Regulation 1
Citation and commencement
These Regulations are the Income Tax (International Tax Compliance Agreements) (Crypto‑Asset Reporting Framework) Regulations 2026 and come into operation on 1 January 2027.
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Income Tax (International Tax Compliance Agreements) (Crypto‑Asset Reporting Framework) Regulations 2026 is Singapore Subsidiary Legislation, cited as Subsidiary Legislation S551 2026, currently marked in force and first recorded in 2026.
Part 1
Citation and commencement
These Regulations are the Income Tax (International Tax Compliance Agreements) (Crypto‑Asset Reporting Framework) Regulations 2026 and come into operation on 1 January 2027.
Implementation of CARF
These Regulations implement Part 1 of the International Standards for Automatic Exchange of Information in Tax Matters pursuant to the Crypto‑Asset Reporting Framework developed and published by the Organisation for Economic Co‑operation and Development (called in these Regulations the CARF), for the purpose of giving effect to any CARF agreement that is declared as an international tax compliance agreement under section 105K(1) of the Act.
The CARF is set out in the Schedule.
Definitions
In these Regulations —
“active entity” has the same meaning as “Active Entity” in subparagraph D(11) of Section IV of the CARF;
“AML/KYC procedures” has the same meaning as “AML/KYC Procedures” in subparagraph F(2) of Section IV of the CARF;
“controlling persons” has the same meaning as “Controlling Persons” in subparagraph D(10) of Section IV of the CARF;
“crypto‑asset user” has the same meaning as “Crypto‑Asset User” in subparagraph D(2) of Section IV of the CARF;
“entity” has the same meaning as “Entity” in subparagraph F(3) of Section IV of the CARF;
“entity crypto‑asset user” has the same meaning as “Entity Crypto‑Asset User” in subparagraph D(5) of Section IV of the CARF;
“excluded person” has the same meaning as “Excluded Person” in subparagraph E(1) of Section IV of the CARF;
“individual crypto‑asset user” has the same meaning as “Individual Crypto‑Asset User” in subparagraph D(3) of Section IV of the CARF;
“IRAS Internet website” means the Internet website of the Inland Revenue Authority of Singapore at https://www.iras.gov.sg;
“pre‑existing entity crypto‑asset user” has the same meaning as “Preexisting Entity Crypto‑Asset User” in subparagraph D(6) of Section IV of the CARF;
“pre‑existing individual crypto‑asset user” has the same meaning as “Preexisting Individual Crypto‑Asset User” in subparagraph D(4) of Section IV of the CARF;
“relevant transaction” has the same meaning as “Relevant Transaction” in subparagraph C(1) of Section IV of the CARF;
“reportable person” has the same meaning as “Reportable Person” in subparagraph D(7) of Section IV of the CARF;
“reportable user” has the same meaning as “Reportable User” in subparagraph D(1) of Section IV of the CARF.
In interpreting these Regulations, recourse is to be had to the CARF read with the Commentaries on the Crypto‑Asset Reporting Framework as at 8 June 2023, which are developed and published by the Organisation for Economic Co‑operation and Development, and available on the IRAS Internet website.
Modifications to Sections I to IV of CARF
For the purposes of regulations 5, 10, 11(3) and 12(1) and (6), Sections I to IV of the CARF are modified by paragraphs (2) to (6).
For the purpose of paragraph A of Section II of the CARF, the appropriate reporting period mentioned in that provision is a period of 12 months.
In subparagraphs A(1) and B(1)(a) of Section III of the CARF, the effective date mentioned in those provisions is 1 January 2027.
In subparagraphs D(4) and (6) of Section IV of the CARF, the reference to a date is to 31 December 2026.
In Sections I and IV of the CARF, “Singapore” is inserted in each placeholder for the jurisdiction.
In Sections I and IV of the CARF, a reference to “Partner Jurisdiction” is to a jurisdiction that is described as one on the IRAS Internet website.
Meaning of “reporting Singaporean crypto‑asset service provider”
In these Regulations, “reporting Singaporean crypto‑asset service provider” means a reporting crypto‑asset service provider —
that is an entity or individual resident in Singapore for a tax purpose;
that is an entity that —
is incorporated or registered under the laws of Singapore; and (ii)is either a legal person or under a duty to file a return to the Comptroller with respect to its income under the Act;
that is an entity managed from Singapore;
that is an entity or individual that has a regular place of business in Singapore; or
that has a branch in Singapore through which relevant transactions are effectuated,and that is not exempt under paragraph C, D, E, F or G of Section I of the CARF (as modified by regulation 4) from the reporting and due diligence requirements in Sections II and III of the CARF, as modified by regulation 4.
Meaning of “residence for a tax purpose”
In these Regulations, a person’s residence for a tax purpose is —
if the person is an individual — the jurisdiction in which the person is resident under the tax laws of the jurisdiction; or
if the person is an entity —
the jurisdiction in which the person is resident under the tax laws of the jurisdiction; or
if the person is not resident in any jurisdiction under the tax laws of any jurisdiction, the jurisdiction in which the person has its effective management.
Part 2
Registration
Unless the Comptroller otherwise directs —
a reporting crypto‑asset service provider that is or becomes a reporting Singaporean crypto‑asset service provider at any time between 1 January 2027 and 31 December 2027 (both dates inclusive) must apply for registration with the Comptroller in accordance with paragraph (2) by 31 March 2028; and
a reporting crypto‑asset service provider that becomes a reporting Singaporean crypto‑asset service provider on a date after 31 December 2027 must apply for registration with the Comptroller in accordance with paragraph (2) by —
31 March of the calendar year following the calendar year in which the reporting crypto‑asset service provider becomes a reporting Singaporean crypto‑asset service provider; or
such extended time as the Comptroller may allow in any particular case.
An application for registration —
must be submitted using the electronic service, unless the Comptroller in any particular case permits it to be submitted in another manner; and
must contain the following particulars:
the name of the reporting Singaporean crypto‑asset service provider;
the full name, address, designation and contact information of an individual authorised by the provider to be the provider’s point of contact for the purposes of these Regulations.
Upon receipt of an application made in accordance with paragraph (2), the Comptroller must register the provider unless the Comptroller has a reasonable excuse not to do so.
A reporting Singaporean crypto‑asset service provider must notify the Comptroller as soon as practicable of any change in the information mentioned in paragraph (2)(b).
In the case of a reporting Singaporean crypto‑asset service provider that is a trust, a requirement under paragraph (1) read with paragraph (2), or paragraph (4), must be complied with by the trustee of the provider.
A requirement under —
paragraph (1) read with paragraph (2); or
paragraph (4),is a requirement under section 105M(1)(b) of the Act, the failure or neglect to comply with which (if such failure or neglect is without reasonable excuse) is an offence under section 105M(1) of the Act.
