After looking at the anxious crowd, I still want to mention Singapore's "Guidelines on Licensing for Digital Token Service Providers" (DTSP), which was actually introduced in 2022 and will only be "officially implemented" on June 30, 2025

Before getting to the main point, disclaimer: This is just an overview, and I am not legally responsible for the following statements. Please consult a professional lawyer

Here are the main points of concern:

1. In or From Singapore

Regardless of whether you serve Singapore users or have a physical entity in Singapore, you may be deemed to be "providing services in or from Singapore" and thus subject to regulation:

a. Core development/operations team is located in Singapore;

b. Servers or hosting systems are set up in Singapore;

c. Marketing activities are clearly targeted at Singapore customers;

d. Receiving funds or funds from Singapore users

In other words, as long as you provide DTSP-scope services in or to Singapore, you need to apply for a license

2. Applicable Service Scope (Covered Digital Token Services)

Simply put, anything related to "trading" is not allowed

a. Issuance or Arranging Issuance - Creating or issuing digital tokens for others, including IDO, Launchpad, Token Generation Event (TGE), etc.

b. Custody Services

Holding or controlling customers' digital tokens, including cold wallet and hot wallet services.

Providing interfaces or systems for customers to securely access their assets.

c. Brokerage / Matching / Exchange Services

Operating centralized or decentralized order books, transaction matching services (including OTC, Dex Aggregator).

Manifestation: Providing trading platform interfaces (UI/UX) to help buyers and sellers complete transactions.

d. Transfer Services

Assisting customers in transferring tokens (i.e., acting as an intermediary in transactions or cross-chain bridge transfers).

Including payment gateways, bridging protocols, and "proxy transfer" functions provided by wallets.

e. Validation / Governance Participation Services

Representing clients in node validation (e.g., Staking on behalf of clients), running validator nodes, or participating in on-chain governance voting.

Involves earning revenue or compensation from Staking or governance.

d. Technology Enabling Custody Services

Providing infrastructure or technical support required for custody services (such as MPC wallet service providers, key custody, custody API developers).

Even if not directly controlling assets, technology playing a key role in the asset control process is also included.

3. Services Not Requiring a License

a. Pure Advisory / Consultancy

For example: project design, token economic model consultation, legal structure advice, product design guidance, etc.;

As long as you do not participate in actual asset custody, issuance, or transaction execution, you will not be considered a DTSP;

MAS points out that merely providing "advice, advisory services" does not constitute a regulated activity.

b. Marketing / Publicity Services

Including community management, advertising placement, brand design, etc.;

Even if you help a Web3 project with market promotion in Singapore, as long as you are not involved in asset circulation, transaction matching, or token management, it is generally not subject to regulation;

However, if you directly arrange token sales/distribution or transfer for clients, you may trigger regulatory obligations.

Disclaimer: I am not legally responsible for the above statements. Please consult a lawyer

Finally, I guess the Hong Kong government should not pop the champagne yet. I suspect there will likely be a reversal, and at least the service providers for technical support should be relaxed somewhat