges reporting crypto-asset service providers to collect self-certifications from users and to report transactions to the tax authority of the… Read more Singapore · Toolkit我能否从楚格或新加坡为欧盟客户提供服务？
The Markets in Crypto-Assets Regulation (MiCA) applies since 30 December 2024 to crypto-asset service providers (CASPs) and since 30 June 2024 to issuers of asset-referenced and e-money tokens. Read more Singapore · Toolkit核对清单
A checklist is only as good as the understanding behind it. The thirteen lists in this chapter assume that the reader has grasped the reasoning in the parts to which they refer. Read more Singapore · Toolkit加入FINMA认可的自律组织
Affiliation to a self-regulatory organisation is the first regulatory act of almost every Swiss crypto business, because the AMLA duty attaches the moment a financial intermediary accepts its first… Read more Singapore · ToolkitFINMA牌照申请
A FINMA licence is needed where the business crosses from AML-only territory into prudential regulation: deposit-taking, portfolio management, securities dealing, fund management, trading venue… Read more Singapore · ToolkitMAS数字支付代币牌照申请
A PSA licence for digital payment token services is applied for through MAS's online portal, following the Guidelines on Licensing for Payment Service Providers (PS-G01). Read more Singapore · Toolkit《2022年金融服务与市场法》第9部分下的MAS数字代币服务提供商制度
The digital token service provider regime catches Singapore-based persons who provide digital token services outside Singapore and who are not already licensed under the PSA, SFA or another… Read more Singapore · Toolkit反洗钱计划
The AML programme is the document regulators and banks ask for first and read most closely. Read more Singapore · Toolkit旅行规则的实施
Both hubs require financial intermediaries to transmit originator and beneficiary information with crypto transfers. Read more Singapore · Toolkit代币发售文件
A token sale produces a predictable set of documents whose quality determines what the issuer can say to FINMA, to MAS, to exchanges and to purchasers afterwards. Read more Singapore · Toolkit托管协议审查
Whether the client is placing assets with a custodian or acting as one, the custody agreement decides the insolvency outcome analysed in the sixth decision guide. Read more Singapore · Toolkit数字资产的遗产规划
The death of a token holder is the event for which the fewest clients have prepared. The checklist translates the planning principles of Part P, Chapter VIII into actions. Read more Singapore · Toolkit遭黑客攻击后的事件响应
The first hours after a security incident decide whether assets are recovered and whether the firm survives the regulatory aftermath. Read more Singapore · Toolkit最初72小时的资产追踪
Stolen or misappropriated tokens move fast and leave a public trail. The first 72 hours are when the trail is freshest and when freezing orders can still catch assets at an exchange. Read more Singapore · Toolkit移居楚格
A founder or investor relocating to Zug faces immigration, tax, social security and practical steps that interlock. Read more Singapore · Toolkit移居新加坡
A founder relocating to Singapore needs a pass before anything else. The pass depends on the role. The Employment Pass requires a sponsoring employer and a qualifying salary. Read more Singapore · Toolkit示范条款与文件框架
Model clauses are dangerous in the hands of someone who does not know why each word is there. Read more Singapore · Toolkit托管协议：瑞士法下的核心条款
The Swiss custody agreement has one job above all others: to put the client within Art. 242a DEBA. Read more Singapore · Toolkit托管协议：新加坡法下的核心条款
Under Singapore law the custody agreement achieves insolvency remoteness by creating a trust. The drafting must therefore supply the three certainties: intention, subject matter and object. Read more Singapore · Toolkit代币购买协议：关键条款
The token purchase agreement governs the primary sale of tokens that exist or will exist at closing. Its difficulties lie in three places. Read more Singapore · Toolkit未来代币简单协议
The SAFT is an investment contract under which the investor pays now for tokens to be delivered when the network launches. Read more Singapore · Toolkit楚格协议基金会的宗旨条款
The Swiss foundation is a dedicated body of assets with legal personality, created by a founder for a purpose that the foundation board must pursue and that the supervisory authority polices. Read more Singapore · ToolkitDAO社团章程：纲要
The Swiss association under Art. 60 ff. Read more Singapore · Toolkit瑞士—新加坡合同的准据法与争议解决条款
Contracts between Swiss and Singapore parties need a governing law that both courts will respect and a forum that can grant relief against assets in both places. Read more Singapore · Toolkit数字资产的遗嘱条款
A will that does not mention digital assets leaves the executor with two problems: establishing that the assets exist and gaining the power to deal with them. The clause below solves the second. Read more Singapore · Toolkit致持有代币之受托人的意愿书
A trustee holding digital assets needs guidance on matters a conventional letter of wishes never covers. Read more Singapore · Toolkit接受加密资产作为出资的董事会决议
Swiss company law permits contributions in kind on incorporation or a capital increase if the asset can be shown on the balance sheet, can be transferred to the company and is realisable. Read more Singapore · Toolkit附时间表和费用区间的程序路线图
Clients ask two questions about every procedure before they ask about the law: how long will it take and what will it cost. Read more Singapore · Toolkit加入瑞士自律组织与《金融机构法》投资组合管理人牌照
The combined roadmap covers the common case of a Zug asset manager that first affiliates with an SRO to begin AML-compliant operations and then obtains a portfolio manager licence under Art. 17… Read more Singapore · Toolkit新加坡数字支付代币服务主要支付机构牌照
The MPI roadmap assumes a Singapore company applying for a licence to provide DPT services, with retail and institutional customers and a group parent in Switzerland. Read more Singapore · Toolkit楚格协议基金会
The Swiss foundation is established by public deed before a notary, registered in the commercial register and placed under the supervision of the competent authority, which for protocol foundations… Read more Singapore · Toolkit新加坡可变资本公司