Part 3
Definitions
In this Part —“reportable jurisdiction” means a jurisdiction outside Singapore that is described as one on the IRAS Internet website;“self‑certification”, in relation to a reporting Singaporean crypto‑asset service provider establishing a relationship with a crypto‑asset user, means a statement containing information —
relating to the crypto‑asset user that is reasonably required by the provider for the purpose of complying with regulations 11 and 12; and
provided by —
in a case where the crypto‑asset user is an entity crypto‑asset user other than an excluded person or an active entity, and the statement only contains information of the residences for a tax purpose of a controlling person of such entity crypto‑asset user — the entity crypto‑asset user or the controlling person; or
in any other case — the crypto‑asset user;“specified particulars”, in relation to a crypto‑asset user, means the following particulars:
if the crypto‑asset user is an individual crypto‑asset user —
the first and last name of the individual;
the residential address of the individual;
every residence for a tax purpose of the individual;
if applicable, the taxpayer identification number (TIN) of the individual with respect to each residence mentioned in sub‑paragraph (iii); and
the date of birth of the individual; (b)if the crypto‑asset user is an entity crypto‑asset user other than an excluded person or an active entity —
the legal name of the entity;
the address of the entity that is registered with any public agency or the address at which the entity is carrying on its business;
every residence for a tax purpose of the entity;
if applicable, the taxpayer identification number (TIN) of the entity with respect to each residence mentioned in sub‑paragraph (iii); and
the following particulars with respect to each controlling person of the entity:
the first and last name of the controlling person;
the residential address of the controlling person;
every residence for a tax purpose of the controlling person;
if applicable, the taxpayer identification number (TIN) of the controlling person with respect to each residence mentioned in sub‑paragraph (C);
the date of birth of the controlling person;
if the crypto‑asset user is an entity that is an excluded person or an active entity —
the legal name of the entity;
the address of the entity that is registered with any public agency or the address at which the entity is carrying on its business;
every residence for a tax purpose of the entity;
if applicable, the taxpayer identification number (TIN) of the entity with respect to each residence mentioned in sub‑paragraph (iii); and
whether the entity is an excluded person or an active entity, and a description of the type of excluded person or active entity (as the case may be);“valid self‑certification” means —
in a case where the crypto‑asset user is an entity crypto‑asset user other than an excluded person or an active entity, and the self‑certification only contains information of one or more residences for a tax purpose of a controlling person of the entity crypto‑asset user — a self‑certification that —
is signed or otherwise positively affirmed by the person making the self‑certification or a person with authority to sign for that person; (ii)states the date on which the self‑certification is signed or otherwise positively affirmed by the person mentioned in sub‑paragraph (i); and
contains the following particulars of the controlling person:
the first and last name of the controlling person;
the residential address of the controlling person;
every residence for a tax purpose of the controlling person;
if applicable, the taxpayer identification number (TIN) of the controlling person with respect to each residence mentioned in sub‑paragraph (C);
the date of birth of the controlling person; and
in any other case, a self‑certification that —
is signed or otherwise positively affirmed by the crypto‑asset user or a person with authority to sign for the crypto‑asset user;
states the date on which the self‑certification is signed or otherwise positively affirmed by the person mentioned in sub‑paragraph (i); and
contains the specified particulars of the crypto‑asset user.
“reportable jurisdiction” means a jurisdiction outside Singapore that is described as one on the IRAS Internet website;
“self‑certification”, in relation to a reporting Singaporean crypto‑asset service provider establishing a relationship with a crypto‑asset user, means a statement containing information —
relating to the crypto‑asset user that is reasonably required by the provider for the purpose of complying with regulations 11 and 12; and
provided by —
in a case where the crypto‑asset user is an entity crypto‑asset user other than an excluded person or an active entity, and the statement only contains information of the residences for a tax purpose of a controlling person of such entity crypto‑asset user — the entity crypto‑asset user or the controlling person; or
in any other case — the crypto‑asset user;
“specified particulars”, in relation to a crypto‑asset user, means the following particulars:
if the crypto‑asset user is an individual crypto‑asset user —
the first and last name of the individual;
the residential address of the individual;
every residence for a tax purpose of the individual;
if applicable, the taxpayer identification number (TIN) of the individual with respect to each residence mentioned in sub‑paragraph (iii); and
the date of birth of the individual; (b)if the crypto‑asset user is an entity crypto‑asset user other than an excluded person or an active entity —
the legal name of the entity;
the address of the entity that is registered with any public agency or the address at which the entity is carrying on its business;
every residence for a tax purpose of the entity;
if applicable, the taxpayer identification number (TIN) of the entity with respect to each residence mentioned in sub‑paragraph (iii); and
the following particulars with respect to each controlling person of the entity:
the first and last name of the controlling person;
the residential address of the controlling person;
every residence for a tax purpose of the controlling person;
if applicable, the taxpayer identification number (TIN) of the controlling person with respect to each residence mentioned in sub‑paragraph (C);
the date of birth of the controlling person;
if the crypto‑asset user is an entity that is an excluded person or an active entity —
the legal name of the entity;
the address of the entity that is registered with any public agency or the address at which the entity is carrying on its business;
every residence for a tax purpose of the entity;
if applicable, the taxpayer identification number (TIN) of the entity with respect to each residence mentioned in sub‑paragraph (iii); and
whether the entity is an excluded person or an active entity, and a description of the type of excluded person or active entity (as the case may be);
“valid self‑certification” means —
in a case where the crypto‑asset user is an entity crypto‑asset user other than an excluded person or an active entity, and the self‑certification only contains information of one or more residences for a tax purpose of a controlling person of the entity crypto‑asset user — a self‑certification that —
is signed or otherwise positively affirmed by the person making the self‑certification or a person with authority to sign for that person; (ii)states the date on which the self‑certification is signed or otherwise positively affirmed by the person mentioned in sub‑paragraph (i); and
contains the following particulars of the controlling person:
the first and last name of the controlling person;
the residential address of the controlling person;
every residence for a tax purpose of the controlling person;
if applicable, the taxpayer identification number (TIN) of the controlling person with respect to each residence mentioned in sub‑paragraph (C);
the date of birth of the controlling person; and
in any other case, a self‑certification that —
is signed or otherwise positively affirmed by the crypto‑asset user or a person with authority to sign for the crypto‑asset user;
states the date on which the self‑certification is signed or otherwise positively affirmed by the person mentioned in sub‑paragraph (i); and
contains the specified particulars of the crypto‑asset user.
Excluded persons
In this Part, “excluded person” means —
an entity the stock of which is regularly traded on one or more established securities markets or an entity that is a related entity of the firstmentioned entity;
a governmental entity;
the Monetary Authority of Singapore established under section 3 of the Monetary Authority of Singapore Act 1970;
a financial institution other than an Investment Entity described in subparagraph E(5)(b) of Section IV of the CARF; or
an international organisation.
For the purposes of paragraph (1)(a), “related entity” has the same meaning as “Related Entity” in subparagraph F(4) of Section IV of the CARF.
For the purposes of paragraph (1)(b), “governmental entity” has the same meaning as “Governmental Entity” in subparagraph E(7) of Section IV of the CARF, and includes —
the Government; (b)every Organ of State;
every entity that is wholly‑owned (whether directly or indirectly) and wholly‑controlled by the Minister for Finance (in his or her corporate capacity), including GIC Private Limited, GIC (Realty) Pte. Ltd., GIC (Ventures) Pte. Ltd., and their wholly‑owned subsidiaries;
every authority established by or under any public Act and whose income is exempt from tax by reason of section 13(1)(e) of the Act, and includes a Town Council established under the Town Councils Act 1988; and
every entity that is wholly‑owned (whether directly or indirectly) and wholly‑controlled by an authority mentioned in sub‑paragraph (d).
For the purpose of paragraph (1)(d), “financial institution” means —
a custodial institution;
a depository institution;
an investment entity; or
a specified insurance company.
For the purpose of paragraph (4)(a), “custodial institution” has the same meaning as “Custodial Institution” in subparagraph E(3) of Section IV of the CARF, and includes —
the holder of a capital markets services licence under the Securities and Futures Act 2001 for carrying out the regulated activity of providing custodial services for securities;
a person (other than an individual) that is exempt under section 99(1)(a) to (d), (g) and (h) of that Act (read with paragraph 6 of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations (Rg 10)), from the requirement to hold a capital markets services licence to carry out the regulated activity of providing custodial services for securities; and
a licensed trust company under the Trust Companies Act 2005.
