有些主题必须从基础理解，细节才有意义。本栏目文章介绍两本书的主题：金融中心专著的前言，新加坡和瑞士为何成为数字资产中心，比较的方法，以及律师解读交易、托管安排或代币所需的技术与分类。每篇文章都提供概述并指向详细章节。
Singapore as an International Financial Centre（新加坡：国际金融中心）— 前言
Few places show as clearly as Singapore that a financial centre can be built by design. Read more Singapore · Gateway to Asia东南亚与区域总部
A multinational group that wants to sell, produce or invest in Southeast Asia faces a region of eleven states, several hundred million consumers and almost as many legal systems as languages. Read more Singapore · Gateway to Asia区域总部模式
A regional headquarters sits between the global head office of a group and its operating subsidiaries in individual countries. Read more Singapore · Gateway to Asia东盟经济一体化
ASEAN was founded on 8 August 1967 in Bangkok by Indonesia, Malaysia, the Philippines, Singapore and Thailand. Read more Singapore · Gateway to Asia条约网络与投资保护
A regional headquarters often holds the shares of the operating companies in the region. Dividends, interest, royalties and service fees then flow from those companies to Singapore. Read more Singapore · Gateway to Asia进入区域市场
The single market of ASEAN remains, for most practical purposes, a collection of national markets with their own company laws, foreign investment rules, tax systems, labour laws and languages. Read more Singapore · Gateway to Asia区域风险及其管理
Southeast Asia has experienced coups, contested elections, mass protests and abrupt changes of policy within the lifetime of most investments. The most dramatic recent example is Myanmar. Read more Singapore · Gateway to Asia东南亚与区域总部：实务影响
A group that establishes a regional headquarters in Singapore should treat the decision as a combination of operational, legal and tax choices. Read more Singapore · Gateway to Asia东南亚与区域总部：与日内瓦和香港的比较
The Geneva volume describes the city's relationship with Africa as one built on trade, banking, diplomacy and the French language. Read more Singapore · Gateway to Asia东南亚与区域总部：摘要
Singapore has become the leading location for regional headquarters in Asia, with about 4,200 regional offices according to an EY study of 2019, because it combines connectivity, talent, legal… Read more Singapore · Gateway to Asia中国：资本、家族财富与“一带一路”
China is Singapore's largest trading partner and the state with which its relationship is most layered. Read more Singapore · Gateway to Asia历史渊源与外交关系
The Chinese presence in Singapore is older than the modern state. Read more Singapore · Gateway to Asia贸易、投资与政府间合作项目
The growth of trade since 1990 has been rapid. Bilateral trade rose from US$8.154 billion in 1998 to US$10.821 billion in 2000. By 2009 it had reached S$75.1 billion. Read more Singapore · Gateway to Asia在新加坡的中国企业
The first Chinese enterprises in modern Singapore were banks and state trading companies. Read more Singapore · Gateway to Asia中国家族财富与家族办公室
The movement of Chinese wealth to Singapore has several causes. Read more Singapore · Gateway to Asia“一带一路”与基础设施融资
President Xi Jinping presented the Silk Road Economic Belt at Nazarbayev University in Astana on 7 September 2013. Read more Singapore · Gateway to Asia涉华业务中的合规挑战
The first compliance question in any China-related relationship concerns the origin of the funds. Read more Singapore · Gateway to Asia中国：资本、家族财富与“一带一路”：与日内瓦和香港的比较
Switzerland was among the first Western states to recognise the People's Republic, on 17 January 1950. Read more Singapore · Gateway to Asia中国：资本、家族财富与“一带一路”：摘要
Singapore's relationship with China grew from the ties of a diaspora with its homeland into a relationship between states, beginning with Deng Xiaoping's visit in November 1978 and formalised by… Read more Singapore · Gateway to Asia印度：投资走廊与GIFT City
Measured by the official statistics of New Delhi, no country has sent more direct investment to India in the past quarter-century than Singapore. Read more Singapore · Gateway to Asia历史与社群纽带
The Indian presence in Singapore is as old as the British settlement. Read more Singapore · Gateway to Asia避免双重征税协定及其修订
Singapore and India concluded a first agreement for the avoidance of double taxation on 20 April 1981. Read more Singapore · Gateway to Asia投资印度的基金
