You may have heard that the Monetary Authority of Singapore (MAS) has recently officially released its final regulatory response to the "Digital Token Service Provider" (DTSP) regime under the Payment Services Act, and has clearly announced that it will be fully implemented by June 30, 2025, with no grace period.
This time, it is no longer a policy trial in the consultation phase, nor is it a symbolic regulatory posture of "talking points."
The signal released by MAS is very clear: no licenses, no engagement in any Token-related business. It doesn't matter whether the client is in Singapore or whether the business is on-chain.
On the surface, this is a new licensing requirement for Token services, but in reality, it is a structural reconstruction of the operational logic of Web3 projects.
Last week, there have been many interpretations of the document, so Portal Labs won't repeat a comprehensive interpretation. We will just share some of our views on the implementation of this regulation.
A Structured Cleanup Under "Administrative Norms"
Some people consider DTSP as an extended version of VASP, but this is not the case.
The launch of DTSP marks that MAS is attempting to systematically reconstruct the vague yet broad concept of "Token services" and delineate the boundaries of what is permissible and impermissible in the form of legal provisions.
The so-called "token services" are no longer limited to Token issuance from the perspective of MAS, but encompass various activities that project parties may engage in, including issuance, promotion, trading, transfer, custody, OTC matching, and even providing technical or operational assistance.
In other words, as long as you are a part of this Token mechanism, whether actively or passively, you may be considered a service provider.
The more critical change is that MAS has abandoned the compliance judgment based on the place of registration or on-chain deployment, returning the core judgment criteria to "where the people are and where the business activities are."
This means that even if your contract is written on the chain, the system is deployed in the cloud, and customers are spread across the globe, as long as you have a permanent presence in Pahang and are promoting Token-related business, you are very likely to be considered as "operating in Singapore."
The classic remote architecture model of "People on the slope, matters on the chain" officially bids farewell to the regulatory vacuum period.
The MAS has no ambiguity in its stance on this matter. In this round of responses, the MAS clearly stated that it will take an "extremely cautious" approach to the issuance of DTSP licenses, applicable only to a very small number of applicants.
According to PANews data statistics, there are currently only 33 cryptocurrency projects holding the MPI license, which has been open for application for 5 years. One can imagine the difficulty and approval rate for the upcoming DTSP license.
Therefore, Portal Labs believes that this is not a licensing bid, nor is it a goal that can be achieved solely through the efforts of a technical team. It is more like an active screening of the project's governance structure. Web3 project architectures that lack role separation, have unclear funding paths, and ambiguous responsibility divisions will lose their eligibility to remain in this round of cleanup.
However, this is not a hostility from Singaporean regulators towards Web3, but rather a more directional signal that the logic of regulatory arbitrage is gradually coming to an end under mainstream regulatory trends.
"Where to go" is no longer the answer
So, where else can we go?
Many Chinese-speaking Web3 project teams' first reaction is: move to Hong Kong.
This expectation is not unfounded. Over the past two years, Hong Kong has frequently released welcoming signals: advancing the VASP system, officials making public statements, hosting Web3 carnivals... It has once been regarded as a major candidate for "taking on Singapore's exit projects."
Immediately after the announcement of the new DTSP regulations in Singapore, Hong Kong Legislative Council member Wu Jiezhuang also spoke out to welcome it, and posted a bilingual statement in Chinese and English on social media saying: "If you are unable to continue your operations in Singapore and are considering moving to Hong Kong, feel free to contact me to learn more about the relevant situation. We are willing to provide assistance and welcome you to develop in Hong Kong!"
This statement undoubtedly sends a positive signal from Hong Kong's side of "leveraging to absorb". However, from a regulatory reality perspective, the issue is far from simple.
Hong Kong's regulation is not lenient; it is another expression of a structured regulatory system:
At the CEX level, Hong Kong has explicitly required trading platforms to operate with licenses and to be regulated by the SFC according to the Securities and Futures Ordinance. Platforms must not only provide compliant solutions at critical nodes such as user access, coin selection, and custody mechanisms, but also establish independent auditing, anti-money laundering, and risk control systems. Compared to the past "trial and adjustment" grey area approach, Hong Kong's regulatory method emphasizes "proactive structural design," which is suitable for institutional platforms willing to operate in long-term compliance.
In terms of Token issuance, there are currently no special laws in Hong Kong regarding the public issuance of Tokens. However, referencing the recent regulatory trends in the United States, the European Union, and Singapore, while there is still some space for certain Token issuances at this stage, it is possible that if legislation advances in the future, the regulatory framework may further tighten.
