Once upon a time, Singapore, with its open and prudent financial policy, was praised by global Web3 entrepreneurs as a "crypto haven" in Asia and even the world. However, a sudden regulatory storm is completely rewriting this situation. On May 30, 2025, the Monetary Authority of Singapore (MAS) officially released new regulations for digital token service providers (DTSPs), requiring all cryptocurrency companies operating in Singapore without obtaining a compliance license to fully stop operations or withdraw by June 30, otherwise they will face criminal penalties.
This hard-line move, which leaves little for a transition period, is seen by the industry as a sweeping sweep of potential "scythes" (i.e., fraudulent or speculative projects that exploit areas of regulatory ambiguity). When Singapore decisively closes its doors, a question arises: where will the crypto capital and talent that has been "swept away" go? The answer seems to point clearly to the shining jewel of the Middle East – Dubai. Will this desert city, which is embracing Web3 with open arms, become the "pick-up man" in this regulatory migration?
The recent regulatory shift in Singapore is centered around Article 137 of the Financial Services and Markets Act (FSM Act), which imposes a licensing obligation on all individuals or institutions that have a business presence in Singapore and provide digital Token services to overseas clients. The key points of the new regulations can be described as "fast, fierce, and precise:"
Relentless deadlines: The MAS clearly stipulates that all affected entities must either obtain a DTSP license or cease all related operations altogether by June 30, 2025. MAS refuses to set up any transition period, which means that there is extremely limited time for businesses to react. Extremely difficult license to obtain: Want to stay? Get the license first. But MAS bluntly stated that DTSP licenses "will only be granted in very limited circumstances". This almost blocks the path left by the compliance of the vast majority of unlicensed companies, and its subtext is tantamount to "persuasion to quit". Broad scope: The new rules target not only international exchanges headquartered in Singapore, but also a large number of Web3 companies with Singapore as their legal domicile but global operations, such as some DeFi protocols, NFT platforms, blockchain game development teams, and even remote developers working from home. MAS's definition of "place of business" is extremely broad and includes not only a formal office, but also a coworking space or even a home office. Deterrence of criminal liability: Continuing to operate in violation of the law after a "dead line" will constitute a criminal offence and face severe penalties under the FSM Act.
So, why is Singapore so resolute in wielding the regulatory "big knife"? The core of the answer lies in the extreme defense of the country's "financial reputation". In the document, MAS repeatedly emphasized that digital token services have strong cross-border anonymity and are easily used for illegal activities such as money laundering and terrorist financing. Although many of the companies they serve are not based in Singapore, if something "happens" to these Singapore-based companies, Singapore will inevitably suffer global reputational and regulatory knock-on effects. Therefore, the regulatory goal of MAS is to filter out high-risk entities at the source, preferring to abandon the tolerance of some innovations rather than at the expense of the reputation of the country's financial center. This is a strategic, preventive defense of the "regulatory reputation red line".
It is worth noting that, in stark contrast to Singapore's strict regulations and crackdowns, Dubai offers a warm invitation. While cryptocurrency companies feel a chill in Singapore, this land in the Middle East is attracting global attention in an unprecedented manner. As the popular phrase at the TOKEN2049 conference goes, "Habibi, Come to Dubai," Dubai is becoming a veritable "promised land" for the crypto industry. Its appeal mainly stems from several aspects:
Attractive tax policy: Dubai offers a very competitive tax environment for businesses. Many companies are exempt from corporate income tax, such as those with annual revenues of less than AED 3 million (approximately US$815,000), or companies registered in certain free zones (e.g., DIFC, DMCC). Even if taxes are required, the tax rate is only 9%, which is much lower than that of major economies such as Europe and the United States. Clear and proactive regulatory framework: In contrast to the regulatory uncertainty in many parts of the world, Dubai has established the world's first independent digital asset regulator, the Virtual Assets Regulatory Authority (VARA). VARA is committed to building a coherent and progressive regulatory environment that encourages innovation while providing clear legal guidance. This provides valuable certainty for crypto businesses, with Middle Eastern regulators weeding out fraudulent companies through rigorous due diligence and leaving quality businesses behind. Strategic location and talent pool: Located at the crossroads of Europe, Asia and Africa, Dubai is a natural gateway for global trade and tourism. Its modern infrastructure, safe living environment and high quality of life have attracted some of the world's best talent and founders. Dubai's strong international connectivity, deep tech talent pool, and secure environment are making it a vibrant hub for blockchain innovation. "Know-how" governments and active ecosystems: Many members of the royal family and the entire government system in this region have thrown themselves into the crypto space. They're knowledgeable, you don't need to explain the basics to them, and it's much easier to communicate. The Dubai government has not only actively promoted its own "blockchain strategy" to become the world's first blockchain-powered government, but has also accepted some cryptocurrency payments and strongly supported various large-scale industry conferences, creating an extremely dynamic ecosystem.