The VCC is Singapore's fund vehicle, incorporated under the Variable Capital Companies Act 2018 and registered with ACRA, with a MAS-licensed or registered fund manager as a statutory requirement. Read more Singapore · Toolkit瑞士限制性合格投资者基金
The L-QIF, available since 1 March 2024, is a collective investment scheme for qualified investors that requires no FINMA approval or supervision of the fund itself. Read more Singapore · Toolkit瑞士定额课税裁定
The expenditure-based taxation ruling is sought from the cantonal tax administration before the individual takes up residence. Read more Singapore · Toolkit新加坡就业准证与ONE准证
The Employment Pass is sponsored by a Singapore employer and depends on a qualifying salary, which is higher for older applicants and for the financial services sector. Read more Singapore · Toolkit瑞士与新加坡的自愿披露
Both jurisdictions reward a taxpayer who discloses undeclared income or assets before the authority finds them. Read more Singapore · Toolkit监管机构与主管机关名录
A practitioner moving between Zug and Singapore deals with two dozen public bodies and a dozen private ones whose names recur throughout this book. Read more Singapore · Toolkit瑞士：监管与政策
The integrated supervisor of banks, insurers, securities firms, fund managers, portfolio managers (through the AOs), financial market infrastructures and, for AML purposes, directly supervised… Read more Singapore · Toolkit瑞士：税务
Responsible for direct federal tax policy and supervision of the cantons, withholding tax, stamp duties, VAT and the international exchange of information including CRS and, once the partner-state… Read more Singapore · Toolkit瑞士：刑事执法与反洗钱
The federal prosecutor, competent for money laundering with international dimensions, organised crime, offences against the federal administration and cases delegated by the cantons. Read more Singapore · Toolkit瑞士：登记、法院与自律
The registration authorities for companies, foundations (except family and ecclesiastical foundations) and associations carrying on a commercial business. Read more Singapore · Toolkit新加坡：监管与政策
The central bank and integrated financial regulator, responsible for the PSA, the SFA, the FSMA and the AML/CFT notices for all regulated financial institutions. Read more Singapore · Toolkit新加坡：税务、刑事执法与反洗钱
The tax authority for income tax, GST, stamp duty and property tax, which also acts as the competent authority for CRS and CARF exchange. Read more Singapore · Toolkit新加坡：法院、争议解决与行业组织
The General Division of the High Court hears first-instance civil claims above the district court limit and all applications for proprietary injunctions, freezing orders and disclosure orders in… Read more Singapore · Toolkit对应机构对照表
The most common error of a Swiss practitioner in Singapore is to expect an SRO-like body that will discuss a business model informally before any filing. There is none. Read more Singapore · Toolkit客户常见问题
The forty questions in this chapter are the ones clients actually ask, in the words they use. The answers are short by design and point to the part of the book that carries the full analysis. Read more Singapore · Toolkit创始人
I am building a protocol, so should I incorporate in Zug or in Singapore? For the protocol foundation and the token issuer, the answer in most cases is Zug. Read more Singapore · Toolkit投资者
I have held Bitcoin for years and sell occasionally, so will Switzerland tax my gains? No, provided you qualify as a private investor under the Circular 36 criteria or the overall assessment. Read more Singapore · Toolkit家族办公室
Should our family office hold crypto directly, through a company or through a fund? Read more Singapore · Toolkit银行与金融机构
We are a Swiss bank, so can we offer crypto custody and trading without a new licence? Yes. Read more Singapore · Toolkit受托人
Can a Singapore licensed trust company hold crypto? Yes. The Trust Companies Act 2005 does not restrict the assets a licensed trust company may hold. Read more Singapore · Toolkit律师同行
My client wants to pay my fees in crypto, so may I accept? Yes in both countries, with AML consequences that are easy to overlook. Read more Singapore · Reference附录
The five annexes that follow are working tools. A reader opens them while a chapter is being read, when a date, a statutory reference, a case citation or a regulator document needs its context. Read more Singapore · Reference大事年表（2008–2026年）
This chronology records, in one line each, the events that shaped digital-asset law in Switzerland and Singapore and the international standards that both hubs implemented. Read more Singapore · Reference法律法规一览表
This table lists the statutes, ordinances and international instruments cited in the book. Read more Singapore · Reference瑞士：联邦法律
Switzerland: federal acts: a section of the book. Read more Singapore · Reference瑞士：条例
Switzerland: ordinances: a section of the book. Read more Singapore · Reference法律法规一览表：新加坡
Table of legislation: Singapore: a section of the book. Read more Singapore · Reference欧盟
European Union: a section of the book. Read more Singapore · Reference国际文书与标准
International instruments and standards: a section of the book. Read more Singapore · Reference判例一览表
The decisions below are those cited in the book, arranged by jurisdiction and, within each jurisdiction, by date. Read more Singapore · Reference判例一览表：新加坡
Table of cases: Singapore: a section of the book. Read more Singapore · Reference瑞士
Switzerland: a section of the book. Read more Singapore · Reference其他司法管辖区
Other jurisdictions: a section of the book. Read more Singapore · Reference监管指引一览表
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 · ReferenceFINMA
FINMA: a section of the book. Read more Singapore · ReferenceMAS
MAS: a section of the book. Read more Singapore · ReferenceFTA及各州税务机关
FTA/ESTV and cantonal tax administrations: a section of the book. Read more Singapore · ReferenceIRAS
IRAS: a section of the book. Read more Singapore · ReferenceSECO
SECO: a section of the book. Read more