In terms of the implementation of Web3 projects, Hong Kong frequently releases supportive signals, but the current regulatory system that has truly taken root still focuses on a few areas such as virtual asset trading platforms. For other forms of Web3 projects (such as DeFi, DAO, RWA issuers, etc.), a dedicated regulatory channel has not yet been established. In reality, regulators tend to accept project types that have clear structures, sufficient information disclosure, and can be transparently identified under the existing licensing system. To some extent, this resembles "partial openness under financial compliance guidance," rather than a general acceptance of all forms of innovation.
In other words, Hong Kong does welcome the landing of the Web3 industry, but the premise is that you can keep up with the regulatory pace. If your operational structure in Singapore has already crossed the line, it is very likely that it will not be able to land in Hong Kong soon either.
As for other alternative locations, such as Dubai, Portugal, Seychelles, and even some regional cities that seem to have a better atmosphere like Shenzhen, they either lack a mature financial regulatory framework or have unclear and unsustainable compliance paths. They may provide a temporary refuge, but it is difficult to establish a long-term legal foundation.
The new regulations for DTSP are not an isolated case, but rather represent a broader regulatory trend: sovereign jurisdictions are no longer accepting the "puzzle piece" Web3 architecture based on registration locations, but are starting to define responsibility based on "where people are and where events occur."
Therefore, the more urgent issue that Web3 projects need to address is no longer about "where to move", but whether they can "exist in compliance" after moving.
From this perspective, Singapore is not the endpoint, nor is Hong Kong the solution. The next stop for Web3 is not another "arbitrage hotspot," but a comprehensive examination of structural capabilities, governance logic, and compliance mindset.
What you really should ask is, how to stay?
The biggest signal released by the new DTSP regulations has never been about suppressing a certain type of project or region, but rather a systematic update of regulatory logic.
In the past, many Web3 projects relied on a "puzzle-like architecture" to navigate the gray areas of compliance: registered in Country A, technical team in Country B, market in Country C, clients spread across the globe, KYC outsourced to Country E, and funds operating in Country F. This seemingly distributed yet "non-penetrable responsibility" approach was once seen as the "standard configuration" for Web3 projects.
But today, the regulatory perspective has fundamentally changed - it no longer looks at where your company is registered or where the code is deployed, but directly anchors:
Who controls the issuance decisions of the Token?
Is the custody path and fund flow of user assets clear?
Where is the actual controller of the project located and what responsibilities do they fulfill?
Is there a mechanism for penetrating governance, structural isolation, and clear responsibilities?
What is being tested here is no longer the wording skills of a particular legal opinion, but the overall "structural capability" of the Web3 project party, that is, whether it can establish a truly penetrable, accountable, and sustainably operating role system and responsibility framework.
In such a regulatory context, "relocating the registration" has essentially ceased to be a solution. It is more like a game of risk transfer, shifting potential issues from one jurisdiction to another area where regulation has yet to respond, failing to fundamentally improve the risk exposure.
From this perspective, DTSP is not just a mandate for Web3 projects, but a turning point for investors' compliance perspectives. It makes a key question unavoidable: "Am I investing in a project, or in a legal risk entity that has not yet been clearly identified?"
For investors, this regulatory evolution means an upgrade in the dimensions of judgment. In traditional investment logic, a white paper, a roadmap, and an AMA are sufficient to build confidence expectations. However, in the reality of tightening regulations, the "structural transparency" of Web3 projects will become a mandatory review item:
Does the Token itself have a legal path and basis for issuance?
Is the control structure clear, and are there any internal responsibility overlaps or risks of proxy holding?
Do founders face excessive legal risks, and should their roles be separated?
Does the project have a compliant financing, token issuance, and even exit mechanism in the future?
These questions are no longer just for lawyers to answer; investors must also learn to ask and examine them.
In other words, regulation is forcing the entire Web3 market to enter a new stage of "identity governance." Web3 projects can no longer rely solely on "narratives," but must provide answers regarding structural design; investors are no longer just looking at valuations, but are asking, "Are you ready to be penetrated by regulation?"
DTSP is just the beginning, a larger wave of compliance is happening globally in sync.
*Tip: Investment involves risks. Please participate in Web3 under the premise of legality and compliance.
The content is for reference only, not a solicitation or offer. No investment, tax, or legal advice provided. See Disclaimer for more risks disclosure.
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IELTS
· 06-10 04:56
Forward #加密市场回调##周末行情分析##交易策略分享# In the craft industries such as fair trade coffee, organic textiles, and handmade jewelry, transparency and trust are crucial. Consumers are increasingly demanding proof of ethical sourcing and authenticity, but traditional supply chain systems often lack the granularity to provide such proofs. BSV, with its scalable blockchain, low-cost transactions, and tamper-proof data storage, offers a powerful solution for recording the supply chain origins of these niche markets. By enabling small producers to record sourcing, verification, and production processes on-chain, BSV enhances consumer confidence and eliminates costly intermediaries. This article explores how BSV is transforming the handmade supply chain and its potential to empower small-scale producers.
