Prying
Singapore's Crypto Industry: The Cost of Getting In
How it got this way
Singapore's edge was never crypto-specific. It began as spillover from decades as Asia's private-banking hub, then ran through a permissive ICO era, a strict licensing gate, an influx of firms leaving China in 2021, and the 2022 crashes. The pivot to institutions began before those crashes.
Mar 2014 MAS's first position on virtual currencies MAS says it will regulate virtual currency intermediaries for money-laundering risk, nothing else. Early era
MAS Deputy Managing Director Ong Chong Tee announced a targeted rule addressing money-laundering and terrorism-financing risk at virtual currency intermediaries, explicit that this "does not extend to the safety and soundness of virtual currency intermediaries nor the proper functioning of virtual currency transactions." Singapore's pull for early crypto activity came from decades of prior positioning as Asia's private-banking hub, not from this statement, or any crypto-specific policy: institutional credibility plus regulatory white space, together.
Nov 2017 MAS's Guide to Digital Token Offerings A token is only a security if it confers equity, debt, or fund-unit rights. Pure utility tokens sit outside securities law entirely. Regulatory gate
Teams structured tokenomics specifically to stay on the utility side of that line. Singapore ranked third globally as an ICO hub in 2017, and Zilliqa and Kyber Network both grew out of NUS computer-science research from the same era.
MAS Guide to Digital Token Offerings (current 26 May 2020 revision of the Nov 2017 guide) DealStreetAsia, on Singapore as the third-largest ICO hub NUS, on its spin-offs
Jan 2019 Payment Services Act passed Digital payment token services get folded into a general payments law that makes crypto dealing and exchange providers meet anti-money-laundering and counter-terrorism-financing requirements. Regulatory gate
The Act converts MAS's 2014-17 posture (regulate AML risk at intermediaries, disclaim the asset, otherwise stay out) into an actual licensing gate a firm needs to legally operate. It comes into force a year later, on 28 January 2020.
Jan 2020 PS Act in force, DPT licensing opens Digital payment token providers now need an MAS licence to operate in Singapore. Regulatory gate
The stringency showed early. By July 2021, around 170 applicants had sought DPT licences and MAS had issued none: 30 had withdrawn and two were rejected. Six were licensed by August 2022. Binance's Singapore affiliate withdrew its application that December. As of 2026, 37 of close to 300 applicants have been licensed.
MAS parliamentary reply, 26 Jul 2021 MAS parliamentary reply, 1 Aug 2022 MAS parliamentary reply, 5 Aug 2026
Sep 2021 China bans crypto, firms relocate to Singapore The PBOC and nine other regulators declare all crypto transactions illegal, sharper than China's 2017 ICO ban. Huobi, then China's largest exchange, makes Singapore its regional headquarters. Outside push
Huobi Group picked Singapore as its regional headquarters in November 2021, and a separate Huobi Singapore entity was seeking an MAS licence. The move cuts both ways, though: the same month, Huobi told its existing Singapore users it would close their accounts by 31 March 2022 to comply with local rules. Magnet and gate, operating at once.
Al Jazeera, on the ban Straits Times, on Huobi's Singapore base Fortune, on Huobi closing Singapore accounts
31 May 2022 Project Guardian launches MAS partners with the industry to pilot asset-tokenization use cases across four focus areas. Institutional build-out
The institutional pivot was already underway before Three Arrows Capital and FTX failed. Those collapses gave MAS a publicly legible reason to foreground it and pair it with new retail restrictions.
Jun 2022 Terra collapses, Three Arrows Capital liquidates Three Arrows Capital enters BVI liquidation on 27 June. Three days later MAS reprimands its Singapore fund manager, a registered fund management company, for breaching its asset cap and giving false information. The 2022 reckoning
Three Arrows Capital Pte. Ltd., the Singapore fund manager, held MAS Registered Fund Management Company status, which capped it at 30 qualified investors and S$250M of assets. MAS found it exceeded that cap from July to September 2020 and again from November 2020 to August 2021, and that it had given MAS misleading information about novating its fund. This is the event that converts a global crash into a Singapore-reputational story specifically: 3AC's failure implicated Singapore's own regulatory perimeter, not just its market exposure.
