Leon Yee – Duane Morris and Selvam

June 16, 2025June 16, 2025 by Duane Morris and Selvam

MAS Issues Clarification on the Regulatory Regime for Digital Token Service Providers under the Financial Services and Markets Act 2022

On 30 May 2025, the Monetary Authority of Singapore (“MAS”) published its response to feedback on the proposed regulatory approach, regulations, and notices for digital token service providers (“DTSPs”) under the Financial Services and Markets Act 2022 (“FSM Act”). This article provides a summary of the key features of the new regime, MAS’s clarifications, and practical implications for affected entities.

Scope of the DTSP Regime
The DTSP regime applies to individuals, partnerships, or Singapore-incorporated entities that carry on a business of providing digital token (“DT”) services outside Singapore. The regulatory focus is on mitigating money laundering and terrorism financing (“ML/TF”) risks, as well as reputational risks to Singapore, given the cross-border and internet-based nature of such services.

October 18, 2024November 27, 2024 by Duane Morris and Selvam

Redefining Boundaries: MAS Consults on New Regulatory Framework for Digital Token Service Providers under the FSMA

By Leon Yee and Sally Kim

On 4 October 2024, the Monetary Authority of Singapore (“MAS”) has published a consultation paper detailing the regulatory framework for Digital Token Service Providers (“DTSPs”) under the Financial Services and Markets Act 2022 (“FSM Act”). This framework addresses the licensing, anti-money laundering, countering the financing of terrorism (“AML/CFT”) requirements, and technological risk management for DTSPs, particularly those based in Singapore but offering services abroad.[1] To effect the objectives of Part 9 of the FSM Act, the MAS intends to prescribe or issue the following instruments: (a) the Financial Services and Markets Regulations (“FSM Regulations”); (b) AML/CFT notices under the FSMA; (c) other notices under the FSMA; and (d) guidelines.

February 21, 2024February 21, 2024 by Leon Yee

Mainstream Adoption: The Era of Bitcoin ETFs Begins

By Leon Yee, Yeo Ming Ze and Brian Sim

1. Navigating the Bitcoin Exchange-Traded Funds (“ETFs”) Landscape: A Comprehensive Overview

Introduction to Bitcoin ETFs in 2024
On 10 January 2024, the U.S. Securities and Exchange Commission (“SEC”) approved the listing and trading of 11 spot Bitcoin ETFs. This followed a case in the U.S. Court of Appeals District of Columbia where the court held that the SEC’s denial of Grayscale Investments conversion of its Bitcoin trust to an ETF was “arbitrary” and “capricious” given that the SEC had approved a futures-based Bitcoin product. The court found these futures-based ETFs to be materially similar to Grayscale’s Bitcoin ETF such that they should have received the same regulatory treatment. The court’s decision was based on two key points: the underlying assets (Bitcoin futures and Bitcoins) being closely related in that they both track spot Bitcoin market prices and the futures and Bitcoin exchanges having the similar controls in place for detecting fraudulent or manipulative market misconduct.
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July 12, 2023July 13, 2023 by Duane Morris and Selvam

Updates to the Application Criteria for Family Offices under the S13O and S13U Tax Incentive Schemes

By Leon Yee and Jennifer Lo

In recent years, Singapore has attracted large inflows of wealth to be managed here, establishing its status as a leading wealth management hub in the region. This is largely thanks to the rule of law, economic and political stability, welcoming investment climate and business-friendly environment in Singapore, which have all played a pivotal role in attracting high net-worth individuals to invest in Singapore.

According to the Global Family Office Compensation Benchmark Report recently published by KPMG Private Enterprise and family office consultancy Agreus, it is estimated that 59% of the family offices in Asia are located in Singapore. The number of single family offices (“SFOs”) in Singapore has leapt from 700 in 2021 to 1,100 as of the end of 2022. Continue reading “Updates to the Application Criteria for Family Offices under the S13O and S13U Tax Incentive Schemes”

July 12, 2023July 12, 2023 by Duane Morris and Selvam

Monetary Authority of Singapore’s Proposed Measures to Regulate DPTSPs and Enhance Customer Protection