Between April 2000 and March 2026 India recorded equity FDI inflows of 787.72 billion US dollars. Read more Singapore · Gateway to AsiaGIFT City：伙伴与竞争者
Gujarat International Finance Tec-City, known as GIFT City, is a planned financial district on the Sabarmati river near Gandhinagar. Read more Singapore · Gateway to Asia监管合作
The legal basis of tax cooperation is the exchange of information clause of 2011 described above, supplemented by the automatic exchange of financial account information under the Common Reporting… Read more Singapore · Gateway to Asia印度：投资走廊与GIFT City：实务影响
The Singapore route to India remains open to structures with substance. Read more Singapore · Gateway to Asia与日内瓦、毛里求斯和迪拜的比较
Switzerland’s relationship with India has been shaped by wealth management more than by direct investment. Read more Singapore · Gateway to Asia印度：投资走廊与GIFT City：摘要
Singapore’s ties with India date from the arrival of Indian soldiers, traders and convicts after 1819, the government of the Straits Settlements from Calcutta until 1867 and the credit networks of… Read more Singapore · Gateway to Asia印度尼西亚与马来西亚：近邻
Singapore has two neighbours with which it shares a strait, a history and a large part of its daily economic life. Read more Singapore · Gateway to Asia新加坡的印度尼西亚财富
The relationship between Singapore and Indonesia began in conflict. Read more Singapore · Gateway to Asia廖内群岛与跨境区域
The Riau Islands lie between 6 and 20 kilometres south of Singapore across the Singapore Strait. Read more Singapore · Gateway to Asia马来西亚与柔佛—新加坡经济特区
The relationship with Malaysia has a different starting point. Singapore was part of Malaysia from 1963 until its separation on 9 August 1965, which Chapter C.II examines. Read more Singapore · Gateway to Asia税务特赦与资产汇回
The most important event for Indonesian wealth in Singapore in the past decade was the tax amnesty that ran from July 2016 to 31 March 2017 under Law No. 11 of 2016 on tax amnesty. Read more Singapore · Gateway to Asia邻国：机遇与风险
Indonesia and Malaysia are home to some of the largest and fastest-growing middle classes in Asia. For Singapore, they are hinterland, market and source of clients at once. Read more Singapore · Gateway to Asia近邻与日内瓦的比较
Geneva lives in an even closer relationship with its neighbour. Read more Singapore · Gateway to Asia印度尼西亚与马来西亚：近邻：摘要
Singapore’s relationship with Indonesia and Malaysia combines geography, history and finance more closely than any other relationship of the financial centre. Read more Singapore · Gateway to Asia避风港：资本流入、财富移民及其政治
Every financial centre that succeeds attracts two kinds of arrivals: money looking for safety and people looking for a place to live with it. Read more Singapore · Gateway to Asia新加坡作为避风港
A safe haven, in the language of finance, is a place where capital is expected to keep its value and remain accessible in times of stress. Read more Singapore · Gateway to Asia财富移民与居留计划
Wealth can move without its owners, but the families who move their family office to Singapore usually want to live there as well. Read more Singapore · Gateway to Asia房地产、住房与舆论
Property is the point at which foreign wealth touches the daily life of Singaporeans most directly. Read more Singapore · Gateway to Asia资金流入与非法资金风险
The attributes that make Singapore attractive to honest wealth also make it attractive to criminals. Read more Singapore · Gateway to Asia在开放与诚信之间取得平衡
The government has expressed its approach to the inflow in a formula that recurs in official statements. Read more Singapore · Gateway to Asia避风港：资本流入、财富迁移及其政治：与日内瓦、香港和迪拜的比较
Geneva and Singapore share the role of safe haven, although their histories of it differ. Read more Singapore · Gateway to Asia避风港：资本流入、财富迁移及其政治：摘要
Singapore attracts wealth because it combines political stability, the rule of law, a strong currency, an AAA rating and a deep financial ecosystem, and by the end of 2025 assets under management… Read more Singapore · Language英语作为工作语言
