How Do You Switch Corporate Service Providers in Singapore?
Dawn Lee
Singapore is one of the most trusted business hubs in the world, with more than 626,000 registered business entities and over 70,000 new companies incorporated…
Digital Asset Regulation in Singapore (2026): Security & Cross-Border Disputes
In Singapore, digital assets are regulated mainly by the Monetary Authority of Singapore (MAS) under the Payment Services Act 2019, with crypto exchange and transfer services treated as “digital payment token” (DPT) services and held to anti-money-laundering, custody and consumer-protection rules. A separate Digital Token Service Provider (DTSP) licensing regime under the Financial Services and Markets Act 2022 took effect on 30 June 2025 for Singapore-based firms serving only overseas customers, a licence MAS says it will rarely grant. Singapore courts already recognise cryptocurrency and NFTs as property capable of being held on trust, so where assets are stolen the High Court can grant proprietary and worldwide freezing (Mareva) injunctions, plus disclosure orders against exchanges. When a dispute crosses borders, recovery is legally possible but practically difficult, depending on tracing the assets and enforcing orders in the jurisdiction where they sit.
Table Of Content
Key moments
| 0:00 | Introduction |
| 3:10 | Singapore regulatory framework |
| 7:30 | Structuring a crypto business |
| 14:00 | Cross-border & crypto as property |
| 21:00 | Security risks & scams |
| 27:30 | Anatomy of an attack |
| 34:00 | Freezing & recovering assets |
| 48:00 | Custody, insurance & risk |
| 1:00:00 | Asset recovery routes |
| 1:06:00 | Practical takeaways |
Singapore's regulatory framework for digital assets
Singapore does not have a single “crypto law”. Instead, the regulatory treatment of a digital asset depends on what the asset does and what activity is carried on with it. The principal regulator is the Monetary Authority of Singapore (MAS), and the most common entry point is the Payment Services Act 2019 (PS Act), which regulates “digital payment token” (DPT) services such as dealing in, or facilitating the exchange of, cryptocurrencies. Firms providing these services must be licensed and comply with anti-money-laundering and countering-the-financing-of-terrorism (AML/CFT) obligations.
The framework has been tightened materially. On 2 April 2024 MAS amended the PS Act to expand the scope of regulated payment services and to impose new user-protection and financial-stability requirements on DPT service providers, with the changes taking effect in stages. Among other things, providers must segregate customers’ assets and hold them on trust, with those safeguarding requirements taking effect six months from 4 April 2024 (MAS, 2024).
MAS has also been deliberately restrictive towards retail speculation. Under its guidelines, DPT service providers should not promote their services to the general public in Singapore, should not offer incentives to trade, must not provide financing, margin or leverage to retail customers, cannot accept locally issued credit-card payments for crypto, and are restricted from facilitating lending or staking of tokens by retail customers (institutional and accredited investors are treated differently). These consumer-protection measures took effect on 4 October 2024 (MAS, 2023).
1. Stablecoins
On 15 August 2023 MAS finalised a regulatory framework for single-currency stablecoins (SCS). It applies to SCS pegged to the Singapore Dollar or a G10 currency and issued in Singapore. Issuers must meet requirements on reserve-asset composition and valuation, redemption at par, capital and disclosure; only those that satisfy the full framework may apply to label their tokens as “MAS-regulated stablecoins” (MAS, 2023).
2. The DTSP regime (Financial Services and Markets Act 2022)
A distinct regime targets a narrower gap. From 30 June 2025, businesses or individuals operating from a place of business in Singapore, or incorporated in Singapore, that provide digital token services solely to customers outside Singapore must be licensed as Digital Token Service Providers (DTSPs) under Part 9 of the Financial Services and Markets Act 2022. MAS has set the bar high and has stated it will generally not issue such a licence, because the money-laundering risk is elevated and it cannot effectively supervise activity carried on wholly overseas (MAS, 2025). Firms already serving customers in Singapore remain regulated under the PS Act, Securities and Futures Act 2001, or Financial Advisers Act 2001, as applicable.
Structuring a crypto business in Singapore
The first question for any digital-asset venture is licence classification, because it drives everything else. The VIVOS panel emphasised mapping the proposed activity to the correct regime before incorporation: a token-exchange or transfer service typically falls under the PS Act as a DPT service; dealing in tokens that are capital-markets products engages the Securities and Futures Act; and a Singapore entity that serves only overseas users may fall into the DTSP net under the FSMA.
A common structuring trap is assuming that serving only foreign customers avoids Singapore regulation. The opposite can be true: that exact model is what the DTSP regime now captures, and MAS has signalled it will rarely license it. Founders should therefore decide early whether their customer base will include Singapore, and design substance, governance and AML/CFT controls to match the regime that applies. Capital is also a live consideration; MAS sets out base-capital requirements that an applicant must meet and maintain.