An entity is not a custodial institution for the purposes of paragraph (5) if it is an active entity that meets the criteria in subparagraph D(11)(b) of Section IV of the CARF.
For the purpose of paragraph (4)(b), “depository institution” has the same meaning as “Depository Institution” in subparagraph E(4) of Section IV of the CARF, and includes —
a bank that holds a licence under section 7 or 79 of the Banking Act 1970;
a finance company licensed under the Finance Companies Act 1967; and
a merchant bank that holds a merchant bank licence, or is treated as having been granted a merchant bank licence, under the Banking Act 1970.
For the purpose of paragraph (4)(c), “investment entity” has the same meaning as “Investment Entity” in subparagraph E(5) of Section IV of the CARF, and includes —
the holder of a capital markets services licence under the Securities and Futures Act 2001 to carry out one or more of the following regulated activities:
dealing in capital markets products;
fund management;
real estate investment trust management;
a person (other than an individual) that is exempt under section 99(1)(a) to (d) and (h) of the Securities and Futures Act 2001 (read with paragraph 2, 3, 4 or 5 of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations), from the requirement to hold a capital markets services licence to carry out one or more of the regulated activities mentioned in sub‑paragraph (a); and
a licensed trust company under the Trust Companies Act 2005, but excludes —
an active entity that meets the criteria in subparagraph D(11)(b) to (e) of Section IV of the CARF; and (e)a person whose only business assets are immovable properties in which the person has a non‑debt, direct interest, namely, a direct interest that does not arise from any debt owed to the person.
In paragraph (8)(a), the expressions “dealing in capital markets products”, “fund management” and “real estate investment trust management” have the same meanings as in Part 2 of the Second Schedule to the Securities and Futures Act 2001.
Paragraph (8)(b) excludes a person who is exempt under section 99(1)(h) of the Securities and Futures Act 2001 (read with paragraph 2(1)(a) or (e) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations), from the requirement to hold a capital markets services licence to carry on business in dealing in capital markets products, and carries on business in dealing in capital markets products for the person’s own account.
For the purpose of paragraph (4)(d), “specified insurance company” has the same meaning as “Specified Insurance Company” in subparagraph E(6) of Section IV of the CARF, and includes a licensed insurer under the Insurance Act 1966 that issues, or is obligated to make payments with respect to, one or more cash value insurance contracts or annuity contracts.
Exemption
A reporting Singaporean crypto‑asset service provider is not required to comply with any requirement in this Part if it fulfils both the reporting requirement and due diligence requirement in Sections II and III of the CARF (as modified by regulation 4) respectively under the rules of a jurisdiction described in paragraph H of Section I of the CARF (as modified by regulation 4) that correspond to the firstmentioned requirement.
A reporting Singaporean crypto‑asset service provider mentioned in paragraph (1) must give a notification to the Comptroller in accordance with paragraph (3) that it has fulfilled the reporting and due diligence requirements in Sections II and III of the CARF (as modified by regulation 4) in the jurisdiction mentioned in paragraph (1).
The notification must be given in the form and manner specified by the Comptroller on the IRAS Internet website, by 31 May of the year immediately following the year in which the reporting and due diligence requirements are fulfilled.
In the case of a reporting Singaporean crypto‑asset service provider that is a trust, the notification must be given by the trustee of the reporting Singaporean crypto‑asset service provider.
A reporting Singaporean crypto‑asset service provider, or (in the case of a reporting Singaporean crypto‑asset service provider that is a trust) its trustee, must take all reasonable steps to ensure that its notification does not contain any information that is false in a material particular.
A requirement under paragraph (2) (read with paragraph (3)) or (5) is a requirement the failure or neglect to comply with which (if such failure or neglect is without reasonable excuse) is an offence under section 105M(1B) of the Act.
Due diligence obligation
A reporting Singaporean crypto‑asset service provider must establish and maintain the following arrangements in relation to each crypto‑asset user:
arrangements to establish all the residences for a tax purpose of —
the crypto‑asset user; and
where the crypto‑asset user is an entity crypto‑asset user other than an excluded person or an active entity — every controlling person of the entity crypto‑asset user;
arrangements to identify whether —
the crypto‑asset user is a reportable user; and (ii)where the crypto‑asset user is an entity crypto‑asset user other than an excluded person or an active entity — the crypto‑asset user has one or more controlling persons each of whom is a reportable person.
A reporting Singaporean crypto‑asset service provider must establish and maintain the arrangements mentioned in paragraph (1) in relation to each crypto‑asset user even if —
the residence for a tax purpose of the crypto‑asset user is not a reportable jurisdiction; or
where the crypto‑asset user is an entity crypto‑asset user other than an excluded person or an active entity — the residence for a tax purpose of any controlling person of the entity crypto‑asset user is not a reportable jurisdiction.
A reporting Singaporean crypto‑asset service provider is treated as having complied with paragraph (1) only if —
in establishing and maintaining such arrangements, the provider complies with the due diligence requirements in Section III of the CARF, as modified by regulation 4; and
where any provision in Section III of the CARF (as modified by regulation 4) requires anything to be obtained in respect of any relevant transaction effectuated for the crypto‑asset user — the provider keeps all information that is needed to explain the relevant transaction.
The reporting Singaporean crypto‑asset service provider must, in relation to any crypto‑asset user, ensure that all of the following are kept for the period mentioned in paragraph (5):
all evidence, record or information in relation to the crypto‑asset user and every relevant transaction effectuated for the crypto‑asset user that it has obtained in accordance with paragraph (3);
a record of the steps it has taken in accordance with paragraph (3) in relation to the crypto‑asset user and every relevant transaction effectuated for the crypto‑asset user.
In paragraph (4), the period is —
in the case of any evidence, record or information mentioned in paragraph (4)(a) that identifies the crypto‑asset user, is a document establishing a relationship with the crypto‑asset user, or is correspondence with the crypto‑asset user — 5 years after the end of the relationship with the crypto‑asset user; (b)in the case of any evidence, record or information mentioned in paragraph (4)(a) relating to any relevant transaction effectuated for the crypto‑asset user — 5 years after 31 December of the calendar year in which the reporting Singaporean crypto‑asset service provider is required to provide any information relating to the relevant transaction to the Comptroller under regulation 12(1); and
in the case of any record mentioned in paragraph (4)(b) — 5 years after 31 December of the calendar year in which the reporting Singaporean crypto‑asset service provider is required to provide any information relating to the crypto‑asset user and the relevant transaction effectuated for the crypto‑asset user to the Comptroller under regulation 12(1).
A reporting Singaporean crypto‑asset service provider must, on or before establishing a relationship with a person that is a crypto‑asset user —
obtain a valid self‑certification to determine whether the person is a reportable person, and confirm its reasonableness; and
in a case where the person is an entity crypto‑asset user other than an excluded person or an active entity — obtain one or more valid self‑certifications to determine whether each controlling person of the entity crypto‑asset user is a reportable person, and confirm the reasonableness of each valid self‑certification.
A reporting Singaporean crypto‑asset service provider must obtain a valid self‑certification, and confirm its reasonableness, from a crypto‑asset user that is a pre‑existing entity crypto‑asset user or a pre‑existing individual crypto‑asset user by 31 December 2027.
A reporting Singaporean crypto‑asset service provider must not effectuate any relevant transaction for any crypto‑asset user that is a pre‑existing entity crypto‑asset user or a pre‑existing individual crypto‑asset user on or after 1 January 2028, unless it has obtained a valid self‑certification, and confirmed its reasonableness, from the crypto‑asset user.