A visitor who lands at Changi, takes a taxi to Raffles Place and spends a day in meetings with bankers, lawyers and regulators may never hear a word of any language other than English. Read more Singapore · Language英语的殖民遗产
When Raffles founded the British settlement in 1819, English was the language of a handful of officials and merchants. Read more Singapore · Language独立后对英语的选择
The legal framework of language in Singapore took shape in three steps. In 1955 the Legislative Assembly gave official status to English, Mandarin, Malay and Tamil. Read more Singapore · Language英语作为各社群之间的共同语言
The success of the policy is measured most clearly by the language that Singaporeans speak at home. Read more Singapore · Language金融与合同中的英语
In the financial sector the question of language hardly arises, because everything is in English. Read more Singapore · Language新加坡英语与国际英语
The English of Singapore is a variety of English with its own features. Read more Singapore · Language英语作为工作语言：对客户和顾问的实际影响
For a European client or adviser, the use of English in Singapore has several practical consequences. Read more Singapore · Language英语作为工作语言：与日内瓦、香港和迪拜的比较
Geneva and Singapore face the language question from opposite ends. Geneva is a French-speaking city in a mainly German-speaking country, working in an industry whose global language is English. Read more Singapore · Language英语作为工作语言：摘要
English came to Singapore as the language of the colonial administration, the courts and the European firms, and spread through mission and government schools, the Queen’s Scholarship and the… Read more Singapore · Language双语政策与作为商业资产的华语
On the evening of 7 September 1979 the Prime Minister, Lee Kuan Yew, opened a campaign at the Singapore Conference Hall with a sentence that set out a problem of language policy in the terms of a… Read more Singapore · Language教育中的双语政策
Before independence Singapore had four school systems, each teaching in a different medium. Read more Singapore · Language讲华语运动
The campaign followed directly from the Goh Report. Lee Kuan Yew’s diagnosis was practical. Read more Singapore · Language方言、华语与身份认同
The Chinese who came to Singapore in the nineteenth century spoke the languages of their districts in Fujian and Guangdong. By the middle of the twentieth century at least twelve dialects were in use. Read more Singapore · Language与中国商业往来中的华语
The economic value of Mandarin depended on China opening to the world. When Lee Kuan Yew first visited China in 1976, he conducted his official meetings in English. Read more Singapore · Language作为官方语言的马来语和淡米尔语
Article 153A of the Constitution of the Republic of Singapore names four official languages: Malay, Mandarin, Tamil and English. Read more Singapore · Language双语政策与作为商业资产的华语：实际影响
For banks, wealth managers, family offices and law firms, the bilingual policy produces a workforce in which almost everyone speaks English and many understand a second language. Read more Singapore · Language双语政策与作为商业资产的华语：与日内瓦和香港的比较
Geneva’s position is the mirror image of Singapore’s. French is the main language of 79 % of the canton’s residents. Read more Singapore · Language双语政策与作为商业资产的华语：摘要
Singapore made a second language compulsory in all schools in 1966 and, after the Goh Report of 1979, turned English into the first language of a single school system from 1987, with Mandarin, Malay… Read more Singapore · Language以英语运作的普通法：合同、法院与法律服务
A financial centre sells promises. Read more Singapore · Language普通法传统
The legal foundations of British Singapore, traced in Part A, lie in the Second Charter of Justice of 27 November 1826. Read more Singapore · Language新加坡法律作为合同准据法
A governing law clause answers several questions at once. Read more Singapore · Language法律职业与外国律师事务所
Singapore lawyers belong to a fused profession. Read more Singapore · Language面向区域的法律服务
Legal services have become a sector that the government measures and promotes like any other service industry. Read more Singapore · Language新加坡法律与瑞士法律作为法律选择
Swiss law and Singapore law are among the laws most often chosen by parties who have no connection with either country. Read more Singapore · Language日内瓦、香港与迪拜比较
