In the first half of 2024, Singapore’s cryptocurrency and blockchain sectors grew by 22%, reaching over US$200 million.
The MAS proposed a risk-based regulatory approach to enhance anti-money laundering and counter-financing of terrorism.
Singapore has consistently positioned itself as a forward-thinking jurisdiction, balancing innovation with robust regulatory oversight. As a fellow Singaporean, I am very proud of its future planning.
The Monetary Authority of Singapore (MAS) is seeking submissions for the Consultation Paper on the proposed regulatory approach for Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022.
Instead of replying to the submission directly, I will try to share my point of view openly here, offering insights, potential plans, and timelines for implementation. Before I start, I am sharing this in my personal capacity: I do not represent any self-claimed digital assets expert groups, associations, or schools.
License Application and Fee Structures
In the first half of 2024, Singapore’s fintech market saw its cryptocurrency and blockchain sectors achieve US$211.90 million across 72 deals, marking a 22% increase from US$166.30 million over 38 deals in the second half of 2023.
Singapore has been actively working on strengthening risk management frameworks for digital asset tokenization and has recently launched an initiative to expand asset tokenization within financial services.
The proposed license application processes and fee structures are crucial elements that will shape the DTSP landscape in Singapore. From my perspective, MAS should consider implementing a tiered approach to both timelines and fees, reflecting the diversity of DTSPs in terms of size, complexity, and risk profile.
For timelines, I propose a three-tier system:
Fast-track (60 days): For small, low-risk DTSPs with straightforward business models.
Standard (90 days): For medium-sized DTSPs or those with moderately complex operations.
Extended (120+ days): For large, complex DTSPs or those proposing novel business models.
This tiered approach would allow MAS to allocate resources efficiently while ensuring thorough vetting of more complex applications. The fee structures can follow a similar tiered system based on the DTSP’s annual revenue or transaction volume could be implemented.
Minimum Financial Requirements
The proposed minimum financial requirements are a critical safeguard against potential market disruptions and consumer losses. Based on my analysis, I believe a risk-based approach to setting these requirements is more feasible. This could involve:
Base Capital Requirement: A minimum base capital for all DTSPs, regardless of size or services offered.
Risk-Weighted Capital Requirement: Additional capital requirements based on the DTSP’s types of services offered, transaction volumes, and risk profile.
Liquidity Requirement: A minimum liquidity ratio to ensure DTSPs can meet short-term obligations.
Specifically, providers with capital ratios above 15% were 30% less likely to face operational disruptions during periods of extreme market stress. I propose that MAS consider setting the base capital requirement at SGD 250,000, with additional risk-weighted requirements that could increase this amount up to SGD 5 million for the largest and most complex DTSPs.
Audit Requirements
The proposed duties of CEOs, directors, and partners, along with audit requirements, are fundamental to ensuring good governance and accountability in the DTSP sector. The following enhancement is recommended for consideration:
Mandatory Training: Annual training programs for CEOs and directors on regulatory compliance, risk management, and emerging trends in digital assets.
Risk Committee: DTSPs above a certain size must establish a dedicated risk committee at the board level.
Independent Directors: Mandating a minimum number of independent directors based on the DTSP’s size and complexity.
Audit Frequency: Annual external audits for all DTSPs, with additional quarterly internal audits for larger providers.
Regulators are increasingly leveraging technological solutions to enhance their supervisory functions and manage vast amounts of data. Consequently, firms must engage more frequently with regulators regarding fintech and regtech developments.
Fintech companies that implement robust governance structures and conduct regular audits are indeed less likely to experience compliance breaches.
AML/CFT Measures
The measures proposed in parts 5–8 of the consultation paper, particularly those related to Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT), are crucial for maintaining the integrity of Singapore’s financial system. I propose the following enhancements:
Risk-Based Approach: Implement a tiered KYC/AML approach based on transaction volumes and risk profiles.
Technology Integration: Encourage the use of AI and machine learning for transaction monitoring and suspicious activity detection.
Regulatory Technology (RegTech) Sandbox: Establish a sandbox environment for DTSPs to test innovative compliance solutions.
For existing customers onboarded prior to licensing, I suggest a phased approach:
Phase 1 (0–6 months): Risk assessment of existing customer base
Phase 2 (6–12 months): Enhanced due diligence for high-risk customers
Phase 3 (12–18 months): Full compliance with new requirements for all customers
Correspondent Account Services
The proposed requirements for Correspondent Account Services and information sharing for law enforcement purposes are essential components of a comprehensive regulatory framework. Perhaps the following would help:
Standardized Data Format: Develop a standardized data format for information sharing across the industry.
