新加坡（三）：监管——PSA、SFA、FSMA/DTSP、稳定币、代币化——Alexander Ressos博士著作《新加坡与瑞士数字资产法》（Digital Assets Law in Singapore and Switzerland）的一部分。
新加坡（三）：监管——PSA、SFA、FSMA/DTSP、稳定币、代币化：Alexander Ressos博士著作《新加坡与瑞士数字资产法》（Digital Assets Law in Singapore and Switzerland）的一部分。
本部分属于Alexander Ressos博士的著作新加坡与瑞士数字资产法，全书在本站逐节完整发布。
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