MSTR Cat

Crypto Law/Level III · Tokens and securities law/3.3 Europe and beyond/Lesson 6

Singapore, Hong Kong and the UAE

Three financial centres that compete for crypto business with licences rather than open doors: who regulates what, where the stablecoin rules stand, and the traps for firms that assume a local company is enough.

Education, not legal, tax or investment advice. Crypto law differs between countries and states and changes often. Check the current rules where you live with a qualified lawyer or tax adviser before you act.

The lean path

The cheapest, lowest-tax, simplest and most private route the law allows, best first. Each step names the rule it rests on and the condition that keeps it lawful.

  1. Singapore and Hong Kong generally do not tax individuals’ capital gains, and the UAE has no personal income tax, so residents hold crypto cheaply; the catch is genuine residency, and US citizens stay taxed worldwide, facing possible 26 U.S.C. 877A exit tax on renouncing.
  2. Licensing follows activity, not incorporation: a Singapore company serving only foreign customers needs a licence MAS said in June 2025 it will generally not issue, so the lawful lean route is to serve none or to obtain the needed licence.
  3. In Hong Kong, use one of the SFC’s licensed platforms and only HKMA-licensed issuers’ stablecoins; falsely claiming licensee status is an offence. Platforms should apply under both licensing ordinances because a token’s classification can change.
  4. In Dubai, check whether the activity sits under VARA or the Dubai International Financial Centre, and use only licensed providers; algorithmic stablecoins and privacy tokens are banned in or directed to the UAE under the Central Bank’s Payment Token Services Regulation.

MaterialsMAS media release of 6 June 2025 on the scope of the Digital Token Service Provider regimeThe SFC’s lists of licensed virtual asset trading platforms and of applicantsThe HKMA’s Register of Licensees under the Stablecoins Ordinance (Cap. 656)VARA’s enforcement page and the Central Bank of the UAE’s Payment Token Services Regulation

Wonder

  1. Can a company set up in Singapore and serve only customers abroad?
  2. Which stablecoin issuers are licensed in Hong Kong?
  3. Does a Dubai crypto licence cover the whole of the United Arab Emirates?

Explore

  1. Singapore regulates crypto mainly through the Payment Services Act 2019, which commenced on 28 January 2020 and requires a licence from the Monetary Authority of Singapore (MAS) to provide digital payment token services, the Act’s category for services involving cryptocurrencies. An expanded scope of regulated activities under the Act took effect on 4 April 2024. Tokens that are capital markets products, such as tokenised shares, fall under the Securities and Futures Act 2001 instead. Holding a Singapore company is not the same as holding a licence, and the next rule shows how far that distinction goes.
  2. Since 30 June 2025, the Financial Services and Markets Act 2022 has required Singapore-based digital token service providers that serve only customers outside Singapore to be licensed. On 6 June 2025 MAS said it had set the bar high and would generally not issue such licences, because the money-laundering risks are higher and it cannot effectively supervise activity carried on abroad; providers without a licence had to cease those activities. Services relating only to utility or governance tokens are outside the regime. This reverses a common assumption: here the trap is a home regulator objecting to a business that serves only foreign customers, not a foreign one objecting.
  3. On stablecoins, MAS announced a framework on 15 August 2023 for single-currency stablecoins pegged to the Singapore dollar or a G10 currency and issued in Singapore. Issuers must meet reserve, capital and disclosure requirements and return the par value within five business days of a redemption request; only compliant issuers may use the label ‘MAS-regulated stablecoin’, and misusing it can be penalised. The framework has not yet been fully legislated: on 1 September 2026 MAS opened a consultation on amending the Payment Services Act to introduce it, which closed on 16 October 2026. Treat the final legislative text as pending as of October 2026.
  4. In Hong Kong, centralised virtual asset trading platforms that carry on business in Hong Kong, or actively market their services to Hong Kong investors, must be licensed by the Securities and Futures Commission (SFC): under the Securities and Futures Ordinance for security tokens and under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) for other tokens. The SFC suggests applying under both, since a token’s classification can change. Its public list in October 2026 showed 13 licensed platforms, from OSL (2020) to Bixin.com (May 2026), and warns that deemed-licensed applicants are not formally licensed. Separately, the Stablecoins Ordinance (Cap. 656) came into effect on 1 August 2025.
  5. Under the Stablecoins Ordinance, issuing fiat-referenced stablecoins is a regulated activity in Hong Kong that needs a licence from the Hong Kong Monetary Authority (HKMA), and it is an offence to claim falsely to be a licensee or an applicant. The HKMA granted the first two licences on 10 April 2026, to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited. In the United Arab Emirates, regulation is split. Dubai’s Virtual Assets Regulatory Authority (VARA), set up in March 2022 under Dubai Law No. 4 of 2022, regulates virtual assets across Dubai’s mainland and free zones except the Dubai International Financial Centre, which lies outside VARA’s remit.
  6. VARA enforces against offshore platforms: its enforcement list records cease-and-desist orders and financial penalties on 17 June 2026 against Peken Global Limited (KuCoin) and MX Holdings Ltd (MEXC) for unlicensed virtual asset activity in Dubai. At federal level, the Central Bank of the UAE’s Payment Token Services Regulation, in force since 31 August 2024, allows only licensed dirham payment tokens for general payments, limits registered foreign stablecoins to buying virtual assets, and bans algorithmic stablecoins and privacy tokens in or directed to the UAE. A practical check: for each of the three places, identify the exact regulator for the activity and zone, then find the firm on that regulator’s own register.

Key facts

  • Singapore’s Payment Services Act 2019 commenced on 28 January 2020 and requires a MAS licence for digital payment token services.
  • From 30 June 2025, Singapore-based digital token service providers serving only customers outside Singapore need a licence, which MAS said it will generally not issue.
  • MAS’s stablecoin framework of 15 August 2023 requires issuers to return par value within five business days of a redemption request.
  • Hong Kong’s Stablecoins Ordinance (Cap. 656) took effect on 1 August 2025, and the HKMA granted the first two issuer licences on 10 April 2026.
  • VARA regulates virtual assets across Dubai, including free zones, except the Dubai International Financial Centre.
  • The UAE Central Bank’s Payment Token Services Regulation bans issuing or providing services for algorithmic stablecoins and privacy tokens in or directed to the UAE.

Exercise nine, six, three, one

9CollectList up to 9 crypto services connected with Singapore, Hong Kong or the UAE that you know of, such as exchanges, stablecoins, brokers or token issuers.
6ClusterSort them into 6 categories: MAS-licensed, SFC-licensed platforms, HKMA-licensed stablecoin issuers, VARA-licensed, regulated in a separate financial free zone, and status unknown.
3DistillReduce the 6 categories to 3 groups: licensed for the activity and place, licensed for something else, and unlicensed or unknown.
1CrystallizeWrite 1 sentence explaining why a company incorporated in Singapore, Hong Kong or Dubai can still be operating without the licence its activity needs.

Fact check

Dates, figures and claims checked against the published sources listed below.

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