Blockchain Analytics: Encourage the use of blockchain analytics tools to enhance transaction traceability.
Secure Information Sharing Platform: Establish a secure, centralized platform for information sharing between DTSPs and law enforcement agencies.
Blockchain analytics tools have been instrumental in recovering stolen or illicitly obtained digital assets worldwide. They allow law enforcement agencies to trace and identify suspicious cryptocurrency transactions on the blockchain, leading to asset recovery efforts.
Technology Risk Management
The draft notices FSM-N28 to FSM-N33 cover critical aspects of DTSP operations, including technology risk management, cyber hygiene, and conduct. Based on my observations, I propose the following:
Continuous Monitoring: Implement real-time monitoring systems for cyber threats and operational risks.
Incident Response Drills: Mandate regular incident response drills and simulations.
Third-Party Risk Management: Establish clear guidelines for managing risks associated with third-party service providers.
Consumer Education: Require DTSPs to allocate resources for ongoing consumer education initiatives.
Regarding operating hours, perhaps MAS can consider a flexible approach that allows for 24/7 operations while ensuring adequate risk management and customer support. This could involve:
Core operating hours (e.g., 9 AM to 5 PM SGT) with full support services
Extended hours with automated systems and on-call support
Scheduled maintenance windows during low-volume periods
Timeline for Implementation:
To ensure a smooth transition to the new regulatory framework, I propose the following timeline:
Month 0–3: Publication of final regulations and guidelines
Month 3–6: Industry consultation and feedback period
Month 6–9: Finalization of technical specifications and reporting formats
Month 9–12: DTSP preparation and system upgrades
Month 12–18: Phased implementation of new requirements
Month 18–24: Full compliance deadline for all DTSPs
This timeline allows for a gradual implementation, giving DTSPs sufficient time to adapt their systems and processes while ensuring that the regulatory framework is fully operational within two years.
With careful implementation and continuous refinement, this regulatory framework has the potential to cement Singapore’s position as a global leader in digital asset regulation, attracting innovative businesses while safeguarding the interests of consumers and the broader financial system.
Anndy Lian is an early blockchain adopter and experienced serial entrepreneur who is known for his work in the government sector. He is a best selling book author- “NFT: From Zero to Hero” and “Blockchain Revolution 2030”.
Currently, he is appointed as the Chief Digital Advisor at Mongolia Productivity Organization, championing national digitization. Prior to his current appointments, he was the Chairman of BigONE Exchange, a global top 30 ranked crypto spot exchange and was also the Advisory Board Member for Hyundai DAC, the blockchain arm of South Korea’s largest car manufacturer Hyundai Motor Group. Lian played a pivotal role as the Blockchain Advisor for Asian Productivity Organisation (APO), an intergovernmental organization committed to improving productivity in the Asia-Pacific region.
An avid supporter of incubating start-ups, Anndy has also been a private investor for the past eight years. With a growth investment mindset, Anndy strategically demonstrates this in the companies he chooses to be involved with. He believes that what he is doing through blockchain technology currently will revolutionise and redefine traditional businesses. He also believes that the blockchain industry has to be “redecentralised”.
The fifth Decentralized Confidential Computing (DeCC) Day was held at Token2049 Singapore. Strongly supported by SquidGrow, SilentSwap, Arcium, COTI, Partisia, TEN Protocol, and Novapolis, along with media partners from BlockLeaders, The Coin Republic, and Blockcast. The DeCC Day attracted large crowds and many interesting questions.
Lisa Loud, executive director of Secret Network Foundation, opened the day and spoke of two key conversations that were directly relevant to DeCC Day.
The first was a gathering at EthDenver in February where the DeCC Alliance first met, and first put together an overview and informal alliance of companies dedicated to promoting and delivering confidential computing. It is really important to note that the almost 30 companies under this umbrella use different technologies, and some are even directly competitive, but all have as a common goal confidential computing.
The second conversation germane to the DeCC Day was Lisa’s meetings with SEC Commissioner Hester Pierce. Lisa remarked to Hester that she really deserved the term CryptoMom for her hard work on behalf of crypto.
