Mainstream Tracks, Flourishing Diversity

Since 2019, a series of forward-looking policy initiatives have been continuously introduced, vigorously advancing the development of Web3 technology. For instance, the "Digital Economy Alliance" was established in 2019 to fully promote the robust growth of the digital economy ecosystem; the "Digital Payment Alliance" was founded in 2020 to actively drive development and innovation in the field of digital payments; and the "Digital Currency Laboratory" was launched to conduct in-depth exploration of the potential and applications of digital currencies.

These policies have spurred numerous Web3 projects to take root and thrive in Singapore. Today, Singapore has achieved notable accomplishments in the Web3 sector, giving rise to many well-known projects. Mankun Law Firm has compiled a list of representative Web3 projects in Singapore for reference.

*The following ranking is not in order of precedence but is sorted by year of establishment.

Merlin Chain

#Infrastructure #Layer2

  • Year Established: 2023
  • Ecosystem: Bitcoin
  • Financing: USD 800 million
  • Project Overview: MerlinChain is a Bitcoin Layer 2 solution supported by Bitmap, built upon the native assets, protocols, and products of Bitcoin Layer 1, making Bitcoin interesting again. MerlinChain aims to amplify the overall asset potential of the Bitcoin ecosystem by empowering Layer 1 assets, protocols, and user ecosystems at Layer 2. Examples include building a metaverse that users can easily access based on Bitmap, and constructing DeFi protocols based on BRC-420 to maximize the release of its token duality. It is a new BTC Layer 2 solution supported by OKX. It has attracted significant attention because it directly addresses the core issue of the Bitcoin network—scalability.

Bitmap Tech, the development team behind Merlin Chain, registered a limited liability company in Texas, United States, in 2021, with its headquarters in Dallas. According to GitHub records, Merlin Chain commissioned ScaleBit to conduct a smart contract audit, including manual code review and static analysis, to identify potential vulnerabilities and security issues. During the audit process, ScaleBit identified four issues of varying severity: absence of event emissions, unused parameters, unnecessary checks, and inaccurate error codes.

AltLayer

#Infrastructure #Modular #Restaking

  • Year Established: 2022
  • Ecosystem: Ethereum
  • Fundraising: USD 21.6 million; a USD 7.2 million seed round was completed in July 2022, and a USD 14.4 million strategic financing round was completed in February 2024.
  • Project Overview: AltLayer is an open and decentralized rollups protocol that incorporates the novel concept of restaked rollups. It leverages existing rollups (derived from any rollup stack, such as OP Stack, Arbitrum Orbit, ZKStack, Polygon CDK, etc.) and provides them with enhanced security, decentralization, interoperability, and rapid finality through crypto-economic mechanisms.

AltLayer’s airdrop documentation sets forth specific legal terms, including a strict requirement for users to complete know-your-customer (KYC) verification. In particular, in connection with its cooperation with Binance Launchpool, all participants staking BNB or FDUSD to receive ALT token rewards must complete identity verification. The documentation also excludes airdrops to, and prohibits participation in ALT new-token mining by, users in sanctioned regions or countries, including Canada, Cuba, the Crimea region, Iran, Japan, New Zealand, the Netherlands, North Korea, Syria, the United States of America and its territories, and any non-government-controlled areas of Ukraine. In addition, the documentation notes potential regulatory and tax issues related to ALT and specifies that the protocol is governed by the laws of the British Virgin Islands. The airdrop documentation further references compliance with data protection and privacy requirements, such as adherence to data privacy regulations including the General Data Protection Regulation (GDPR).

DWF Labs

#CeFi #OTC #MarketMaker

  • Year Established: 2022
  • Project Overview: DWF Labs is a Web3 venture capital firm and market maker. DWF Labs provides market-making, secondary-market investment, early-stage investment, and over-the-counter (OTC) services, as well as token listing and advisory services, to Web3 companies. DWF Labs is part of Digital Wave Finance (DWF), one of the world’s leading cryptocurrency traders, trading spot and derivatives on more than 40 top-tier exchanges. DWF has established its global headquarters in Switzerland and its Asia regional headquarters in Singapore. It also maintains offices in Dubai, mainland China, and Hong Kong, China.

DWF Labs is headquartered in Switzerland and maintains an office in Singapore. According to DWF Labs’ officially disclosed privacy policy, DWF Labs collects and shares data in accordance with applicable laws and regulations and retains users’ data rights. In particular, for users residing in the European Economic Area, DWF Labs complies with the General Data Protection Regulation (GDPR). Users have the right to access, correct, delete, and restrict the processing of their personal data. The company relies on lawful bases for processing user data, including performance of contracts, legal compliance, and user consent.

On the Liquid Markets platform, DWF Labs requires users to complete know-your-customer (KYC) verification, which includes collecting and verifying users’ identity information and proof of address, as well as conducting biometric verification (such as facial recognition). These processes are designed to prevent illegal activities such as identity theft and money laundering. The KYC process has basic and enhanced tiers; the enhanced tier applies to users with higher transaction volumes, such as accounts with daily withdrawals exceeding USD 1 million.