Aug 2022 "Yes to Digital Asset Innovation, No to Cryptocurrency Speculation" MAS Managing Director Ravi Menon names Luna's collapse directly, argues crypto "lacks the three fundamental qualities of money," and previews retail-suitability and leverage restrictions while reaffirming Project Guardian in the same speech. Institutional build-out
"MAS' facilitative posture on digital asset activities and restrictive stance on cryptocurrency speculation are not contradictory," Menon says, naming and resolving what he calls a public perception of mixed messages. Delivered three months after Terra/3AC and roughly ten weeks before FTX.
Nov 2022 FTX collapses Temasek writes down its full $275M FTX investment to zero. FTX itself was not licensed by MAS and operated offshore. The 2022 reckoning
MAS confirms it saw no cause to have placed FTX on its Investor Alert List, since FTX neither operated in nor actively solicited Singapore users, unlike Binance, which was on that list for exactly that reason. The two 2022 shocks are structurally different: 3AC exposed a real gap in MAS's regulatory perimeter, FTX exposed Temasek's due diligence on an offshore investment MAS was never positioned to police. Domestic commentary at the time didn't always draw that line clearly.
MAS statement, Nov 2022 TechCrunch, on the Temasek writedown
Jul 2023 Investor protection measures published MAS announces that DPT providers will have to hold customer assets under a statutory trust, and says it will stop them facilitating retail lending and staking. Regulatory gate
Institutional and accredited investors stay exempt from the lending/staking restriction. This is the clearest textual instance of the pivot: what had been one licensing regime for everyone splits into two doors, institutional infrastructure gets built out, retail gets hard restrictions.
Sep 2023 Zhu Su arrested at Changi Airport 3AC co-founder Zhu Su is arrested attempting to leave Singapore and jailed four months for contempt of court, for failing to comply with a disclosure order tied to the liquidation, not over the collapse of the fund itself. The 2022 reckoning
A committal order was also issued against co-founder Kyle Davies, who had not been apprehended. In June 2025 the Court of Appeal upheld the orders requiring both founders to disclose their dealings with the fund.
Jun 2025 The offshore loophole closes Singapore-incorporated firms serving only overseas customers now need an MAS licence too, with no transitional period. MAS says it will generally not grant one. Regulatory gate
This closes off the structure that let a firm hold a Singapore registration while avoiding Singapore-facing rules entirely. The rule covers digital payment tokens and tokens of capital markets products only. Utility and governance tokens stay outside it.
Sep 2026 Draft stablecoin law published MAS publishes actual draft legislative amendments implementing its stablecoin framework, open for consultation until 16 October 2026. Institutional build-out
Non-MAS-regulated stablecoins get treated as ordinary digital payment tokens, inheriting the full 2023 consumer-protection package. MAS is separately weighing whether to recognise foreign-issued stablecoins in the same window.
Do the courts back it up?
Yes. Whether crypto counts as property took four rulings to settle, including one reversal, and a fifth in 2026 shows the freezing machinery works.
2019 B2C2 v Quoine, first instance [2019] SGHC(I) 3
B2C2 won on both breach of contract and breach of trust, implicitly treating crypto as property that can be held in trust.
After an April 2017 exchange glitch executed trades at roughly 250x the market rate, Quoine unilaterally reversed them. The Singapore International Commercial Court ruled in B2C2's favour on breach of contract and breach of trust.
Court of Appeal judgment, which recounts the first-instance ruling
2020 Quoine v B2C2, on appeal [2020] SGCA(I) 2 Reversed here
Contract win upheld. Trust finding reversed. The property question deliberately left open.
The Court of Appeal, led by Chief Justice Sundaresh Menon, kept the contract ruling but reversed the trust finding, holding the property question "should not be dealt with here but should be kept open for another day." The case's lasting influence turned out to be elsewhere: for a deterministic trading algorithm, the relevant state of mind for a mistake defence is the programmer's at the time of coding, not a specific instance of it, a doctrinally new answer for contracts formed by autonomous code.
2022 CLM v CLN [2022] SGHC 46
Crypto is property. Singapore's first direct ruling on the question, two years after the Court of Appeal left it open.
Applying the classic English Ainsworth property test, the High Court held cryptocurrency is property capable of being frozen and traced, over a US$7.09M BTC/ETH theft. It's also Singapore's first reported freezing injunction against "persons unknown," with exchanges operating in Singapore ordered to disclose account data.