In the case of a reporting Singaporean crypto‑asset service provider that is a trust, a requirement under paragraph (1), (4), (6), (7) or (8) must be complied with by the trustee of the reporting Singaporean crypto‑asset service provider.
A requirement under paragraph (1), (4), (6), (7) or (8) is a requirement the failure or neglect to comply with which (if such failure or neglect is without reasonable excuse) is an offence under section 105M(1B) of the Act.
Reporting obligation
A reporting Singaporean crypto‑asset service provider must, in respect of calendar year 2027 and every following calendar year, prepare and provide to the Comptroller, or a person authorised by the Comptroller under section 105L(1) of the Act, a return setting out all the information that a reporting crypto‑asset service provider is required to report under Section II of the CARF, as modified by regulation 4.
If, during the calendar year in question, the reporting Singaporean crypto‑asset service provider has not effectuated any relevant transaction for any crypto‑asset user that is a reportable user or that has a controlling person that is a reportable person, the return under paragraph (1) must state that fact.
The reporting Singaporean crypto‑asset service provider must provide a return under this regulation to the Comptroller or a person authorised by the Comptroller under section 105L(1) of the Act, on or before 31 May of the year following the calendar year to which the return relates, or by such later date as the Comptroller may permit.
The return must be provided in the form and manner described on the IRAS Internet website.
A return which is made otherwise than in accordance with paragraphs (3) and (4) is treated as not having been made.
For the purpose of paragraph (1), the definitions in Section IV of the CARF apply as modified by regulation 4.
In the case of a reporting Singaporean crypto‑asset service provider that is a trust, a requirement under paragraph (1) (read with paragraphs (3) and (4)), or paragraph (2) (read with paragraphs (3) and (4)) must be complied with by the trustee of the provider.
A requirement under —
paragraph (1) (read with paragraphs (3) and (4)); or
paragraph (2) (read with paragraphs (3) and (4)),is a requirement under section 105M(1)(b) of the Act, the failure or neglect to comply with which (if such failure or neglect is without reasonable excuse) is an offence under section 105M(1) of the Act.
Appointment of agent
A reporting Singaporean crypto‑asset service provider may appoint a person as its agent to carry out on its behalf its obligations under regulations 11 and 12.
The person so appointed must, upon the reporting Singaporean crypto‑asset service provider’s request, provide the reporting Singaporean crypto‑asset service provider with —
all records, documentary evidence and information that is in the agent’s possession or under the agent’s control that the agent uses to carry out the provider’s obligations mentioned in paragraph (1); and
all records, documents and information that the agent obtains in the course of carrying out the provider’s obligations mentioned in paragraph (1).
To avoid doubt, the reporting Singaporean crypto‑asset service provider (or in the case of a trust, its trustee) remains responsible for any obligation that its agent carries out on its behalf.
THE SCHEDULE
Regulation 2(2)
CRYPTO‑ASSET REPORTING FRAMEWORK
Section I: Obligations of Reporting Crypto‑Asset Service Providers
A. A Reporting Crypto‑Asset Service Provider is subject to the reporting and
due diligence requirements in Sections II and III in [Jurisdiction], if it is:
1. an Entity or individual resident for tax purposes in [Jurisdiction];
2. an Entity that (a) is incorporated or organised under the laws of
[Jurisdiction] and (b) either has legal personality in [Jurisdiction] or has
an obligation to file tax returns or tax information returns to the tax
authorities in [Jurisdiction] with respect to the income of the Entity;
3. an Entity managed from [Jurisdiction]; or
4. an Entity or individual that has a regular place of business in [Jurisdiction].
B. A Reporting Crypto‑Asset Service Provider is subject to the reporting and
due diligence requirements in Sections II and III in [Jurisdiction] with respect to
Relevant Transactions effectuated through a Branch based in [Jurisdiction].
S 551/2026
C. A Reporting Crypto‑Asset Service Provider that is an Entity is not required to
complete the reporting and due diligence requirements in Sections II and III it is
subject to in [Jurisdiction] pursuant to subparagraphs A(2), (3) or (4), if such
requirements are completed by such Reporting Crypto‑Asset Service Provider in
a Partner Jurisdiction by virtue of it being resident for tax purposes in such
Partner Jurisdiction.
D. A Reporting Crypto‑Asset Service Provider that is an Entity is not required to
complete the reporting and due diligence requirements in Sections II and III it is
subject to in [Jurisdiction] pursuant to subparagraphs A(3) or (4), if such
requirements are completed by such Reporting Crypto‑Asset Service Provider in
a Partner Jurisdiction by virtue of it being an Entity that (a) is incorporated or
organised under the laws of such Partner Jurisdiction and (b) either has legal
personality in the Partner Jurisdiction or has an obligation to file tax returns or
tax information returns to the tax authorities in the Partner Jurisdiction with
respect to the income of the Entity.
E. A Reporting Crypto‑Asset Service Provider that is an Entity is not required to
complete the reporting and due diligence requirements in Sections II and III it is
subject to in [Jurisdiction] pursuant to subparagraph A(4), if such requirements
are completed by such Reporting Crypto‑Asset Service Provider in a Partner
Jurisdiction by virtue of it being managed from such Partner Jurisdiction.
F.
A Reporting Crypto‑Asset Service Provider that is an individual is not
required to complete the reporting and due diligence requirements in Sections II
and III it is subject to in [Jurisdiction] pursuant to subparagraph A(4), if such
requirements are completed by such Reporting Crypto‑Asset Service Provider in
a Partner Jurisdiction by virtue of it being resident for tax purposes in such
Partner Jurisdiction.
G. A Reporting Crypto‑Asset Service Provider is not required to complete the
reporting and due diligence requirements in Sections II and III in [Jurisdiction]
with respect to Relevant Transactions it effectuates through a Branch in a Partner
Jurisdiction, if such requirements are completed by such Branch in such Partner
Jurisdiction.
H. A Reporting Crypto‑Asset Service Provider is not required to complete the
reporting and due diligence requirements in Sections II and III it is subject to in
[Jurisdiction] pursuant to subparagraphs A(1), (2), (3) or (4), if it has lodged a
notification with [Jurisdiction] in a format specified by [Jurisdiction] confirming
that such requirements are completed by such Reporting Crypto‑Asset Service
Provider under the rules of a Partner Jurisdiction pursuant a substantially similar
nexus that it is subject to in [Jurisdiction].
