2.     Compliance Support

We assist crypto exchanges in establishing and reviewing their compliance frameworks, including:

• Advice on Know Your Customer and Anti-Money Laundering requirements;
• Review of existing KYC and AML procedures and compliance handbooks;
• Drafting of KYC and AML procedures, policies and supporting documentation;
• Compliance and best-practices framework advisory; and
• Advice on compliance with applicable MAS requirements.

3.     Token Listing Support

We advise crypto exchanges on the legal and regulatory considerations relating to tokens proposed for listing, including:

• Legal classification of tokens proposed for listing;
• Regulatory review of new tokens and digital assets before they are made available on the exchange; and
• Legal support for token listings and Initial Exchange Offerings.

4.     Exchange and Platform Documentation

We prepare and review documentation required for the operation of crypto exchanges, including:

• Exchange and platform terms and conditions;
• Token agreements;
• Commercial and business services agreements;
• Prospectuses and white papers;
• Customer-facing terms and regulatory disclosures; and
• Documentation that complies with Singapore law and, through coordination with overseas counsel, the laws of other jurisdictions.

5.     Exchange Set-Up and Structuring

For crypto exchanges establishing or expanding their Singapore operations, we provide assistance with:

• Structuring the Singapore entity through which the exchange will operate;
• Singapore company incorporation;
• Aligning the proposed corporate structure with the exchange’s licensing and regulatory requirements;
• Structuring related entities or initiatives established by the exchange; and
• Coordinating cross-border legal and regulatory advice through KGP’s international network.

6.     Crypto Exchange Disputes and Asset Recovery

We assist crypto exchanges with disputes and incidents involving digital assets, including:

• Disputes involving customers, counterparties and technology service providers;
• Fraud and unauthorised digital asset transfers;
• Crypto asset tracing and recovery;
• Applications for freezing orders and other urgent court relief; and
• Representation in mediation, arbitration and litigation.