Reply0
IELTS
· 06-10 04:56
Forward #加密市场回调##周末行情分析##交易策略分享# In the craft industries such as fair trade coffee, organic textiles, and handmade jewelry, transparency and trust are crucial. Consumers are increasingly demanding proof of ethical sourcing and authenticity, but traditional supply chain systems often lack the granularity to provide such proofs. BSV, with its scalable blockchain, low-cost transactions, and tamper-proof data storage, offers a powerful solution for recording the supply chain origins of these niche markets. By enabling small producers to record sourcing, verification, and production processes on-chain, BSV enhances consumer confidence and eliminates costly intermediaries. This article explores how BSV is transforming the handmade supply chain and its potential to empower small-scale producers.
The Great Panic: Where Can Web3 Projects Go Under the Impact of Singapore's New DTSP Regulations?
You may have heard that the Monetary Authority of Singapore (MAS) has recently officially released its final regulatory response to the "Digital Token Service Provider" (DTSP) regime under the Payment Services Act, and has clearly announced that it will be fully implemented by June 30, 2025, with no grace period.
This time, it is no longer a policy trial in the consultation phase, nor is it a symbolic regulatory posture of "talking points."
The signal released by MAS is very clear: no licenses, no engagement in any Token-related business. It doesn't matter whether the client is in Singapore or whether the business is on-chain.
On the surface, this is a new licensing requirement for Token services, but in reality, it is a structural reconstruction of the operational logic of Web3 projects.
Last week, there have been many interpretations of the document, so Portal Labs won't repeat a comprehensive interpretation. We will just share some of our views on the implementation of this regulation.
A Structured Cleanup Under "Administrative Norms"
Some people consider DTSP as an extended version of VASP, but this is not the case.
The launch of DTSP marks that MAS is attempting to systematically reconstruct the vague yet broad concept of "Token services" and delineate the boundaries of what is permissible and impermissible in the form of legal provisions.
The so-called "token services" are no longer limited to Token issuance from the perspective of MAS, but encompass various activities that project parties may engage in, including issuance, promotion, trading, transfer, custody, OTC matching, and even providing technical or operational assistance.
In other words, as long as you are a part of this Token mechanism, whether actively or passively, you may be considered a service provider.
The more critical change is that MAS has abandoned the compliance judgment based on the place of registration or on-chain deployment, returning the core judgment criteria to "where the people are and where the business activities are."
This means that even if your contract is written on the chain, the system is deployed in the cloud, and customers are spread across the globe, as long as you have a permanent presence in Pahang and are promoting Token-related business, you are very likely to be considered as "operating in Singapore."
The classic remote architecture model of "People on the slope, matters on the chain" officially bids farewell to the regulatory vacuum period.
The MAS has no ambiguity in its stance on this matter. In this round of responses, the MAS clearly stated that it will take an "extremely cautious" approach to the issuance of DTSP licenses, applicable only to a very small number of applicants.
According to PANews data statistics, there are currently only 33 cryptocurrency projects holding the MPI license, which has been open for application for 5 years. One can imagine the difficulty and approval rate for the upcoming DTSP license.
Therefore, Portal Labs believes that this is not a licensing bid, nor is it a goal that can be achieved solely through the efforts of a technical team. It is more like an active screening of the project's governance structure. Web3 project architectures that lack role separation, have unclear funding paths, and ambiguous responsibility divisions will lose their eligibility to remain in this round of cleanup.
However, this is not a hostility from Singaporean regulators towards Web3, but rather a more directional signal that the logic of regulatory arbitrage is gradually coming to an end under mainstream regulatory trends.
"Where to go" is no longer the answer
So, where else can we go?
Many Chinese-speaking Web3 project teams' first reaction is: move to Hong Kong.
This expectation is not unfounded. Over the past two years, Hong Kong has frequently released welcoming signals: advancing the VASP system, officials making public statements, hosting Web3 carnivals... It has once been regarded as a major candidate for "taking on Singapore's exit projects."
Immediately after the announcement of the new DTSP regulations in Singapore, Hong Kong Legislative Council member Wu Jiezhuang also spoke out to welcome it, and posted a bilingual statement in Chinese and English on social media saying: "If you are unable to continue your operations in Singapore and are considering moving to Hong Kong, feel free to contact me to learn more about the relevant situation. We are willing to provide assistance and welcome you to develop in Hong Kong!"