S 551/2026
Section II: Reporting requirements
A. For each relevant calendar year or other appropriate reporting period, and
subject to the obligations of Reporting Crypto‑Asset Service Providers in
Section I and the due diligence procedures in Section III, a Reporting
Crypto‑Asset Service Provider must report the following information with
respect to its Crypto‑Asset Users that are Reportable Users or that have
Controlling Persons that are Reportable Persons:
1. the name, address, jurisdiction(s) of residence, TIN(s) and date and place of
birth (in the case of an individual) of each Reportable User and, in the case
of any Entity that, after application of the due diligence procedures, is
identified as having one or more Controlling Persons that is a Reportable
Person, the name, address, jurisdiction(s) of residence and TIN(s) of the
Entity and the name, address, jurisdiction(s) of residence, TIN(s) and date
and place of birth of each Reportable Person, as well as the role(s) by virtue
of which each Reportable Person is a Controlling Person of the Entity;
2. the name, address and identifying number (if any) of the Reporting
Crypto‑Asset Service Provider;
3. for each type of Relevant Crypto‑Asset with respect to which it has
effectuated Relevant Transactions during the relevant calendar year or other
appropriate reporting period:
the full name of the type of Relevant Crypto‑Asset;
the aggregate gross amount paid, the aggregate number of units and the
number of Relevant Transactions in respect of acquisitions against Fiat
Currency;
the aggregate gross amount received, the aggregate number of units
and the number of Relevant Transactions in respect of disposals against
Fiat Currency;
the aggregate fair market value, the aggregate number of units and the
number of Relevant Transactions in respect of acquisitions against
other Relevant Crypto‑Assets;
the aggregate fair market value, the aggregate number of units and the
number of Relevant Transactions in respect of disposals against other
Relevant Crypto‑Assets;
the aggregate fair market value, the aggregate number of units and the
number of Reportable Retail Payment Transactions;
the aggregate fair market value, the aggregate number of units and the
number of Relevant Transactions, and subdivided by Transfer type
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where known by the Reporting Crypto‑Asset Service Provider, in
respect of Transfers to the Reportable User not covered by
subparagraphs A(3)(b) and (d);
the aggregate fair market value, the aggregate number of units and the
number of Relevant Transactions, and subdivided by Transfer type
where known by the Reporting Crypto‑Asset Service Provider, in
respect of Transfers by the Reportable User not covered by
subparagraphs A(3)(c), (e) and (f); and
the aggregate fair market value, as well as the aggregate number of
units in respect of Transfers by the Reportable Crypto‑Asset User
effectuated by the Reporting Crypto‑Asset Service Provider to wallet
addresses not known by the Reporting Crypto‑Asset Service Provider
to be associated with a virtual asset service provider or financial
institution.
B. Notwithstanding subparagraph A(1), the TIN is not required to be reported if
a TIN is not issued by the relevant Reportable Jurisdiction or (ii) the domestic
law of the relevant Reportable Jurisdiction does not require the collection of the
TIN issued by such Reportable Jurisdiction.
C. Notwithstanding subparagraph A(1), the place of birth is not required to be
reported unless the Reporting Crypto‑Asset Service Provider is otherwise
required to obtain and report it under domestic law.
D.
For the purposes of subparagraphs A(3)(b) and (c), the amount paid or
received must be reported in the Fiat Currency in which it was paid or received.
In case the amounts were paid or received in multiple Fiat Currencies, the
amounts must be reported in a single Fiat Currency, converted at the time of each
Relevant Transaction in a manner that is consistently applied by the Reporting
Crypto‑Asset Service Provider.
E. For the purposes of subparagraphs A(3)(d) through (i), the fair market value
must be determined and reported in a single Fiat Currency, valued at the time of
each Relevant Transaction in a manner that is consistently applied by the
Reporting Crypto‑Asset Service Provider.
F.
The information reported must identify the Fiat Currency in which each
amount is reported.
G. The information pursuant to paragraph A must be reported by xx/xx of the
calendar year following the year to which the information relates.
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Section III: Due diligence procedures
A Crypto‑Asset User is treated as a Reportable User beginning as of the date it is
identified as such pursuant to the due diligence procedures described in this
Section.
A. Due diligence procedures for Individual Crypto‑Asset Users
The following procedures apply for purposes of determining whether the
Individual Crypto‑Asset User is a Reportable User.
1. When establishing the relationship with the Individual Crypto‑Asset User,
or with respect to Preexisting Individual Crypto‑Asset Users by 12 months
after the effective date of these rules, the Reporting Crypto‑Asset Service
Provider must obtain a self‑certification that allows the Reporting
Crypto‑Asset Service Provider to determine the Individual Crypto‑Asset
User’s residence(s) for tax purposes and confirm the reasonableness of such
self‑certification based on the information obtained by the Reporting
Crypto‑Asset Service Provider, including any documentation collected
pursuant to AML/KYC Procedures.
2. If at any point there is a change of circumstances with respect to an
Individual Crypto‑Asset User that causes the Reporting Crypto‑Asset
Service Provider to know, or have reason to know, that the original
self‑certification is incorrect or unreliable, the Reporting Crypto‑Asset
Service Provider cannot rely on the original self‑certification and must
obtain a valid self‑certification, or a reasonable explanation and, where
appropriate, documentation supporting the validity of the original
self‑certification.
B. Due diligence procedures for Entity Crypto‑Asset Users
The following procedures apply for purposes of determining whether the Entity
Crypto‑Asset User is a Reportable User or an Entity, other than an Excluded
Person or an Active Entity, with one or more Controlling Persons who are
Reportable Persons.
1. Determine whether the Entity Crypto‑Asset User is a Reportable User.
When establishing the relationship with the Entity Crypto‑Asset User,
or with respect to Preexisting Entity Crypto‑Assets Users by 12 months
after the effective date of these rules, the Reporting Crypto‑Asset
Service Provider must obtain a self‑certification that allows the
Reporting Crypto‑Asset Service Provider to determine the Entity
Crypto‑Asset User’s residence(s) for tax purposes and confirm the
reasonableness of such self‑certification based on the information
obtained by the Reporting Crypto‑Asset Service Provider, including
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any documentation collected pursuant to AML/KYC Procedures. If the
Entity Crypto‑Asset User certifies that it has no residence for tax
purposes, the Reporting Crypto‑Asset Service Provider may rely on the
place of effective management or on the address of the principal office
to determine the residence of the Entity Crypto‑Asset User.
If the self‑certification indicates that the Entity Crypto‑Asset User is
resident in a Reportable Jurisdiction, the Reporting Crypto‑Asset
Service Provider must treat the Entity Crypto‑Asset User as a
Reportable User, unless it reasonably determines based on the
self‑certification or on information in its possession or that is
publicly available, that the Entity Crypto‑Asset User is an Excluded
Person.
2. Determine whether the Entity has one or more Controlling Persons
who are Reportable Persons.
With respect to an Entity Crypto‑Asset User, other than an Excluded
Person, the Reporting Crypto‑Asset Service Provider must determine
whether it has one or more Controlling Persons who are Reportable
Persons, unless it determines that the Entity Crypto‑Asset User is an Active
Entity, based on a self‑certification from the Entity Crypto‑Asset User.
Determining the Controlling Persons of the Entity Crypto‑Asset User.
For the purposes of determining the Controlling Persons of the Entity
Crypto‑Asset User, a Reporting Crypto‑Asset Service Provider may
rely on information collected and maintained pursuant to AML/KYC
Procedures, provided that such procedures are consistent with the 2012
FATF Recommendations (as updated in June 2019 pertaining to virtual
asset service providers). If the Reporting Crypto‑Asset Service
Provider is not legally required to apply AML/KYC Procedures that
are consistent with the 2012 FATF Recommendations (as updated in
June 2019 pertaining to virtual asset service providers), it must apply
substantially similar procedures for the purposes of determining the
Controlling Persons.
Determining whether a Controlling Person of an Entity Crypto‑Asset
User is a Reportable Person. For the purposes of determining whether a
Controlling Person is a Reportable Person, a Reporting Crypto‑Asset
Service Provider must rely on a self‑certification from the Entity
Crypto‑Asset User or such Controlling Person that allows the
Reporting
Crypto‑Asset
Service
Provider
to
determine
the
Controlling Person’s residence(s) for tax purposes and confirm the
reasonableness of such self‑certification based on the information
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obtained by the Reporting Crypto‑Asset Service Provider, including
any documentation collected pursuant to AML/KYC Procedures.