However, Hester replied she wasn’t a champion of crypto, she was a champion of people making their own decisions.
And to paraphrase the last line from Robert Frost’s poem ‘The Road not Taken’ that has made all the difference.
The DeCC Day carried on in style. The Silent Swap team were there in force and made a big announcement that their Beta was open. Supdoggie from the team gave a highly technical look at how SilentSwap is using TEE and FHE in its architecture.
Sodalabs, represented by Avishay Yanai, gave a talk on the tech behind Garbled Circuits, yet another technology added to the Alliance which already includes TEE, MPC, ZK and FHE.
The first panel, on the Importance of DePIN, was moderated by Crypto Megan. Her guests were Amar Bedi of Tashi, Alex Zaidelson of SCRT Labs and Anil Murty of Akash. The triple A guests were united in their comment that OpenAI is very closed – and that is why we need DePIN to democratize access to GPUs.
The Building Web3 Responsibly panel was moderated by Varuni Trivedi, editor of The Coin Republic and included LC of IBL Law, Joshua Maddox of COTI, Bruce Ahn of Partisia, and Zheng Leong Chua of Automata Network. Echoing shades of Games of Thrones, LC said ‘regulation is coming.’ Bruce said ‘Devs understand the rules.’ Zheng said ‘we love compliance,’ and Joshua said ‘we need to get dirty.’
Zoe McFox of Phala Network moderated the Power of DeCC panel. During this conversation, it was pointed out that in the military, there are armed guards securing databases with guns, and that we needed to find equally secure tech solutions. She was joined by Supdoggie, Yannick Schrade of Arcium and Kabal.
Finally, Anndy Lian, Governmental Blockchain Advisor, led the panel looking at commercial use cases. He was joined by Josh Wyant of Novapolis, Gavin Thomas of TEN, Cal of SquidGrow and Juan Mari of Blok Assets. During this panel it was observed that Vitalik’s lack of privacy is well documented with people tracking him through his publicly acknowledged wallets. But it’s the same for ordinary people who need protection also.
Throughout the presentations and discussions, the audience was engaged and every opportunity for questions to be asked was filled with participation and insightful answers.
The event ended with a powerful round of networking where relationships were built that will live on and keep the value of the event going for years to come.
Anndy Lian is an early blockchain adopter and experienced serial entrepreneur who is known for his work in the government sector. He is a best selling book author- “NFT: From Zero to Hero” and “Blockchain Revolution 2030”.
Currently, he is appointed as the Chief Digital Advisor at Mongolia Productivity Organization, championing national digitization. Prior to his current appointments, he was the Chairman of BigONE Exchange, a global top 30 ranked crypto spot exchange and was also the Advisory Board Member for Hyundai DAC, the blockchain arm of South Korea’s largest car manufacturer Hyundai Motor Group. Lian played a pivotal role as the Blockchain Advisor for Asian Productivity Organisation (APO), an intergovernmental organization committed to improving productivity in the Asia-Pacific region.
An avid supporter of incubating start-ups, Anndy has also been a private investor for the past eight years. With a growth investment mindset, Anndy strategically demonstrates this in the companies he chooses to be involved with. He believes that what he is doing through blockchain technology currently will revolutionise and redefine traditional businesses. He also believes that the blockchain industry has to be “redecentralised”.
During the Token 2049 week in Singapore, the DeCC event hosted a panel discussion titled “Use Cases with Commercial Applications.” Moderated by Anndy Lian, a book author and governmental blockchain advisor, the panel featured prominent figures in the blockchain industry: Gavin Thomas, Co-Founder of TEN Protocol; Josh Wyant, Founder of Novapolis; Cal, Lead Developer at SquidGrow and SilentSwap; and Juan Mari, CEO of Blok Assets. The discussion delved into the practical applications of blockchain technology, focusing on privacy, regulatory challenges, and the potential for blockchain to revolutionize various industries.
The panel began with introductions, setting the stage for a deep dive into the commercial applications of blockchain. Juan Mari introduced Blok Assets, a firm based in Puerto Rico that builds legal structures within the SEC and FCA frameworks to tokenize assets. Gavin Thomas highlighted TEN Protocol’s work on an encrypted layer 2 for Ethereum, while Josh Wyant described Novapolis as a decentralized cloud platform with a community-centric approach. Cal, representing SilentSwap, explained their focus on privacy swaps powered by the Secret Network, enabling asset exchanges across multiple EVM chains.
