新加坡的数字资产规则在国际标准框架内并通过与其他中心的比较而形成。本栏目文章介绍比较新加坡与瑞士的七个维度，以及MiCA、香港、美国、英国和阿联酋。文章还涉及FATF、金融稳定理事会、巴塞尔委员会、国际证监会组织和经合组织的标准、各项标准如何落实为国内法，以及何为正当的监管套利。
新加坡自1992年起成为金融行动特别工作组（FATF）成员，并于2022年7月至2024年6月担任主席。第15项建议和旅行规则通过MAS通告进入本地实务。经合组织的加密资产报告框架（CARF）沿着同一路径进入税务申报。
以这座城市命名的《新加坡调解公约》自2020年9月12日起生效。截至2026年8月28日，该公约有60个签署方和25个缔约方。
在多个中心开展业务的集团必须了解规则在哪些方面并行、在哪些方面分歧。文章比较资产的法律性质、牌照范围、托管、反洗钱、税务、执法和继承。
每项比较都说明其局限，因为一项规则并不总能脱离其所在的法律秩序而单独移植。
小国外交：东盟与战略平衡
A financial centre lives on the confidence of people who will never visit it. Read more Singapore · Law and Disputes东盟的成立
Singapore did not seek independence on its own. It entered the Federation of Malaysia in 1963 and left it two years later after political and communal tensions that Chapter C.II describes. Read more Singapore · Law and Disputes小国现实主义
Singapore's foreign policy rests on a sober view of its own position. Read more Singapore · Law and Disputes贸易协定与经济外交
Few economies depend on trade as heavily as Singapore. Its trade in goods and services was equivalent to about 320 per cent of gross domestic product in 2020. Read more Singapore · Law and Disputes中立及其局限
Outside observers sometimes describe Singapore as neutral, a term its own government avoids. Read more Singapore · Law and Disputes外交为金融中心服务
The first service that diplomacy renders to the financial centre is predictability. A client who places assets in Singapore makes a bet on the jurisdiction over a horizon of ten or twenty years. Read more Singapore · Law and Disputes小国外交：东盟与战略平衡：实际影响
For banks, asset managers and trust companies, Singapore's foreign policy creates both opportunities and obligations. Read more Singapore · Law and Disputes小国外交：东盟与战略平衡：与日内瓦和香港的比较
Switzerland and Singapore are both small states that have turned their foreign policy into an asset for their financial centres. Their methods differ. Read more Singapore · Law and Disputes小国外交：东盟与战略平衡：摘要
Singapore became independent in 1965 without security or a hinterland and placed its survival inside a regional framework when its foreign minister Rajaratnam signed the Bangkok Declaration that… Read more Singapore · Law and Disputes新加坡的国际与区域机构
A financial centre lives from more than banks, exchanges and courts. It also lives from the institutions that gather governments, central banks and experts around common problems. Read more Singapore · Law and DisputesAPEC与区域经济合作
Regional economic cooperation in the Asia-Pacific began with economists and businessmen. Read more Singapore · Law and Disputes区域金融监测与合作
The Asian financial crisis of 1997, which Chapter D.III examines, left East Asian governments with a sharp lesson. Read more Singapore · Law and Disputes中央银行合作与创新中心
The central banks of East Asia and the Pacific cooperate through the Executives' Meeting of East Asia-Pacific Central Banks, established in 1991. Read more Singapore · Law and Disputes标准制定机构与区域办事处
The global standard setters for finance sit in Europe. The Financial Stability Board, established in April 2009 as the successor of the Financial Stability Forum, is hosted by the BIS in Basel. Read more Singapore · Law and Disputes对金融中心的实际影响
The international institutions in Singapore are small employers compared with the financial sector itself. Their value lies in information and in contacts. Read more Singapore · Law and Disputes国际新加坡与国际日内瓦
The difference between the two cities begins with numbers. Read more Singapore · Law and Disputes新加坡的国际与区域机构：摘要
Singapore hosts a small number of international organisations whose subjects lie close to economics and finance, among them the APEC Secretariat, the ASEAN+3 Macroeconomic Research Office, the… 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