3. If at any point there is a change of circumstances with respect to an Entity
Crypto‑Asset User or its Controlling Persons that causes the Reporting
Crypto‑Asset Service Provider to know, or have reason to know, that the
original
self‑certification is incorrect
or unreliable,
the Reporting
Crypto‑Asset
Service
Provider
cannot
rely
on
the
original
self‑certification
and
must
obtain
a
valid
self‑certification,
or
a
reasonable
explanation
and,
where
appropriate,
documentation
supporting the validity of the original self‑certification.
C. Requirements for validity of self‑certifications
1. A self‑certification provided by an Individual Crypto‑Asset User or
Controlling Person is valid only if it is signed or otherwise positively
affirmed by the Individual Crypto‑Asset User or Controlling Person, it is
dated at the latest at the date of receipt and it contains the following
information with respect to the Individual Crypto‑Asset User or Controlling
Person:
first and last name;
residence address;
jurisdiction(s) of residence for tax purposes;
with respect to each Reportable Person, the TIN with respect to each
Reportable Jurisdiction; and
date of birth.
2. A self‑certification provided by an Entity Crypto‑Asset User is valid only if
it is signed or otherwise positively affirmed by the Crypto‑Asset User, it is
dated at the latest at the date of receipt and it contains the following
information with respect to the Entity Crypto‑Asset User:
legal name;
address;
jurisdiction(s) of residence for tax purposes;
with respect to each Reportable Person, the TIN with respect to each
Reportable Jurisdiction;
in case of an Entity Crypto‑Asset User other than an Active Entity or an
Excluded Person, the information described in subparagraph C(1) with
respect to each Controlling Person of the Entity Crypto‑Asset User,
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unless such Controlling Person has provided a self‑certification
pursuant to subparagraph C(1), as well as the role(s) by virtue of
which each Reportable Person is a Controlling Person of the Entity, if
not already determined on the basis of AML/KYC Procedures; and
if applicable, information as to the criteria it meets to be treated as an
Active Entity or Excluded Person.
3. Notwithstanding subparagraphs C(1) and (2), the TIN is not required to be
collected if the jurisdiction of residence of the Reportable Person does not
issue a TIN to the Reportable Person, or the domestic law of the relevant
Reportable Jurisdiction does not require the collection of the TIN issued by
such Reportable Jurisdiction.
D. General due diligence requirements
1. A Reporting Crypto‑Asset Service Provider that is also a Financial
Institution for the purposes of the Common Reporting Standard may rely on
the due diligence procedures completed pursuant to Sections IV and VI of
the Common Reporting Standard for the purpose of the due diligence
procedures pursuant to this Section. A Reporting Crypto‑Asset Service
Provider may also rely on a self‑certification already collected for other tax
purposes, provided such self‑certification meets the requirements of
paragraph C of this Section.
2. A Reporting Crypto‑Asset Service Provider may rely on a third party to
fulfil the due diligence obligations set out in this Section III, but such
obligations remain the responsibility of the Reporting Crypto‑Asset Service
Provider.
3. A Reporting Crypto‑Asset Service Provider is required to maintain all
documentation and data for a period of not less than five years after the end
of the period within which the Reporting Crypto‑Asset Service Provider
must report the information required to be reported pursuant to Section II.
Section IV: Defined Terms
The following terms have the meanings set forth below:
A. Relevant Crypto‑Asset
1. The term “Crypto‑Asset” means a digital representation of value that relies
on a cryptographically secured distributed ledger or a similar technology to
validate and secure transactions.
2. The term “Relevant Crypto‑Asset” means any Crypto‑Asset that is not a
Central Bank Digital Currency, a Specified Electronic Money Product or
any Crypto‑Asset for which the Reporting Crypto‑Asset Service Provider
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has adequately determined that it cannot be used for payment or investment
purposes.
3. The term “Central Bank Digital Currency” means any digital Fiat Currency
issued by a Central Bank.
4. The term “Specified Electronic Money Product” means any Crypto‑Asset
that is:
a digital representation of a single Fiat Currency;
issued on receipt of funds for the purpose of making payment
transactions;
represented by a claim on the issuer denominated in the same Fiat
Currency;
accepted in payment by a natural or legal person other than the issuer;
and
by virtue of regulatory requirements to which the issuer is subject,
redeemable at any time and at par value for the same Fiat Currency
upon request of the holder of the product.
The term “Specified Electronic Money Product” does not include a
product created for the sole purpose of facilitating the transfer of funds
from a customer to another person pursuant to instructions of the
customer. A product is not created for the sole purpose of facilitating
the transfer of funds if, in the ordinary course of business of the
transferring Entity, either the funds connected with such product are
held longer than 60 days after receipt of instructions to facilitate the
transfer, or, if no instructions are received, the funds connected with
such product are held longer than 60 days after receipt of the funds.
B. Reporting Crypto‑Asset Service Provider
1. The term “Reporting Crypto‑Asset Service Provider” means any individual
or Entity that, as a business, provides a service effectuating Exchange
Transactions for or on behalf of customers, including by acting as a
counterparty, or as an intermediary, to such Exchange Transactions, or by
making available a trading platform.
C. Relevant Transaction
1. The term “Relevant Transaction” means any:
Exchange Transaction; and
Transfer of Relevant Crypto‑Assets.
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2. The term “Exchange Transaction” means any:
exchange between Relevant Crypto‑Assets and Fiat Currencies; and
exchange between one or more forms of Relevant Crypto‑Assets.
3. The term “Reportable Retail Payment Transaction” means a Transfer of
Relevant Crypto‑Assets in consideration of goods or services for a value
exceeding USD 50 000.
4. The term “Transfer” means a transaction that moves a Relevant
Crypto‑Asset from or to the Crypto‑Asset address or account of one
Crypto‑Asset
User,
other
than
one
maintained
by
the
Reporting
Crypto‑Asset Service Provider on behalf of the same Crypto‑Asset User,
where, based on the knowledge available to the Reporting Crypto‑Asset
Service Provider at the time of transaction, the Reporting Crypto‑Asset
Service Provider cannot determine that the transaction is an Exchange
Transaction.
5. The term “Fiat Currency” means the official currency of a jurisdiction,
issued by a jurisdiction or by a jurisdiction’s designated Central Bank or
monetary authority, as represented by physical banknotes or coins or by
money in different digital forms, including bank reserves and Central Bank
Digital Currencies. The term also includes commercial bank money and
electronic
money
products
(including
Specified
Electronic
Money
Products).
D. Reportable User
1. The term “Reportable User” means a Crypto‑Asset User that is a
Reportable Person.
2. The term “Crypto‑Asset User” means an individual or Entity that is a
customer of a Reporting Crypto‑Asset Service Provider for purposes of
carrying out Relevant Transactions. An individual or Entity, other than a
Financial Institution or a Reporting Crypto‑Asset Service Provider, acting
as a Crypto‑Asset User for the benefit or account of another individual or
Entity as agent, custodian, nominee, signatory, investment advisor, or
intermediary, is not treated as a Crypto‑Asset User, and such other
individual or Entity is treated as the Crypto‑Asset User. Where a Reporting
Crypto‑Asset Service Provider provides a service effectuating Reportable
Retail Payment Transactions for or on behalf of a merchant, the Reporting
Crypto‑Asset Service Provider must also treat the customer that is the
counterparty to the merchant for such Reportable Retail Payment
Transaction as the Crypto‑Asset User with respect to such Reportable
Retail Payment Transaction, provided that the Reporting Crypto‑Asset
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Service Provider is required to verify the identity of such customer by virtue
of the Reportable Retail Payment Transaction pursuant to domestic
anti‑money laundering rules.