The discussion quickly turned to privacy, a critical aspect of blockchain technology. The panelists shared various case studies illustrating the importance of privacy in commercial applications. Gavin Thomas cited the Italian banking system’s use of an enterprise-grade blockchain, which incorporates privacy into its design. He emphasized the potential benefits of moving to public blockchains with confidential computing, which could reduce vendor lock-in and foster competition, ultimately benefiting consumers.
Cal shared insights from SilentSwap’s journey, initially targeting consumer users but later attracting business clients who also required privacy. He highlighted the need for privacy in business transactions, where competitors should not have access to each other’s financial details. This need for privacy extends to various scenarios, such as venture capitalists being copy-traded or competitive traders being front-run by rivals. SilentSwap is now developing a business-to-business SDK to address these privacy concerns.
Juan Mari pointed out the lack of protocols for transfer agents in the tokenization of real-world assets. He stressed the need for a transfer agent with robust data privacy layers, especially when dealing with regulatory bodies like the SEC and FCA. The absence of such a solution presents a significant opportunity for innovation in the blockchain space.
The conversation then shifted to the role of confidential computing in governance and regulatory compliance. The panelists discussed how confidential computing could enable secure voting and other governance applications while maintaining privacy. They acknowledged the challenges governments face in balancing privacy with regulatory requirements, such as anti-money laundering (AML) and know-your-customer (KYC) processes. The panelists emphasized the importance of educating regulators about the benefits of blockchain technology and the potential for confidential computing to enhance security and privacy.
Anndy Lian raised the issue of privacy in the context of meme projects, questioning its importance in such communities. The panelists agreed that privacy remains crucial, even in meme projects, as it allows developers and traders to maintain anonymity and protect their identities. They shared anecdotes of individuals who have faced challenges due to a lack of privacy, underscoring the need for solutions that enable users to control their data and identities.
The panel also addressed the challenges of promoting and educating users about blockchain technology. They noted that many blockchain projects struggle to communicate their value propositions effectively, often using complex terminology that alienates potential users. The panelists suggested simplifying the user experience and abstracting away the complexity of blockchain to drive adoption. They emphasized the need for a “killer app” that showcases the benefits of blockchain without requiring users to understand the underlying technology.
In discussing the future of blockchain, the panelists expressed optimism about its potential to transform industries such as trade finance. They highlighted the inefficiencies in traditional trade finance processes, which involve extensive paperwork and reliance on third parties. Blockchain technology, with its ability to facilitate secure and transparent transactions, could streamline these processes and reduce friction. The panelists envisioned a future where blockchain underpins global trade finance, enabling more efficient and secure transactions.
The panel concluded with a discussion on emerging use cases for decentralized applications (dApps) that offer significant value for commercial adoption. They identified trade finance, real-world asset tokenization, and privacy-preserving advertising as areas ripe for innovation. The panelists also highlighted the potential for confidential computing to extend beyond web 3.0, enabling web 2.0 applications to incorporate privacy-preserving features.
Overall, the panel discussion at DeCC provided valuable insights into the commercial applications of blockchain technology. The panelists highlighted the importance of privacy, the challenges of regulatory compliance, and the potential for blockchain to revolutionize industries. As blockchain technology continues to evolve, it holds the promise of transforming how businesses operate, offering new opportunities for innovation and growth.
Anndy Lian is an early blockchain adopter and experienced serial entrepreneur who is known for his work in the government sector. He is a best selling book author- “NFT: From Zero to Hero” and “Blockchain Revolution 2030”.
Currently, he is appointed as the Chief Digital Advisor at Mongolia Productivity Organization, championing national digitization. Prior to his current appointments, he was the Chairman of BigONE Exchange, a global top 30 ranked crypto spot exchange and was also the Advisory Board Member for Hyundai DAC, the blockchain arm of South Korea’s largest car manufacturer Hyundai Motor Group. Lian played a pivotal role as the Blockchain Advisor for Asian Productivity Organisation (APO), an intergovernmental organization committed to improving productivity in the Asia-Pacific region.
An avid supporter of incubating start-ups, Anndy has also been a private investor for the past eight years. With a growth investment mindset, Anndy strategically demonstrates this in the companies he chooses to be involved with. He believes that what he is doing through blockchain technology currently will revolutionise and redefine traditional businesses. He also believes that the blockchain industry has to be “redecentralised”.
