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Over the last few years, we have seen global regulators walk a fine line as they attempt to regulate digital assets without stifling innovation even as the technology moves at the speed of the internet. Nowhere has this been more true than in Singapore, where regulators have sought to launch a framework for digital assets focused on creating a welcoming environment for cryptocurrency businesses while at the same time zealously protecting consumers and mitigating the risks of money laundering and other illicit activity. This has triggered robust advertising and AML regulation.

Singapore’s Payment Services Act came into effect in January 2020, providing a framework for regulating areas from trading cryptocurrencies to using tokens for payments. Under the law, the Monetary Authority of Singapore (MAS) issues digital payment token licenses to crypto companies that make it through the application process. And, in April, Singapore extended the licensing requirement to virtual asset service providers in the city-state which only do business overseas.

Singapore has led the way globally when it comes to crypto regulation. Understanding the regulatory framework in Singapore is critical for businesses looking to engage with the nation, but also for those looking to understand regulatory frameworks for digital assets across the globe.

To examine and discuss Singapore's approach to crypto regulation, TRM Talks is joined by Tan Shi Min, Deputy Director & Head, Payments Policy Division at the Monetary Authority of Singapore, John Ho, Global Head of Legal, Financial Markets at Standard Chartered Bank and Grace Chong, Head of Financial Regulatory (Singapore) at Gibson, Dunn & Crutcher LLP.
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Deputy Director & Head, Payments Policy Division, Monetary Authority of Singapore
Ms Tan Shi Min is the head of the Policy Division within the Payments Department at the Monetary Authority of Singapore (MAS). The department is responsible for the authorisation, supervision and policy-making in relation to payment systems and payment service providers, such as e-money issuers and digital payment token (more commonly known as cryptocurrency) service providers. Ms Tan oversees the formulation and review of regulatory policies for retail payment systems and payment services.

Prior to this role, Ms Tan was responsible for formulating banking regulatory policies including the digital banking regulatory framework that opened Singapore’s banking sector to non-bank entities. Ms Tan also spent eight years in the development function and the Beijing Representative Office of MAS.
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Head of Financial Regulatory (Singapore), Gibson, Dunn & Crutcher LLP
Grace heads Gibson Dunn’s Financial Regulatory practice in Singapore, and has extensive experience advising on cross-border and complex regulatory matters, including licensing and conduct of business requirements, regulatory investigations, and regulatory change.  A former in-house counsel at the Monetary Authority of Singapore, Ms. Chong regularly interacts with key regulators, is closely involved in regional regulatory reform initiatives and has led discussions with regulators on behalf of the financial services industry.

Grace has advised banks, exchanges, asset managers and startups across Singapore and Hong Kong on regulatory issues such as banking and payments regulations, implementation of electronic trading platforms, licensing, tokenized products launches, crypto funds setup, outsourcing, virtual banking, corporate acquisitions, and data protection and security.

Grace has been consistently named as one of Singapore’s top 10 FinTech lawyers and is highly ranked in Chambers FinTech 2022, with clients noting that she “is very savvy and shares her knowledge of the MAS and market trends” and “is very pragmatic and always comes forth with sensible and realistic propositions, after an in-depth understanding of our requirements and objectives. She is a real asset to have on our side.”  Further, she is recommended in Financial Services Regulatory for Singapore by The Legal 500 2022 guide which notes that she “is one of the best crypto regulatory lawyers in Singapore and is very responsive and personable.”  Ms. Chong was recognized as an “Innovative Individual” in Financial Times’ Innovative Lawyers Awards 2021 and was named as one of Asian Legal Business’ Top 15 Rising Lawyers for APAC.
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Global Head of Legal, Financial Markets, Standard Chartered Bank
John Ho is the Global Head of Legal, Financial Markets for Standard Chartered Bank (“SCB”), overseeing and providing legal advisory, transactional and documentation support for Financial Markets (FM) business globally for Standard Chartered Bank (SCB), its branches and affiliates. Mr. Ho is also the co-chair of (1) the ISDA South East Asia Legal and Regulatory Committee and (2) the ISDA Asia Pacific ESG Working group.

He is an active participant in the industry’s Fintech events and is a public speaker on topics such as Blockchain, Digital Assets, Financial Markets, Sustainability and Regulatory Reforms. He serves as a mentor to startups and recently co-authored a publication from the World Economic Forum called The Digital Currency Governance Consortium Whitepaper. He is a also mentor for the UK FCA Sustainability TechSprint, FCA Digital Sandbox,  R3 and LongHash.

Prior to joining SCB, Mr. Ho was the Managing Director Principal in the legal department of Bear Stearns (Japan), Ltd (“Bear Stearns”) where he supported the Asia franchise (including Tokyo, Hong Kong, China, Taiwan, Korea, India and South-east Asia) from January 2003 to August 2008 covering various structured products and derivatives including equity derivatives, credit derivatives, fixed income and commodities.

Prior to joining Bear Stearns, Mr. Ho worked as Asia equity counsel for Lehman Brothers in Tokyo with experience dealing in convertibles, options, warrants, delta one products and other types of equity derivatives transactions, equity finance and equity capital markets.

He is qualified as an advocate and solicitor in Singapore since 1995 and he received his law degree from the National University of Singapore.”
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Head of Legal and Government Affairs, TRM Labs
Ari Redbord is Head of Legal and Government Affairs at TRM Labs, a blockchain analytics company. Prior to joining TRM Labs, he served as a Senior Advisor to the Deputy Secretary and the Under Secretary for Terrorism and Financial Intelligence at the United States Department of Treasury. In this capacity, he worked with teams from the Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), and other Treasury and interagency components on issues related to sanctions, the Bank Secrecy Act, cryptocurrency, and anti-money laundering strategies.

Previously, Mr. Redbord served as a Senior Assistant United States Attorney for the District of Columbia, where he investigated and prosecuted cases related to cryptocurrency, terrorist financing, sanctions evasion, export control, child exploitation and human trafficking. He has received numerous awards from FinCEN, the FBI, and the United States Attorney's Office, including the Attorney General's Award for leading an interagency task force dedicated to prosecuting those who abuse and exploit children.