A New Era of Cryptocurrency Asset Regulation in Singapore: Analysis and Impact of DTSP Rules

Recently, the financial regulatory landscape in Singapore has undergone significant changes. The "Financial Services and Markets Act" will officially take effect on June 30, 2025, marking the formal implementation of the new DTSP regulations. This initiative means that Singapore is beginning to impose strict regulations on encryption assets, and projects as well as many practitioners that have not obtained licenses may face a new round of adjustments.

Regulatory Shift in Singapore

On September 24, 2021, mainland China implemented strict regulatory measures on activities related to virtual currencies. This resulted in a large number of encryption asset practitioners migrating to Singapore, temporarily injecting vitality into the Singaporean economy, while also driving up the local cost of living.

However, the financial risks of encryption assets cannot be ignored. While enjoying the economic dividends, the Singapore government is also considering how to balance development and risks. As early as April 2022, Singapore passed the Financial Services and Markets Act, laying the foundation for the regulation of encryption assets.

Scope of DTSP License

The DTSP (Digital Token Service Providers) license mainly targets the following two types of entities:

1. Individuals or legal entities conducting business within Singapore
2. Singapore-registered companies providing digital token services to clients outside of Singapore.

It is worth noting that the new regulations have a rather broad definition of "conducting business in Singapore"; as long as one is physically located within Singapore, whether conducting encryption asset business through a physical storefront or an online platform, it falls under the regulatory scope.

Regulated Business Types

The DTSP rules cover transactions and financial operations related to encryption assets, mainly including:

• Digital Token Trading
• Digital Token Exchange Operations
• Digital Token Custody
• Digital Token Transfer
• Digital Token Consultation

Exemption Business

Certain technical support services related to encryption assets that are more peripheral are not within the scope of regulation, such as:

• Pure data storage
• Authentication Service
• Network communication support
• Non-essential technical services

Impact and Outlook on the Industry

The regulatory measures in Singapore are not sudden, but rather provide a three-year transition period. However, many industry practitioners may not have fully appreciated this change and are now facing a new round of adjustments.

In the long run, the compliance operation of encryption assets may become a global trend. For participants who wish to develop in the industry for the long term, it will become crucial to emphasize compliance construction and to layout relevant licenses early.

For practitioners who may leave Singapore, Southeast Asian countries such as Thailand, Vietnam, Malaysia, and the Philippines have held a relatively open attitude towards encryption assets in recent years, potentially becoming new options. In addition, the Middle East regions such as Dubai and Abu Dhabi have attracted some practitioners' attention due to their flexible capital flow policies.

Regardless of the direction chosen, participants in the encryption asset industry need to assess carefully and make the best decisions based on their own circumstances.