Geneva offers Swiss law, a codified civil law, in a city whose courts sit in French. Read more Singapore · Language英语普通法：合同、法院与法律服务：摘要
Singapore received English law through the Charter of 1826 and the Civil Law Ordinance of 1878, then gave its common law a fixed and sovereign basis through the Application of English Law Act 1993… Read more Singapore · Language人才：教育、移民与金融从业人员
A financial centre has no mines, fields or factories of its own. Read more Singapore · Language大学与金融教育
Higher education in Singapore began with medicine. Read more Singapore · Language就业准证与移民政策
Singapore has always been a city of immigrants, as Part A described for the nineteenth century. The modern policy of recruiting foreign professionals took shape in the 1990s. Read more Singapore · Language本地人才与外国人才
Singapore’s population in June 2026 was about 6.21 million, of whom 3.68 million were citizens, about 547,000 permanent residents and 1.98 million non-residents. Read more Singapore · Language专业资格与继续教育
The central institution of professional training in Singapore’s financial sector is the Institute of Banking and Finance (IBF). Read more Singapore · Language人才争夺战
Singapore’s efforts have earned international recognition. Read more Singapore · Language对企业和专业人士的实际影响
A financial institution that builds a team in Singapore must think about immigration from the outset. The qualifying salary, which rises with age, determines the minimum cost of each foreign hire. Read more Singapore · Language人才：教育、移民与金融业劳动力：与日内瓦的比较
Geneva and Singapore both depend on foreign professionals, but they obtain them through very different legal channels. Read more Singapore · Language人才：教育、移民与金融业劳动力：摘要
Singapore has built its financial workforce through three public research universities: the National University of Singapore with roots in 1905, Nanyang Technological University with roots in the… Read more Singapore · Singapore 2035加密资产：从《支付服务法》到Project Guardian
Few subjects have tested the reputation of the Monetary Authority of Singapore as severely as crypto-assets. Read more Singapore · Singapore 2035《2019年支付服务法》
Before 2020 the regulation of payments in Singapore was divided between two statutes. Read more Singapore · Singapore 20352022年的倒闭事件及其监管后果
The first shock came in May 2022. Read more Singapore · Singapore 2035FSMA下的数字代币服务提供商
The Financial Services and Markets Act 2022 is an omnibus statute that gives the Monetary Authority sector-wide powers over financial institutions. Read more Singapore · Singapore 2035稳定币
Stablecoins occupy a special position in the regulatory strategy. Read more Singapore · Singapore 2035Project Guardian与代币化
The Monetary Authority began to explore distributed ledger technology for wholesale finance in 2016, working with banks, international organisations and other central banks on digital currencies… Read more Singapore · Singapore 2035加密资产：从《支付服务法》到守护者项目：实务影响
A firm that wishes to offer services in crypto-assets from Singapore must first determine which statute applies. Read more Singapore · Singapore 2035与日内瓦和苏黎世的比较
Switzerland and Singapore both claim legal certainty for crypto-assets, which they achieved by different means. Read more Singapore · Singapore 2035加密资产：从《支付服务法》到守护者项目：摘要
Singapore brought cryptocurrency dealing and exchange under licence through the Payment Services Act 2019, in force since 28 January 2020, whose first purpose was to prevent money laundering and… Read more Singapore · Singapore 2035可持续金融与碳市场
Sustainable finance came late to Singapore. Read more Singapore · Singapore 2035绿色金融行动计划
Singapore’s turn to green finance was announced as policy before the market demanded it. Read more Singapore · Singapore 2035分类法与信息披露
A taxonomy is a classification system that states which economic activities count as sustainable. It is the dictionary on which green labels, grant eligibility and disclosure depend. Read more Singapore · Singapore 2035碳税与碳信用
Singapore introduced Southeast Asia’s first carbon tax on 1 January 2019. The legal basis is the Carbon Pricing Act 2018 and its regulations. Read more Singapore · Singapore 2035亚洲的转型金融