2023 ByBit Fintech v Ho Kai Xin [2023] SGHC 199
Crypto held to be a "thing in action" (a type of property) that can be held in trust. The question the 2020 appeal left open, finally answered.
After an employee diverted roughly 4.21M USDT via manipulated internal spreadsheets, the High Court declared an institutional constructive trust in ByBit's favour, closing the exact loop the 2020 Court of Appeal left open three years earlier.
2026 DVA v DVC [2026] SGHC(I) 4
A S$75M freeze, showing Singapore's courts can now enforce crypto claims in practice.
The SICC froze roughly S$75M in BTC and USDC in March 2026 in a dispute with the operator of one of the world's largest crypto trading platforms, granting an interim injunction that bars the defendant from dealing with the assets.
- Cited abroad, not copied: When a Hong Kong court ruled crypto is property, it weighed cases from England, Australia, Singapore, New Zealand, Canada, the BVI and the US (Clifford Chance), so Singapore didn't set the precedent everyone else followed.
- Not every case lands here: Terra is counted among Singapore's blockchain companies (Tracxn), but Do Kwon's fraud prosecution and 15-year sentence happened in a US court (US Department of Justice).
What's actually regulated
The licensing gate
The licensing gate opened January 2020. By August 2026, MAS's own count was 37 licensed Digital Payment Token providers out of close to 300 applicants (MAS), close to 90% never making it through.
- 37 Licensed
- 263 Not licensed (mostly rejected or withdrawn, per MAS)
Three global names left the licensing process instead of clearing it:
-
Binance: Its Singapore affiliate withdrew in December 2021 and Binance.sg was due to close by 13 February 2022 (CNA). That October it had already cut Singapore users off from spot trading and fiat deposits on the global site (Business Times). MAS put Binance on its investor alert list in 2021 and later said Binance had taken steps to stop soliciting Singapore users (CNA). The global site was still reachable from Singapore as of October 2026, without a Singapore licence.
-
Huobi (HTX): Closed all Singapore accounts on 31 March 2022 (HTX). Its current user agreement still lists Singapore as a prohibited jurisdiction (HTX).
-
Luno: Withdrew its application in April 2023 and left the market on 20 June (Straits Times).
Also worth knowing
- The licence covers businesses, not residents: It governs who can operate a crypto business in Singapore, not what residents do with their own money. Bybit is unlicensed, was added to MAS's investor alert list in June 2026 (MAS), and its own terms exclude Singapore users (Bybit).
- A widely reported fine appears fabricated: A S$4.8M AML fine against three DPT providers, reported in March 2026, doesn't appear in MAS's list of enforcement actions.
- No crypto-specific work pass: Neither the Employment Pass nor the EntrePass mentions blockchain or crypto.
- One loosening: In April 2026, MAS proposed letting banks treat cryptoassets on public, permissionless blockchains under the lighter Group 1 prudential category if they meet principle-based safeguards (MAS consultation paper; Allen & Gledhill summary).
Who's actually here
38 firms hold a Digital Payment Token service licence, per MAS's live registry (October 2026). Capital markets services licences and market-operator recognition are separate regimes and are not counted here. Roughly a fifth are other fintechs, including PayPal, Revolut and moomoo, whose main business is payments, banking or stockbroking rather than crypto.
Where Singapore is strong
- Tokenization: ADDX and DigiFT are MAS-recognised market operators that also hold capital markets services licences (ADDX, DigiFT). DigiFT has distributed tokenized funds from UBS Asset Management and Invesco, plus a treasury strategy sub-managed by Wellington. StraitsX issues the XSGD and XUSD stablecoins through three MAS-licensed payment entities.
- Classic DeFi: Thinner. The best-known protocols with Singapore roots, Zilliqa and Kyber Network, both came out of one NUS computing lab, which spun out six start-ups in all (NUS).