I. Introduction

The Monetary Authority of Singapore (“MAS”) published the “Response to Feedback Received on Proposed Regulatory Measures for Digital Payment Token Services (Part 1)” (“MAS’ Response to the October 2022 Consultation Paper”) on 3 July 2023, announcing new measures for Digital Payment Token service providers (“DPTSPs”) with regards to the safekeeping of customers’ digital assets. The lack of protection and segregation of customer deposits appear to be the chief concern that MAS intends to tackle with their new slate of measures. It is hoped that with the stricter rules in place, it will reduce the risk of loss or misuse of customers’ assets by DPTSPs and facilitate customer’s fund recovery in the event of a DPTSP’s insolvency. This proactive approach demonstrates Singapore’s commitment to creating a more secure environment – taking lessons from the past experiences of renowned crypto exchanges like Voyager and Celsius. These developments lay the foundation for a resilient and trusted crypto space in Singapore. Continue reading “Monetary Authority of Singapore’s Proposed Measures to Regulate DPTSPs and Enhance Customer Protection”

March 3, 2023April 25, 2023 by Duane Morris and Selvam

解读新加坡更新版全球投资者计划（GIP）

新加坡的全球投资者计划（以下简称“GIP”）是由新加坡经济发展局（以下简称“EDB”）推出的一项永久居留权计划，旨在鼓励高净值个人和企业家在新加坡进行投资。该计划为有愿意投资大量资金的合格申请人提供了获得新加坡永久居留权的快速路径。

在EDB最近的一份公告中，该计划将在今年3月发生一些变化。此次调整是为了更好地筛选并吸引有能力为新加坡带来重大经济影响的投资者，同时使他们在新加坡扎根。希望高净值外国投资能更积极地参与到新加坡的经济活动中，共同推动当地的经济增长。

Continue reading “解读新加坡更新版全球投资者计划（GIP）”

March 2, 2023April 25, 2023 by Duane Morris and Selvam

New and Enhanced Global Investor Programme in Singapore

The Global Investor Programme (“GIP”) is a permanent residency scheme that was launched by the Economic Development Board (“EDB”) in Singapore to encourage high-net-worth individuals and entrepreneurs to invest in the country. The scheme provides a fast track to permanent residency for eligible applicants who are willing to invest a significant amount of money.

Continue reading “New and Enhanced Global Investor Programme in Singapore”

January 19, 2023July 12, 2023 by Duane Morris and Selvam

SGX RegCo Updates – Enhancements to Disclosures on Directors’ Remuneration and Cap on Independent Directors’ Tenure

By Leon Yee and Jennifer Lo

On 11 January 2023, the Singapore Exchange Regulation (“SGX RegCo”) announced the requirement to disclose remuneration details of directors and chief executive officers (“CEOs”) and the imposition of a limit on the tenure of independent directors (“IDs”).

Continue reading “SGX RegCo Updates – Enhancements to Disclosures on Directors’ Remuneration and Cap on Independent Directors’ Tenure”

August 10, 2022August 17, 2022 by Duane Morris and Selvam

了解新加坡NFT消费者保护

非同质化代币（NFT）是区块链上的加密代币，其可以证明数字资产的所有权和真实性，也可以被看作是有所有权证的数字数据。NFT是不可替代的，因为没有相同的两个NFT，每个NFT都有唯一的识别号和元数据。

作为买卖数字艺术品的一种模式，NFT正变得越来越流行，其允许艺术家将其真实的数字艺术品货币化，否则这些数字艺术品很容易被复制。至关重要的是，NFT可以与数字艺术品和实物艺术品一起证明出处。此外，某些NFT可能涉及卖方向买方提供通行证，该通行证允许NFT持有人获得独家商品或服务，包括活动、订阅、内容或限量版产品。 Continue reading “了解新加坡NFT消费者保护”

August 1, 2022August 1, 2022 by Duane Morris and Selvam

Understanding Consumer Protections for NFTs in Singapore

Non-fungible tokens (NFTs) are cryptographic tokens on a blockchain that can prove the ownership and authenticity of a digital asset, which can also be considered as digital data with a certificate of ownership. NFTs are non-fungible because no two NFTs are the same and each has a unique identification code and metadata.

NFTs are becoming increasingly popular as a mode to buy and sell digital artworks, permitting artists to monetise their authentic digital artwork, which could otherwise easily be copied. Crucially, NFTs can be used with both digital and physical artwork for establishing provenance. In addition, certain NFTs may involve the seller providing the buyer with an access pass, which allows NFT holders access to exclusive goods or services, including events, subscriptions, content, or limited-edition products.

Continue reading “Understanding Consumer Protections for NFTs in Singapore”