3. The term “Individual Crypto‑Asset User” means a Crypto‑Asset User that
is an individual.
4. The term “Preexisting Individual Crypto‑Asset User” means an Individual
Crypto‑Asset User that has established a relationship with the Reporting
Crypto‑Asset Service Provider as of [xx/xx/xxxx].
5. The term “Entity Crypto‑Asset User” means a Crypto‑Asset User that is an
Entity.
6. The term “Preexisting Entity Crypto‑Asset User” means an Entity
Crypto‑Asset User that has established a relationship with the Reporting
Crypto‑Asset Service Provider as of [xx/xx/xxxx].
7. The term “Reportable Person” means a Reportable Jurisdiction Person
other than an Excluded Person.
8. The term “Reportable Jurisdiction Person” means an Entity or individual
that is resident in a Reportable Jurisdiction under the tax laws of such
jurisdiction, or an estate of a decedent that was a resident of a Reportable
Jurisdiction. For this purpose, an Entity such as a partnership, limited
liability partnership or similar legal arrangement that has no residence for
tax purposes shall be treated as resident in the jurisdiction in which its place
of effective management is situated.
9. The term “Reportable Jurisdiction” means any jurisdiction (a) with which
an agreement or arrangement is in effect pursuant to which [Jurisdiction] is
obligated to provide the information specified in Section II with respect to
Reportable Persons resident in such jurisdiction, and (b) which is identified
as such in a list published by [Jurisdiction].
10. The term “Controlling Persons” means the natural persons who exercise
control over an Entity. In the case of a trust, such term means the settlor(s),
the trustee(s), the protector(s) (if any), the beneficiary(ies) or class(es) of
beneficiaries, and any other natural person(s) exercising ultimate effective
control over the trust, and in the case of a legal arrangement other than a
trust, such term means persons in equivalent or similar positions. The term
“Controlling Persons” must be interpreted in a manner consistent with the
2012 Financial Action Task Force Recommendations, as updated in
June 2019 pertaining to virtual asset service providers.
11. The term “Active Entity” means any Entity that meets any of the following
criteria:
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less than 50% of the Entity’s gross income for the preceding calendar
year or other appropriate reporting period is passive income and less
than 50% of the assets held by the Entity during the preceding calendar
year or other appropriate reporting period are assets that produce or are
held for the production of passive income;
substantially all of the activities of the Entity consist of holding (in
whole or in part) the outstanding stock of, or providing financing and
services to, one or more subsidiaries that engage in trades or businesses
other than the business of a Financial Institution, except that an Entity
does not qualify for this status if the Entity functions (or holds itself
out) as an investment fund, such as a private equity fund, venture
capital fund, leveraged buyout fund, or any investment vehicle whose
purpose is to acquire or fund companies and then hold interests in those
companies as capital assets for investment purposes;
the Entity is not yet operating a business and has no prior operating
history, but is investing capital into assets with the intent to operate a
business other than that of a Financial Institution, provided that the
Entity does not qualify for this exception after the date that is
24 months after the date of the initial organisation of the Entity;
the Entity was not a Financial Institution in the past five years, and is in
the process of liquidating its assets or is reorganising with the intent to
continue or recommence operations in a business other than that of a
Financial Institution;
the Entity primarily engages in financing and hedging transactions
with, or for, Related Entities that are not Financial Institutions, and
does not provide financing or hedging services to any Entity that is not
a Related Entity, provided that the group of any such Related Entities is
primarily engaged in a business other than that of a Financial
Institution; or
the Entity meets all of the following requirements:
it is established and operated in its jurisdiction of residence
exclusively for religious, charitable, scientific, artistic, cultural,
athletic, or educational purposes; or it is established and operated
in its jurisdiction of residence and it is a professional
organisation, business league, chamber of commerce, labour
organisation, agricultural or horticultural organisation, civic
league
or
an
organisation
operated
exclusively
for
the
promotion of social welfare;
it is exempt from income tax in its jurisdiction of residence;
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it has no shareholders or members who have a proprietary or
beneficial interest in its income or assets;
the applicable laws of the Entity’s jurisdiction of residence or the
Entity’s formation documents do not permit any income or assets
of the Entity to be distributed to, or applied for the benefit of, a
private person or non‑charitable Entity other than pursuant to the
conduct of the Entity’s charitable activities, or as payment of
reasonable compensation for services rendered, or as payment
representing the fair market value of property which the Entity
has purchased; and
the applicable laws of the Entity’s jurisdiction of residence or the
Entity’s formation documents require that, upon the Entity’s
liquidation or dissolution, all of its assets be distributed to a
Governmental Entity or other non‑profit organisation, or escheat
to the government of the Entity’s jurisdiction of residence or any
political subdivision thereof.
E. Excluded Person
1. The term “Excluded Person” means (a) an Entity the stock of which is
regularly traded on one or more established securities markets; (b) any
Entity that is a Related Entity of an Entity described in clause (a); (c) a
Governmental Entity; (d) an International Organisation; (e) a Central Bank;
or (f) a Financial Institution other than an Investment Entity described in
Section IV E(5)(b).
2. The term “Financial Institution” means a Custodial Institution, a
Depository Institution, an Investment Entity, or a Specified Insurance
Company.
3. The term “Custodial Institution” means any Entity that holds, as a
substantial portion of its business, Financial Assets for the account of
others. An Entity holds Financial Assets for the account of others as a
substantial portion of its business if the Entity’s gross income attributable to
the holding of Financial Assets and related financial services equals or
exceeds 20% of the Entity’s gross income during the shorter of: (i) the
three‑year period that ends on 31 December (or the final day of a
non‑calendar year accounting period) prior to the year in which the
determination is being made; or (ii) the period during which the Entity has
been in existence.
4. The term “Depository Institution” means any Entity that:
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accepts deposits in the ordinary course of a banking or similar
business; or
holds Specified Electronic Money Products or Central Bank Digital
Currencies for the benefit of customers.
5. The term “Investment Entity” means any Entity:
that primarily conducts as a business one or more of the following
activities or operations for or on behalf of a customer:
trading in money market instruments (cheques, bills, certificates
of deposit, derivatives, etc.); foreign exchange; exchange,
interest rate and index instruments; transferable securities; or
commodity futures trading;
individual and collective portfolio management; or
otherwise investing, administering, or managing Financial
Assets, money, or Relevant Crypto‑Assets on behalf of other
persons; or
the gross income of which is primarily attributable to investing,
reinvesting, or trading in Financial Assets or Relevant Crypto‑Assets,
if the Entity is managed by another Entity that is a Depository
Institution, a Custodial Institution, a Specified Insurance Company, or
an Investment Entity described in subparagraph E(5)(a).
An Entity is treated as primarily conducting as a business one or more of the
activities described in subparagraph E(5)(a), or an Entity’s gross income is
primarily attributable to investing, reinvesting, or trading in Financial
Assets or Relevant Crypto‑Assets for purposes of subparagraph E(5)(b), if
the Entity’s gross income attributable to the relevant activities equals or
exceeds 50% of the Entity’s gross income during the shorter of: (i) the
three‑year period ending on 31 December of the year preceding the year in
which the determination is made; or (ii) the period during which the Entity
has been in existence. For the purposes of subparagraph E(5)(a)(iii), the
term “otherwise investing, administering, or managing Financial Assets,
money, or Relevant Crypto‑Assets on behalf of other persons” does not
include the provision of services effectuating Exchange Transactions for or
on behalf of customers. The term “Investment Entity” does not include an
Entity that is an Active Entity because it meets any of the criteria in
subparagraphs D(11)(b) through (e).