Who's moving in and out
Firms are moving in both directions. In October 2025, Gu Ronghui, CertiK's co-founder, a technology adviser to MAS and a former member of Hong Kong's Web3 task force, told the South China Morning Post: "Over the past two years, especially in the first half of this year, many professionals and companies in the Web3 ecosystem have relocated their headquarters to Hong Kong from Singapore." Over a similar window, several infrastructure-grade players deepened their Singapore presence, while Bybit went the other way:
| Company | Move | When |
|---|---|---|
| Ripple | MAS approved an expansion of the payment activities under its Major Payment Institution licence | Dec 2025 |
| Coinbase | Opened a new Singapore office and plans to grow local staff from 150 to about 200 by the end of 2026 | Jul 2026 |
| BitGo | Appointed Angela Ang, a former MAS licensing lead, as APAC Managing Director and President of BitGo Singapore | Jun 2026 |
| Circle | Agreed to acquire Singapore-headquartered payments firm Tazapay, subject to MAS approval | Sep 2026 |
| Bybit | Opened its global headquarters in Dubai, later on a narrow preparatory VARA licence its CEO called "very restricted" | Apr 2023 |
What it costs to set up
Singapore's entry cost sits in the middle of five hubs: above Switzerland and the Cayman Islands, below Dubai and Hong Kong. The harder gate is approval, not cost: only 37 of close to 300 applicants hold a Digital Payment Token licence (MAS, August 2026).
- First-year fees: Fees include the first year of supervision or membership where it is payable up front.
- Minimums: Capital figures are minimums, and regulators can ask for more.
- Exchange rates: Converted at 5 October 2026 rates (ExchangeRate-API).
- Hong Kong: The capital figure applies to platforms trading security tokens (SFC circular). Platforms licensed only for other tokens follow Part VI of the SFC's VATP Guidelines, which Regulatory Counsel and HK Licence put at the same amounts.
- Switzerland: A full FinTech licence needs at least CHF 300,000 of capital (Equilex).
Where each hub leads
No single jurisdiction wins on every dimension:
-
Institutional tokenization
Singapore
MAS runs Project Guardian, a live industry pilot for tokenized finance since 2022
-
Crypto case law
Singapore
Courts have held crypto is property that can sit in trust (2022, 2023)
-
Banking access for crypto firms
Switzerland
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Tokenized-fund regulation
Cayman Islands
-
Exchange headquarters
Dubai
Bybit moved its global headquarters there from Singapore in April 2023
-
Family-office growth
Hong Kong
Deloitte estimates 3,384 single-family offices at end-2025, up 681 in two years
The funding picture
Singapore blockchain companies have raised $680M in equity funding so far in 2026 (to September), already more than all of 2025 ($632M), per Tracxn. About $400M of it is one deal.
2026 so far: one deal, fewer rounds
On 16 July 2026, Citadel Securities invested $400M in Crypto.com at a $20B valuation (Crypto.com), which Tracxn lists among Singapore's 2026 rounds. Without it, the other 17 rounds raised about $280M, up around 19% on the same months of 2025, but across far fewer deals.
Year by year
2026 is already ahead of 2025 and 2023, but still behind 2024 ($820M) and about a third of 2022's $2.03B peak.
Who has raised, and how far they got
Tracxn tracks 2,456 Singapore blockchain startups. 989 have raised funding ($7.64B in total), 174 have reached Series A or later, 51 Series C or later, and 5 have become unicorns. The sector has seen 37 acquisitions and 3 IPOs.
Where the money was lost
- Temasek and FTX: Temasek wrote down its entire US$275M FTX investment in November 2022 (BBC). Against a portfolio worth US$401B at market value in March 2026 (Temasek Review 2026), that is about 0.07%.
- Three Arrows Capital: The larger Singapore collapse. It owed creditors about $3.5B (Decrypt). MAS found it had exceeded the S$250M asset cap on its registered fund manager status for most of the period from July 2020 to August 2021, and reprimanded it in June 2022 (MAS). Its founders received nine-year bans in September 2023 (CNA).
The jobs picture
There is no widely published headcount for Singapore's crypto workforce. Job postings are the closest public proxy, and the one source that compares cities on the same basis is Coincub's Web3 Jobs Report 2025:
| Market | Postings, 2025 | YoY | Dev salary |
|---|---|---|---|
| Singapore | 3,086 | +27% | $60K to 140K |
| Hong Kong | 1,569 | +35% | $50K to 154K |
| Taiwan | 716 | +81% | $28K to 90K |
| United States | 21,612 | +26% | $60K to 150K |
Postings and growth are from Coincub (report, press release); Taiwan's growth is calculated from its 396 postings in 2024. Salary ranges are from web3.career's blockchain developer table. These are postings, not headcount.
