- The Blockchain Association of Singapore (“BAS”) is an industry body whose mission is
to be the leading industry organisation for the advocacy, collaboration, convergence,
and fair use of blockchain and scalable technologies in Singapore, which has a vibrant
blockchain community.
- Our members include Virtual Asset Service Providers (“VASPs”) (cryptocurrency
exchanges, digital asset exchanges, custodial providers, OTC platforms, most of which
are regulated in Singapore under the Payment Services Act), blockchain-based
enterprises, academia, RegTech providers and professional consultancy firms. - BAS’ Regulatory and Compliance Sub-Committee had organised a Webinar on 1 Apr
2021 attracting 247 registrants, attended by around 214 participants from about 156
companies. This set of submissions crystallizes some of the comments received during
the Webinar. - A panel of the Sub-Committee members, comprising former regulators and
compliance thought leaders from the community, had led discussion of issues during
the Webinar. - At the outset, we would like to reiterate that BAS is committed to ensure upholding of
robust and risk-appropriate standards of Anti-Moneylaundering (“AML”) and
Combating the Financing of Terrorism (“CFT”) for the blockchain industry and is
generally supportive of greater clarity on international prescriptions for AML/CFT
compliance. For instance, we have conducted various webinars for our members to
promote AML/CFT compliance, including a session relating to FATF’s Virtual Assets
Red Flags Indicators of Money Laundering and Terrorist Financing (Sep 2020).