Because the regulatory perimeter shifts with the business model, structuring is best treated as a legal and tax exercise from day one rather than a compliance afterthought. VIVOS works with founders on entity selection, licensing strategy and the tax treatment of token issuance and trading.
Is crypto "property"? Cross-border disputes
Yes, under Singapore law, cryptocurrency and NFTs are recognised as property. In ByBit Fintech Ltd v Ho Kai Xin and others [2023] SGHC 199, the High Court held that crypto assets are property capable of being held on trust and are choses in action, applying the classic four-part test from National Provincial Bank v Ainsworth (the asset must be definable, identifiable by third parties, capable of assumption, and have some permanence). This built on earlier rulings: in CLM v CLN and others [2022] SGHC 46 the court treated stolen cryptocurrency as property capable of being the subject of a proprietary injunction, and in Janesh s/o Rajkumar v Unknown Person (“CHEFPIERRE”) [2022] SGHC 264 it recognised an NFT as property and granted a proprietary injunction over a Bored Ape Yacht Club token.
The property characterisation matters enormously for victims of theft and fraud, because it unlocks proprietary remedies and tracing. Later decisions have continued to refine the practicalities: courts have addressed how to value notoriously volatile crypto holdings and how jurisdiction is established in cross-border claims.
Cross-border friction is the recurring theme. A Singapore court can recognise your stolen tokens as property and freeze them, but the wallet, the exchange or the wrongdoer may sit in another country. Enforcement then turns on tracing the assets on-chain, identifying the holder, and obtaining recognition or co-operation in the relevant foreign jurisdiction, which is where many recoveries succeed or stall.
Security risks and scams
Most digital-asset losses are not failures of the blockchain itself but of the people and platforms around it. The VIVOS panel framed the dominant risk categories at a deliberately general, educational level: social-engineering and phishing that trick a holder into revealing access; compromise of private keys or recovery phrases; and counterparty failure, where an exchange or custodian becomes insolvent or is itself compromised. Investment “scams”, fake platforms, romance-investment fraud, and impersonation remain a large share of reported losses.
The scale is significant. According to the Singapore Police Force, victims lost about S$182 million to scams involving cryptocurrency in 2025, roughly a fifth of all scam losses that year, while a dedicated Crypto Tracing Team, operational since March 2025, has helped recover over S$20 million in virtual assets (Singapore Police Force). The practical lesson for businesses and individuals is that prevention, sound key management, verified counterparties and scepticism towards “guaranteed” returns are far cheaper than recovery.
1. Anatomy of an attack (in outline)
Without giving any operational detail, the typical pattern the panel described is: an attacker first obtains access (often through deception rather than code), then moves assets quickly through a chain of wallets and across services to frustrate tracing, before attempting to cash out via an off-ramp. Because on-chain movement is fast and irreversible, the window to act is short, which is precisely why the freezing tools below are time-critical.
Freezing and recovering assets
Singapore’s courts have a well-developed toolkit for preserving and recovering misappropriated digital assets, and crucially they can deploy it even where the wrongdoer is anonymous. In CLM v CLN the High Court granted Singapore’s first worldwide freezing (Mareva) injunction against “persons unknown” in a crypto-theft case, together with a proprietary injunction and disclosure orders against exchanges. The main tools are summarised below.
| Tool | What it does |
|---|---|
| Proprietary injunction | Preserves specific assets that the claimant asserts belong to them, preventing dealing or dissipation pending trial. |
| Worldwide freezing (Mareva) injunction | Restrains a defendant from dissipating assets, potentially on a worldwide basis, to keep them available to satisfy a judgment. |
| Bankers Trust / disclosure orders | Compel third parties such as exchanges to disclose account and transaction information to help identify wrongdoers and trace funds. |
| Service out of jurisdiction | Permits a claim and orders to be served on defendants located abroad where the case meets the jurisdictional gateways. |
| Service by alternative means | Allows service through non-traditional channels – in CHEFPIERRE, the court permitted service via the defendant’s social-media account and crypto wallet. |
Speed is everything. Because on-chain transfers are near-instant and irreversible, victims should seek injunctive relief and disclosure orders as early as possible, ideally before the assets are moved through mixing services or off-ramped into fiat.
Custody, insurance and risk
For businesses holding client crypto, custody is now a regulated discipline, not a technical detail. Following the 2024 PS Act amendments, DPT service providers must segregate customers’ assets, hold them on trust, keep proper records and maintain systems to protect the integrity and security of those assets. The policy aim – sharpened by the failures of the 2022 “crypto winter” is to keep customer assets identifiable and ring-fenced from a provider’s own balance sheet, so they can be returned if the provider fails.
Custody choices (self-custody, qualified third-party custodian, or a mix), key-management architecture and insurance cover should be assessed together as part of an operational-risk framework. Insurance for digital-asset custody exists but is specialised, and cover for theft or key loss should be read carefully against its exclusions. The panel’s general guidance was to treat custody, governance and insurance as a single risk question rather than three separate procurement decisions.