This statement undoubtedly sends a positive signal from Hong Kong's side of "leveraging to absorb". However, from a regulatory reality perspective, the issue is far from simple.
Hong Kong's regulation is not lenient; it is another expression of a structured regulatory system:
At the CEX level, Hong Kong has explicitly required trading platforms to operate with licenses and to be regulated by the SFC according to the Securities and Futures Ordinance. Platforms must not only provide compliant solutions at critical nodes such as user access, coin selection, and custody mechanisms, but also establish independent auditing, anti-money laundering, and risk control systems. Compared to the past "trial and adjustment" grey area approach, Hong Kong's regulatory method emphasizes "proactive structural design," which is suitable for institutional platforms willing to operate in long-term compliance.
In terms of Token issuance, there are currently no special laws in Hong Kong regarding the public issuance of Tokens. However, referencing the recent regulatory trends in the United States, the European Union, and Singapore, while there is still some space for certain Token issuances at this stage, it is possible that if legislation advances in the future, the regulatory framework may further tighten.
In terms of the implementation of Web3 projects, Hong Kong frequently releases supportive signals, but the current regulatory system that has truly taken root still focuses on a few areas such as virtual asset trading platforms. For other forms of Web3 projects (such as DeFi, DAO, RWA issuers, etc.), a dedicated regulatory channel has not yet been established. In reality, regulators tend to accept project types that have clear structures, sufficient information disclosure, and can be transparently identified under the existing licensing system. To some extent, this resembles "partial openness under financial compliance guidance," rather than a general acceptance of all forms of innovation.
In other words, Hong Kong does welcome the landing of the Web3 industry, but the premise is that you can keep up with the regulatory pace. If your operational structure in Singapore has already crossed the line, it is very likely that it will not be able to land in Hong Kong soon either.
As for other alternative locations, such as Dubai, Portugal, Seychelles, and even some regional cities that seem to have a better atmosphere like Shenzhen, they either lack a mature financial regulatory framework or have unclear and unsustainable compliance paths. They may provide a temporary refuge, but it is difficult to establish a long-term legal foundation.
The new regulations for DTSP are not an isolated case, but rather represent a broader regulatory trend: sovereign jurisdictions are no longer accepting the "puzzle piece" Web3 architecture based on registration locations, but are starting to define responsibility based on "where people are and where events occur."
Therefore, the more urgent issue that Web3 projects need to address is no longer about "where to move", but whether they can "exist in compliance" after moving.
From this perspective, Singapore is not the endpoint, nor is Hong Kong the solution. The next stop for Web3 is not another "arbitrage hotspot," but a comprehensive examination of structural capabilities, governance logic, and compliance mindset.
What you really should ask is, how to stay?
The biggest signal released by the new DTSP regulations has never been about suppressing a certain type of project or region, but rather a systematic update of regulatory logic.
In the past, many Web3 projects relied on a "puzzle-like architecture" to navigate the gray areas of compliance: registered in Country A, technical team in Country B, market in Country C, clients spread across the globe, KYC outsourced to Country E, and funds operating in Country F. This seemingly distributed yet "non-penetrable responsibility" approach was once seen as the "standard configuration" for Web3 projects.
But today, the regulatory perspective has fundamentally changed - it no longer looks at where your company is registered or where the code is deployed, but directly anchors:
What is being tested here is no longer the wording skills of a particular legal opinion, but the overall "structural capability" of the Web3 project party, that is, whether it can establish a truly penetrable, accountable, and sustainably operating role system and responsibility framework.
In such a regulatory context, "relocating the registration" has essentially ceased to be a solution. It is more like a game of risk transfer, shifting potential issues from one jurisdiction to another area where regulation has yet to respond, failing to fundamentally improve the risk exposure.
From this perspective, DTSP is not just a mandate for Web3 projects, but a turning point for investors' compliance perspectives. It makes a key question unavoidable: "Am I investing in a project, or in a legal risk entity that has not yet been clearly identified?"
For investors, this regulatory evolution means an upgrade in the dimensions of judgment. In traditional investment logic, a white paper, a roadmap, and an AMA are sufficient to build confidence expectations. However, in the reality of tightening regulations, the "structural transparency" of Web3 projects will become a mandatory review item:
These questions are no longer just for lawyers to answer; investors must also learn to ask and examine them.
In other words, regulation is forcing the entire Web3 market to enter a new stage of "identity governance." Web3 projects can no longer rely solely on "narratives," but must provide answers regarding structural design; investors are no longer just looking at valuations, but are asking, "Are you ready to be penetrated by regulation?"
DTSP is just the beginning, a larger wave of compliance is happening globally in sync.
*Tip: Investment involves risks. Please participate in Web3 under the premise of legality and compliance.