This paragraph shall be interpreted in a manner consistent with similar
language set forth in the definition of “financial institution” in the Financial
Action Task Force Recommendations.
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6. The term “Specified Insurance Company” means any Entity that is an
insurance company (or the holding company of an insurance company) that
issues, or is obligated to make payments with respect to, a Cash Value
Insurance Contract or an Annuity Contract.
7. The term “Governmental Entity” means the government of a jurisdiction,
any political subdivision of a jurisdiction (which, for the avoidance of
doubt, includes a state, province, county, or municipality), or any wholly
owned agency or instrumentality of a jurisdiction or of any one or more of
the foregoing. This category is comprised of the integral parts, controlled
entities, and political subdivisions of a jurisdiction.
An “integral part” of a jurisdiction means any person, organisation,
agency, bureau, fund, instrumentality, or other body, however
designated, that constitutes a governing authority of a jurisdiction.
The net earnings of the governing authority must be credited to its own
account or to other accounts of the jurisdiction, with no portion inuring
to the benefit of any private person.
An integral part does not include any individual who is a sovereign,
official, or administrator acting in a private or personal capacity.
A controlled entity means an Entity that is separate in form from the
jurisdiction or that otherwise constitutes a separate juridical entity,
provided that:
the Entity is wholly owned and controlled by one or more
Governmental Entities directly or through one or more
controlled entities;
the Entity’s net earnings are credited to its own account or to
the accounts of one or more Governmental Entities, with no
portion of its income inuring to the benefit of any private
person; and
the Entity’s assets vest in one or more Governmental
Entities upon dissolution.
Income does not inure to the benefit of private persons if such persons
are the intended beneficiaries of a governmental programme, and the
programme activities are performed for the general public with respect
to the common welfare or relate to the administration of some phase of
government. Notwithstanding the foregoing, however, income is
considered to inure to the benefit of private persons if the income is
derived from the use of a governmental entity to conduct a commercial
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business, such as a commercial banking business, that provides
financial services to private persons.
8. The
term
“International
Organisation”
means
any
international
organisation or wholly owned agency or instrumentality thereof. This
category
includes
any intergovernmental organisation
(including
a
supranational
organisation)
(a)
that
is
comprised
primarily
of
governments; (b) that has in effect a headquarters or substantially similar
agreement with the jurisdiction; and (c) the income of which does not inure
to the benefit of private persons.
9. The term “Central Bank” means an institution that is by law or government
sanction the principal authority, other than the government of the
jurisdiction itself, issuing instruments intended to circulate as currency.
Such an institution may include an instrumentality that is separate from the
government of the jurisdiction, whether or not owned in whole or in part by
the jurisdiction.
10. The term “Financial Asset” includes a security (for example, a share of
stock in a corporation; partnership or beneficial ownership interest in a
widely held or publicly traded partnership or trust; note, bond, debenture, or
other evidence of indebtedness), partnership interest, commodity, swap (for
example, interest rate swaps, currency swaps, basis swaps, interest rate
caps, interest rate floors, commodity swaps, equity swaps, equity index
swaps, and similar agreements), Insurance Contract or Annuity Contract, or
any interest (including a futures or forward contract or option) in a security,
Relevant Crypto‑Asset, partnership interest, commodity, swap, Insurance
Contract, or Annuity Contract. The term “Financial Asset” does not include
a non‑debt, direct interest in real property.
11. The term “Equity Interest” means, in the case of a partnership that is a
Financial Institution, either a capital or profits interest in the partnership. In
the case of a trust that is a Financial Institution, an Equity Interest is
considered to be held by any person treated as a settlor or beneficiary of all
or a portion of the trust, or any other natural person exercising ultimate
effective control over the trust. A Reportable Person will be treated as being
a beneficiary of a trust if such Reportable Person has the right to receive
directly or indirectly (for example, through a nominee) a mandatory
distribution or may receive, directly or indirectly, a discretionary
distribution from the trust.
12. The term “Insurance Contract” means a contract (other than an Annuity
Contract) under which the issuer agrees to pay an amount upon the
occurrence of a specified contingency involving mortality, morbidity,
accident, liability, or property risk.
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13. The term “Annuity Contract” means a contract under which the issuer
agrees to make payments for a period of time determined in whole or in part
by reference to the life expectancy of one or more individuals. The term
also includes a contract that is considered to be an Annuity Contract in
accordance with the law, regulation, or practice of the jurisdiction in which
the contract was issued, and under which the issuer agrees to make
payments for a term of years.
14. The term “Cash Value Insurance Contract” means an Insurance Contract
(other than an indemnity reinsurance contract between two insurance
companies) that has a Cash Value.
15. The term “Cash Value” means the greater of (i) the amount that the
policyholder is entitled to receive upon surrender or termination of the
contract (determined without reduction for any surrender charge or policy
loan), and (ii) the amount the policyholder can borrow under or with regard
to the contract. Notwithstanding the foregoing, the term “Cash Value” does
not include an amount payable under an Insurance Contract:
solely by reason of the death of an individual insured under a life
insurance contract;
as a personal injury or sickness benefit or other benefit providing
indemnification of an economic loss incurred upon the occurrence of
the event insured against;
as a refund of a previously paid premium (less cost of insurance
charges whether or not actually imposed) under an Insurance Contract
(other than an investment‑linked life insurance or annuity contract) due
to cancellation or termination of the contract, decrease in risk exposure
during the effective period of the contract, or arising from the
correction of a posting or similar error with regard to the premium for
the contract;
as a policyholder dividend (other than a termination dividend)
provided that the dividend relates to an Insurance Contract under
which
the
only
benefits
payable
are
described
in
subparagraph E(15)(b); or
as a return of an advance premium or premium deposit for an Insurance
Contract for which the premium is payable at least annually if the
amount of the advance premium or premium deposit does not exceed
the next annual premium that will be payable under the contract.
S 551/2026
F. Miscellaneous
1. The term “Partner Jurisdiction” means any jurisdiction that has put in place
equivalent legal requirements and that is included in a list published by
[Jurisdiction].
2. The term “AML/KYC Procedures” means the customer due diligence
procedures of a Reporting Crypto‑Asset Service Provider pursuant to the
anti‑money laundering or similar requirements to which such Reporting
Crypto‑Asset Service Provider is subject.
3. The term “Entity” means a legal person or a legal arrangement, such as a
corporation, partnership, trust, or foundation.
4. An Entity is a “Related Entity” of another Entity if either Entity controls the
other Entity, or the two Entities are under common control. For this purpose
control includes direct or indirect ownership of more than 50% of the vote
and value in an Entity.
5. The term “TIN” means Taxpayer Identification Number (or functional
equivalent in the absence of a Taxpayer Identification Number).
6. The term “Branch” means a unit, business or office of a Reporting
Crypto‑Asset Service Provider that is treated as a branch under the
regulatory regime of a jurisdiction or that is otherwise regulated under the
laws of a jurisdiction as separate from other offices, units, or branches of
the Reporting Crypto-Asset Service Provider. All units, businesses, or
offices of a Reporting Crypto‑Asset Service Provider in a single jurisdiction
shall be treated as a single branch.
Section V: Effective implementation
A jurisdiction must have rules and administrative procedures in place to ensure
effective implementation of, and compliance with, the reporting and due
diligence procedures set out above.
S 551/2026
Made on 11 August 2026.
NGIAM SIEW YING
Second Permanent Secretary,
Ministry of Finance,
Singapore.
[AG/LEGIS/SL/134/2025/27]
S 551/2026
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