Asset recovery routes
When assets are lost, recovery usually runs along two complementary tracks. The civil route uses the proprietary and freezing injunctions and disclosure orders described above to preserve assets, identify holders, and ultimately obtain judgment and enforcement.
The criminal/regulatory route involves reporting to the police and relevant authorities, who can investigate, work with overseas counterparts and, increasingly, trace assets on-chain in Singapore, through a dedicated crypto-tracing capability that has recovered virtual assets in practice.
The realistic assessment the panel offered: recovery is possible and Singapore’s legal tools are among the most developed in the region, but outcomes depend on speed, the quality of on-chain tracing, whether the assets reach a co-operative exchange or jurisdiction, and the cost of cross-border enforcement. Some value is recovered; full recovery is far from guaranteed. Early, coordinated legal action materially improves the odds.
Key takeaways
- Activity-based regulation. Singapore regulates what a digital asset does; crypto exchange and transfer services fall under the Payment Services Act as DPT services and must be licensed.
- New DTSP regime since 30 June 2025. Singapore firms serving only overseas customers must be DTSP-licensed under the FSMA 2022 – a licence MAS says it will rarely grant.
- Crypto and NFTs are property. ByBit v Ho Kai Xin, CLM v CLN and the CHEFPIERRE NFT case confirm digital assets can be held on trust and protected by proprietary remedies.
- Courts can freeze stolen crypto. Proprietary and worldwide Mareva injunctions, plus disclosure orders against exchanges, are available – even against “persons unknown”.
- Cross-border recovery is possible but hard. Success depends on speed, tracing, and enforcement where the assets actually sit.
- Custody is regulated. DPT providers must segregate and hold customer assets on trust; treat custody, governance, and insurance as one risk question.
Protect and Recover Digital Assets
Planning a digital-asset venture, weighing a licensing strategy, or dealing with a cross-border dispute? VIVOS advises founders and businesses on structuring, licensing and risk. Speak with our corporate advisory team, or explore how token issuance and trading are handled under our taxation services.
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Frequently
Asked Questions
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Is cryptocurrency legal in Singapore?
Yes. Cryptocurrency is legal to own and trade in Singapore, but the businesses that provide crypto services are regulated. Exchange and transfer services are “digital payment token” services under the Payment Services Act 2019 and must be licensed by MAS and comply with anti-money-laundering rules. MAS actively discourages retail speculation through marketing and product restrictions.
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Is cryptocurrency property under Singapore law?
Yes. In ByBit Fintech Ltd v Ho Kai Xin [2023] SGHC 199 the High Court held that crypto assets are property capable of being held on trust and are choses in action. Earlier cases (CLM v CLN [2022] SGHC 46 and the CHEFPIERRE NFT case [2022] SGHC 264) reached consistent conclusions for cryptocurrency and NFTs respectively. This means stolen digital assets can attract proprietary remedies.
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Do I need a MAS licence to run a crypto business in Singapore?
Usually, yes. Providing digital payment token services, such as dealing in or facilitating the exchange of cryptocurrencies, requires a licence under the Payment Services Act 2019. Separately, a Singapore-based firm that serves only overseas customers needs a Digital Token Service Provider licence under the FSMA 2022, which MAS has indicated it will rarely grant. The right classification depends on your activity and customer base.
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Can Singapore courts freeze stolen crypto?
Yes. The Singapore High Court can grant proprietary injunctions to preserve specific assets and worldwide freezing (Mareva) injunctions to stop dissipation, alongside disclosure orders compelling exchanges to reveal account information. In CLM v CLN the court granted such relief even against unidentified “persons unknown”. Because on-chain transfers are fast and irreversible, applying early is critical.
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Can stolen crypto be recovered across borders?
It is possible but not guaranteed. Singapore’s courts have strong tools and can permit service abroad and by alternative means such as via a defendant’s wallet or social media. Actual recovery depends on tracing the assets on-chain, identifying who holds them, and securing enforcement or co-operation in the jurisdiction where the assets sit. Speed and coordinated legal action significantly improve the chances.
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How are stablecoins regulated in Singapore?
MAS finalised a framework for single-currency stablecoins on 15 August 2023. It applies to stablecoins pegged to the Singapore Dollar or a G10 currency and issued in Singapore, and sets requirements on reserve backing, valuation, redemption at par, capital and disclosure. Only issuers that meet the full framework may label their tokens as “MAS-regulated stablecoins”.
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Are retail investors restricted from trading crypto in Singapore?
Retail access is not banned, but it is constrained. MAS guidelines say DPT providers should not promote services to the public, must not offer trading incentives, cannot provide financing, margin or leverage to retail customers, cannot accept locally issued credit cards for crypto, and are restricted from offering lending or staking of tokens to retail customers. These measures took effect from October 2024.
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