The tightening of regulations in Singapore has objectively created a huge opportunity window for Dubai. Those high-quality Web3 teams and companies that cannot obtain licenses in Singapore and face legal risks will naturally seek new and more business-friendly environments, and Dubai is undoubtedly one of the best options.
Singapore's "one-size-fits-all" policy may impact some early-stage innovation teams that are not "predatory" but temporarily find it difficult to meet high compliance costs, such as developers of certain decentralized protocols. For them, the lower operational costs and more relaxed innovation environment in Dubai are very attractive.
As more and more leading companies shift their focus to Dubai, relevant industry talent, including developers, researchers, operations and marketing personnel, will also flow, further strengthening Dubai's role as a talent hub. Therefore, Dubai's role as a "pick-up man" is not simply to receive eliminated assets, but to actively attract the world's best quality cryptocurrency resources, which is a strategic industrial undertaking.
Overall, Singapore and Dubai, two Asian financial and innovation hubs, are putting on a wonderful "Tale of Two Cities." This ebb and flow of regulatory policies clearly outlines the profound reshaping of the global Crypto Assets landscape.
Singapore's choice is to return to its traditional positioning as a global top financial center, prioritizing financial stability and reputation, and adopting a more cautious and stringent filtering mechanism for high-risk Web3 innovations. In contrast, Dubai has seized this historic opportunity, actively embracing Web3 with its foresight and determination, aiming to become an innovative hub in the era of the global digital economy.
Behind this great migration is the inevitable trend of the cryptocurrency industry from barbaric growth to standardization and specialization. In the future, the global regulatory landscape is likely to become more fragmented, with different jurisdictions playing different roles depending on their own endowments and strategies. For cryptocurrency companies that are up and down in the wave, the space for "regulatory arbitrage" is shrinking day by day, and finding a "home" that can provide long-term stability, clear rules and development prospects has become a top priority.
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Singapore's "zero tolerance" policy on the purge of Crypto Assets "scissors", penalties for non-compliance! Is Dubai becoming a "dumb buyer"?
Once upon a time, Singapore, with its open and prudent financial policy, was praised by global Web3 entrepreneurs as a "crypto haven" in Asia and even the world. However, a sudden regulatory storm is completely rewriting this situation. On May 30, 2025, the Monetary Authority of Singapore (MAS) officially released new regulations for digital token service providers (DTSPs), requiring all cryptocurrency companies operating in Singapore without obtaining a compliance license to fully stop operations or withdraw by June 30, otherwise they will face criminal penalties. This hard-line move, which leaves little for a transition period, is seen by the industry as a sweeping sweep of potential "scythes" (i.e., fraudulent or speculative projects that exploit areas of regulatory ambiguity). When Singapore decisively closes its doors, a question arises: where will the crypto capital and talent that has been "swept away" go? The answer seems to point clearly to the shining jewel of the Middle East – Dubai. Will this desert city, which is embracing Web3 with open arms, become the "pick-up man" in this regulatory migration? The recent regulatory shift in Singapore is centered around Article 137 of the Financial Services and Markets Act (FSM Act), which imposes a licensing obligation on all individuals or institutions that have a business presence in Singapore and provide digital Token services to overseas clients. The key points of the new regulations can be described as "fast, fierce, and precise:" Relentless deadlines: The MAS clearly stipulates that all affected entities must either obtain a DTSP license or cease all related operations altogether by June 30, 2025. MAS refuses to set up any transition period, which means that there is extremely limited time for businesses to react. Extremely difficult license to obtain: Want to stay? Get the license first. But MAS bluntly stated that DTSP licenses "will only be granted in very limited circumstances". This almost blocks the path left by the compliance of the vast majority of unlicensed companies, and its subtext is tantamount to "persuasion to quit". Broad scope: The new rules target not only international exchanges headquartered in Singapore, but also a large number of Web3 companies with Singapore as their legal domicile but global operations, such as some DeFi protocols, NFT platforms, blockchain game development teams, and even remote developers working from home. MAS's definition of "place of business" is extremely broad and includes not only a formal office, but also a coworking space or even a home office. Deterrence of criminal liability: Continuing to operate in violation of the law after a "dead line" will constitute a criminal offence and face severe penalties under the FSM Act. So, why is Singapore so resolute in wielding the regulatory "big knife"? The core of the answer lies in the extreme defense of the country's "financial reputation". In the document, MAS repeatedly emphasized that digital token services have strong cross-border anonymity and are easily used for illegal activities such as money laundering and terrorist financing. Although many of the companies they serve are not based in Singapore, if something "happens" to these Singapore-based companies, Singapore will inevitably suffer global reputational and regulatory knock-on effects. Therefore, the regulatory goal of MAS is to filter out high-risk entities at the source, preferring to abandon the tolerance of some innovations rather than at the expense of the reputation of the country's financial center. This is a strategic, preventive defense of the "regulatory reputation red line".