The transition question in Asia is above all a question of coal. Asia accounts for about half of global greenhouse gas emissions, roughly a third of which come from coal-fired power plants. Read more Singapore · Singapore 2035“漂绿”与法律责任
Greenwashing, the presentation of products or activities as more sustainable than they are, is the legal risk that accompanies the growth of the field. Read more Singapore · Singapore 2035可持续金融与碳市场：实务影响
For banks, insurers and asset managers in Singapore, sustainable finance has become a matter of risk management and conduct, and only in the second place a business opportunity. Read more Singapore · Singapore 2035新加坡与日内瓦：通往可持续金融的两条道路
Geneva and Singapore have both made sustainable finance a strategic field, from different starting points and with different instruments. Read more Singapore · Singapore 2035可持续金融与碳市场：摘要
Singapore turned sustainable finance into a strategic field of its financial centre through the Green Finance Action Plan of 2019 and the Finance for Net Zero Action Plan of 2023, using grants,… Read more Singapore · Singapore 2035竞争：香港、迪拜、伦敦、苏黎世和日内瓦
A financial centre is measured against the places that compete for its clients, its firms and its talent. Singapore has never been able to forget this. Read more Singapore · Singapore 2035香港
The rivalry between Singapore and Hong Kong is almost as old as the two British settlements. Read more Singapore · Singapore 2035迪拜与海湾地区
Dubai entered the competition late and from an unusual starting point. Read more Singapore · Singapore 2035伦敦
London is the centre on which Singapore was modelled, in law and in institutions. Read more Singapore · Singapore 2035苏黎世与日内瓦
For three decades Singapore has been called the Switzerland of Asia. Read more Singapore · Singapore 2035排名及其意义
The most widely cited ranking is the Global Financial Centres Index, first published in March 2007 by the London think tank Z/Yen and, since 2015, produced jointly with the China Development… Read more Singapore · Singapore 2035实际影响：在金融中心之间作出选择
A family, a firm or an asset manager choosing among Singapore, Hong Kong, Dubai, London and the Swiss centres will weigh criteria that rankings capture only partly. Read more Singapore · Singapore 2035竞争：香港、迪拜、伦敦、苏黎世和日内瓦：新加坡与日内瓦之比较
The Geneva volume describes the competition of centres from the viewpoint of a city that is losing relative market share while growing in absolute terms. Read more Singapore · Singapore 2035竞争：香港、迪拜、伦敦、苏黎世和日内瓦：摘要
Singapore ranked fourth among the world’s financial centres in the Global Financial Centres Index of September 2026, one point behind Hong Kong and ahead of Dubai, Zurich and Geneva, a position that… Read more Singapore · Singapore 2035人工智能与金融中心
Every generation of technology has reshaped the work of Singapore’s financial centre. The telegraph tied the agency houses of the nineteenth century to London and Calcutta. Read more Singapore · Singapore 2035银行业与资产管理中的人工智能
Banks used statistical models long before the term artificial intelligence became fashionable. Credit scoring, market risk models and fraud rules have been part of banking for decades. Read more Singapore · Singapore 2035负责任使用的原则
Singapore was among the first jurisdictions to issue principles specifically for the use of artificial intelligence in finance. Read more Singapore · Singapore 2035合规与监管中的人工智能
Compliance is one of the most promising and most delicate fields for artificial intelligence. Read more Singapore · Singapore 2035责任与问责
Who is liable when an artificial intelligence system makes a mistake? Singapore has so far answered this question without new legislation. Read more Singapore · Singapore 2035人工智能与金融工作的未来
The financial sector is one of Singapore’s largest employers of skilled labour. Read more Singapore · Singapore 2035人工智能与金融中心：实际影响
For financial institutions in Singapore, the Guidelines of October 2026 turn artificial intelligence governance into a project with deadlines. Read more Singapore · Singapore 2035与日内瓦、苏黎世和欧盟的比较
Switzerland and Singapore share a preference for principles and ordinary supervision over a dedicated statute. Read more Singapore · Singapore 2035人工智能与金融中心：摘要
