Singapore and Hong Kong

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Singapore regulates crypto service providers under the Payment Services Act of 2019, which introduced a licence for digital payment token services. The Monetary Authority of Singapore has applied the licence restrictively, granting it to a limited number of providers and refusing or withdrawing many applications. It has also restricted the marketing of crypto services to retail clients and has introduced further requirements for providers that serve clients only abroad.¹ The collapse of several Singapore-based crypto firms in 2022, among them Three Arrows Capital and Terraform Labs, led the Authority to tighten its approach further.

Hong Kong took a different course in 2023 when it introduced a licensing regime for virtual asset trading platforms, which allows licensed platforms to serve retail investors under strict conditions. It also presented itself as a hub for the crypto industry in Asia.² It has since adopted rules on stablecoin issuers and has approved exchange-traded funds on Bitcoin and ether. The author's fifteen years in Singapore and Hong Kong, including his work as external compliance officer of a fund management firm regulated by the Monetary Authority of Singapore, offer a basis for comparison. Both Asian centres combine an English-speaking legal environment with a regulator that engages closely with the industry while placing greater emphasis than Switzerland on the protection of retail investors. For Zug companies that wish to expand into Asia, a subsidiary in one of these centres is often the route of choice.

Notes

MAS, reply to parliamentary question on DPT service provider applicants, 26 July 2021, mas.gov.sg: about 170 DPT applications, around 30 withdrawn, 2 rejected, no licence yet issued; Morgan Lewis, "New Guidelines Discourage Cryptocurrency Trading by General Public in Singapore", January 2022, morganlewis.com: MAS guidelines of 17 January 2022 bar DPT service providers under the Payment Services Act from marketing in public areas and through influencers; Allen & Gledhill, 10 June 2025, allenandgledhill.com: FSMA 2022 Part 9 regime from 30 June 2025, under which MAS will generally not license DTSPs serving only customers outside Singapore. ↩
Davis Polk, "Hong Kong licensing regime for virtual asset trading platforms comes into force", 20 June 2023, davispolk.com: the licensing regime for virtual asset trading platforms came into force on 1 June 2023; licensed platforms may serve retail investors in eligible large-cap non-security tokens, subject to onboarding, custody and other investor-protection requirements; SFC, "Virtual asset trading platform operators", sfc.hk: licences under the AMLO and the SFO. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

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Singapore and Hong Kong

Notes

Setting up or expanding in Switzerland?