What the job pays
No major recruiter appears to publish a crypto-specific salary guide for Singapore. These ranges come from CryptoJobsList, a crypto-native job board that compiles anonymous salary submissions and job posts. The blockchain engineer range is based on 17 entries (CryptoJobsList). The figures are submitted and advertised pay, not payroll records.
Who is hiring and cutting
Company-level headcount is thin. The firms that do disclose numbers show global cuts alongside a protected or growing Singapore base:
Coinbase
Cut about 14% of staff worldwide in May 2026. In July it opened a new Singapore office and planned to reach about 200 local staff by year end.
Crypto.com
Announced a cut of up to 12% of its workforce in March 2026, citing AI. It did not publish a Singapore breakdown.
Bybit
Moved its headquarters to Dubai in April 2023 and plans a regional centre of more than 500 staff in Abu Dhabi.
Sources: Engadget and the Straits Times (Coinbase), Cointelegraph (Crypto.com), The National (Bybit's Abu Dhabi plans) and Bybit's own terms (Singapore exclusion).
The informal side
DAO contributors, airdrop farmers and crypto-KOL earners are even less visible. Singapore's Platform Workers Act, in force since January 2025, covers ride-hail and delivery work (MOM), and there is no official count of residents earning crypto income this way. The one documented nuance is tax. The IRAS guide (e-Tax Guide, PDF) draws a distinction most secondary sources flatten into a flat rule:
Was the airdrop received in exchange for a service?
No
Not taxable
A genuine, unsolicited windfall airdrop is generally untaxed.
Yes
Taxable as service income
Most points-program farming, bridging, trading volume and social tasks plausibly fail this test.
The guide, whose latest edition is January 2026, never mentions DAOs. Singapore also taxes income sourced in Singapore, so a resident doing the work while sitting here is plausibly earning taxable income whether or not the payer is an offshore protocol. That is an interpretation of the source-of-income test, not tax advice. A summary by BDO reaches the same airdrop conclusion.
Where people train
Four universities teach blockchain or fintech material, at very different depths:
SUTD
Compliance course
Regulatory Compliance for Blockchain, jointly awarded with the Blockchain Association Singapore.
SMU
Executive certificate
Blockchain and Digital Assets for Financial Services, an e-learning course.
NUS
Digital FinTech MSc
A broader fintech degree from NUS Computing, rather than a blockchain-specific one.
What this means for you
Hold it?
Yes. Singapore's licensing regime, in force since January 2020, applies to the businesses that provide token services (MAS), not to residents holding their own crypto. That licence gate governs supply, not demand: a resident can also reach an unlicensed offshore platform directly, as Binance's global site shows.
Taxed?
Singapore has no general capital gains tax. IRAS's e-Tax Guide (latest edition January 2026) treats gains from selling tokens as untaxed capital gains unless the activity amounts to a trade or business. The guide does not cover staking or DeFi yield. A BDO summary says such rewards may be taxable if frequent or substantial. DAO contributors and airdrop farmers face a sharper, separate question, because the guide is silent on DAOs.
Buy it?
Through any exchange on MAS's list of Digital Payment Token licensees, which includes Coinbase, OKX, Bitstamp, Independent Reserve, Upbit, Coinhako, Blockchain.com, Gemini and Crypto.com. For stablecoins, StraitsX's payment entities are also on that list.
Spend it?
Limited is the honest word. Nothing in Singapore matches the Philippines' QR Ph network, where Coins.ph users can spend crypto at nearly 700,000 merchants (Bitcoin.com News). What Singapore has instead is a cheap cash-out path for stablecoins. StraitsX charges nothing for SGD bank transfers in or out of a personal account, and minting XSGD costs only the network fee (StraitsX fee schedule).
Get paid in it?
Not mainstream. Paying a salary in crypto isn't a standard product in Singapore, whereas in the Philippines PDAX and Toku offer stablecoin payroll with local cash-out (Cointelegraph). Earning crypto income here today, through DAO pay, airdrop farming or KOL fees, means sitting in the informal economy, with tax treatment that depends on facts IRAS's guide doesn't fully address. For the Philippines in full, see Mapping ASEAN's Crypto Scene.