Artificial intelligence entered Singapore’s financial institutions through machine-learning models in risk management, anti-money laundering, fraud detection and customer engagement, before… Read more Singapore · Singapore 2035地缘政治：在美国与中国之间
Singapore became a financial centre in a world that was, for most of its independent history, growing more open. Read more Singapore · Singapore 2035战略竞争与金融中心
The modern financial centre was built on assumptions that held for half a century. Read more Singapore · Singapore 2035技术管制与供应链
The most important instrument of the rivalry is technology control. Read more Singapore · Singapore 2035制裁风险
Sanctions reach Singapore at three levels. The first consists of measures adopted by the United Nations Security Council, which Singapore implements as a matter of international obligation. Read more Singapore · Singapore 2035新加坡作为中间人
Singapore has a long practice of offering itself as a meeting place. Read more Singapore · Singapore 2035碎片化的情景
Economists have tried to measure the cost of a divided world economy. Read more Singapore · Singapore 2035地缘政治：在美国与中国之间：实际影响
Banks and asset managers in Singapore should treat geopolitical risk as a permanent feature of their business. Read more Singapore · Singapore 2035地缘政治：在美国与中国之间：与日内瓦、香港和迪拜的比较
Switzerland faced the same choice in 2022 and resolved it more decisively. Read more Singapore · Singapore 2035地缘政治：夹在美国与中国之间：摘要
Singapore built its financial centre in an open world economy whose assumptions the rivalry between the United States and China now calls into question. Read more Singapore · Singapore 20352035年情景
This last chapter brings together the developments that the preceding chapters of Part K have described one by one: crypto-assets, sustainable finance, competition between centres, artificial… Read more Singapore · Singapore 2035方法
Scenario planning grew out of military strategy. Read more Singapore · Singapore 2035情景一：亚洲枢纽地位巩固
The first scenario extends the trends of the period since 2020. Asian wealth continues to grow faster than wealth in Europe and North America. Read more Singapore · Singapore 2035情景二：分裂与中立
The second scenario assumes that the rivalry between the United States and China, examined in Chapter V of this part, hardens into a division of the world economy. Tariffs rise and stay high. Read more Singapore · Singapore 2035情景三：数字颠覆
The third scenario assumes that technology changes the structure of financial intermediation faster than the base case suggests. Tokenised bonds, funds and deposits become common. Read more Singapore · Singapore 2035情景四：诚信危机
The fourth scenario takes the threats that Part E and Part H described and asks what would happen if one of them materialised on a larger scale. Read more Singapore · Singapore 20352035年情景：实际影响
Some decisions perform well in all four scenarios, which makes them the first priority for a prudent firm. Read more Singapore · Singapore 20352035年情景：与日内瓦的比较
The Geneva volume develops three scenarios for its city: a specialised and connected centre that accepts its rank and concentrates on functions where it remains unrivalled, an eroded centre that… Read more Singapore · Singapore 2035结论
Of the four scenarios, the consolidated Asian hub is the most probable in the author’s judgement. Read more Singapore · Singapore 20352035年情景：摘要
The method of scenarios, which Herman Kahn developed at RAND and Pierre Wack brought to Shell in 1971, has been used by the Singapore government since its experiments in the Ministry of Defence in… Read more Singapore · Two Hubs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 · 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 · 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 · 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 · 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 · 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 · 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 · 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 · 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 · 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