It is worth noting that, in stark contrast to Singapore's strict regulations and crackdowns, Dubai offers a warm invitation. While cryptocurrency companies feel a chill in Singapore, this land in the Middle East is attracting global attention in an unprecedented manner. As the popular phrase at the TOKEN2049 conference goes, "Habibi, Come to Dubai," Dubai is becoming a veritable "promised land" for the crypto industry. Its appeal mainly stems from several aspects: Attractive tax policy: Dubai offers a very competitive tax environment for businesses. Many companies are exempt from corporate income tax, such as those with annual revenues of less than AED 3 million (approximately US$815,000), or companies registered in certain free zones (e.g., DIFC, DMCC). Even if taxes are required, the tax rate is only 9%, which is much lower than that of major economies such as Europe and the United States. Clear and proactive regulatory framework: In contrast to the regulatory uncertainty in many parts of the world, Dubai has established the world's first independent digital asset regulator, the Virtual Assets Regulatory Authority (VARA). VARA is committed to building a coherent and progressive regulatory environment that encourages innovation while providing clear legal guidance. This provides valuable certainty for crypto businesses, with Middle Eastern regulators weeding out fraudulent companies through rigorous due diligence and leaving quality businesses behind. Strategic location and talent pool: Located at the crossroads of Europe, Asia and Africa, Dubai is a natural gateway for global trade and tourism. Its modern infrastructure, safe living environment and high quality of life have attracted some of the world's best talent and founders. Dubai's strong international connectivity, deep tech talent pool, and secure environment are making it a vibrant hub for blockchain innovation. "Know-how" governments and active ecosystems: Many members of the royal family and the entire government system in this region have thrown themselves into the crypto space. They're knowledgeable, you don't need to explain the basics to them, and it's much easier to communicate. The Dubai government has not only actively promoted its own "blockchain strategy" to become the world's first blockchain-powered government, but has also accepted some cryptocurrency payments and strongly supported various large-scale industry conferences, creating an extremely dynamic ecosystem. The tightening of regulations in Singapore has objectively created a huge opportunity window for Dubai. Those high-quality Web3 teams and companies that cannot obtain licenses in Singapore and face legal risks will naturally seek new and more business-friendly environments, and Dubai is undoubtedly one of the best options. Singapore's "one-size-fits-all" policy may impact some early-stage innovation teams that are not "predatory" but temporarily find it difficult to meet high compliance costs, such as developers of certain decentralized protocols. For them, the lower operational costs and more relaxed innovation environment in Dubai are very attractive. As more and more leading companies shift their focus to Dubai, relevant industry talent, including developers, researchers, operations and marketing personnel, will also flow, further strengthening Dubai's role as a talent hub. Therefore, Dubai's role as a "pick-up man" is not simply to receive eliminated assets, but to actively attract the world's best quality cryptocurrency resources, which is a strategic industrial undertaking.
Overall, Singapore and Dubai, two Asian financial and innovation hubs, are putting on a wonderful "Tale of Two Cities." This ebb and flow of regulatory policies clearly outlines the profound reshaping of the global Crypto Assets landscape. Singapore's choice is to return to its traditional positioning as a global top financial center, prioritizing financial stability and reputation, and adopting a more cautious and stringent filtering mechanism for high-risk Web3 innovations. In contrast, Dubai has seized this historic opportunity, actively embracing Web3 with its foresight and determination, aiming to become an innovative hub in the era of the global digital economy. Behind this great migration is the inevitable trend of the cryptocurrency industry from barbaric growth to standardization and specialization. In the future, the global regulatory landscape is likely to become more fragmented, with different jurisdictions playing different roles depending on their own endowments and strategies. For cryptocurrency companies that are up and down in the wave, the space for "regulatory arbitrage" is shrinking day by day, and finding a "home" that can provide long-term stability, clear rules and development prospects has become a top priority.