In addition, DWF Labs collaborates with Sumsub for KYC and know-your-business (KYB) verification. Sumsub provides technical support including verification of various government-issued identification documents worldwide, address verification, and database checks. The platform integrates multi-layered security and compliance measures, including anti-money laundering (AML) requirements and compliance with the Travel Rule, to ensure that its global operations meet local regulatory standards.

Aethir

#Infrastructure #DePIN #CloudComputing #ArtificialIntelligence

  • Year Established: 2022
  • Ecosystem: Ethereum, Arbitrum
  • Financing: USD 9 million; Pre-A round completed in July 2023
  • Project Overview: Aethir is a decentralized real-time rendering network that unlocks content accessibility in the metaverse. Aethir builds scalable, decentralized cloud infrastructure (DCI), and its network helps gaming and artificial intelligence companies, regardless of size, deliver their products directly to consumers, irrespective of their location or hardware.

Aethir has registered the Aethir Foundation in Singapore, primarily to support the expansion of decentralized computing and the Web3 ecosystem. To ensure project compliance, the Aethir Foundation has taken necessary measures to ensure that its operations comply with international and Singaporean legal requirements. For example, during the Checker Node reward and withdrawal processes, Aethir requires users to complete KYC identity verification to meet anti-money laundering (AML) compliance requirements; node operators are also required to complete KYC during node sales and operations. Meanwhile, Aethir’s terms explicitly restrict user conduct to comply with applicable laws and regulations, such as prohibiting the use of unauthorized software or engaging in activities like the dissemination of illegal content. These terms also cover ownership of intellectual property and feedback, safeguarding the platform’s lawful operations. Additionally, in certain jurisdictions, the Aethir platform restricts participation by certain users, such as those from the United States or countries subject to sovereign sanctions. These measures align with local laws and international sanctions requirements, ensuring compliance with legal provisions across various global jurisdictions when conducting business.

Cointime

#CryptoMedia

  • Year Established: 2022
  • Project Overview: Cointime is a crypto news aggregation platform operated by QUANTBASE PTE. LTD. Cointime primarily provides readers with the latest crypto news, events, data, and indices. Whether it is news on cryptocurrency trends, real-time price movements, in-depth industry analysis, or cutting-edge technology, readers can find it all on Cointime.

 

zkLink

#Infrastructure #Layer2

  • Year Established: 2021
  • Ecosystem: Ethereum, Polygon, BNB Chain, Avalanche, Arbitrum, Optimism, Base, StarkNet, zkSync, Linea, Polygon zkEVM, Manta, opBNB
  • Financing: Completed an USD 8.5 million seed round in October 2021; completed an USD 10 million strategic financing round in May 2023; completed an USD 4.68 million public offering round in January 2024; completed strategic financing in July 2024.
  • Project Overview: zkLink is a transaction-centric multi-chain Layer 2 network featuring unified liquidity secured by ZK-Rollups. dApps built on the zkLink Layer 2 network leverage seamless multi-chain liquidity to provide rapid deployment solutions for decentralized and non-custodial order books, automated market makers (AMMs), derivatives, and NFT exchanges. Operating as a trustless, permissionless, and non-custodial interoperability protocol, zkLink aims to connect different blockchains, eliminate disparities among different tokens, and address the problem of liquidity silos formed on isolated chains.

According to publicly available information, zkLink implemented a series of compliance measures during the sale and registration process for its $ZKL token. These measures included requiring participants to complete Know Your Customer (KYC) identity verification and excluding residents of the United States, Canada, China, South Korea, and certain restricted jurisdictions to comply with applicable national regulations. Additionally, the zkLink platform restricted access for users in jurisdictions subject to economic sanctions, ensuring that service usage adheres to local and international regulations, such as the economic sanctions lists of Europe and the United States. These measures safeguard zkLink’s compliance in the global market and help mitigate legal risks.

zkLink provides a detailed privacy policy to ensure compliance with data protection regulations such as the General Data Protection Regulation (GDPR). The policy stipulates the collection and processing of users’ IP addresses, access data, and log information, primarily to ensure service stability and improve user experience. Furthermore, zkLink conducts anonymous user behavior tracking to collect non-personally identifiable data for product improvement. The policy also explicitly emphasizes user responsibilities, including securing wallet keys and recovery phrases.

zkLink engaged ABDK Consulting to conduct a comprehensive audit of its smart contracts and protocols. The scope of the review covered differences between the zkLink Protocol and Era contracts, including specific .sol files, files related to synchronization cost optimization, and interfaces. The audit identified several medium-severity issues, primarily concerning suboptimal code design, such as parameter passing, encoding call efficiency, and storage address calculations. It also addressed certain overflow and defect issues that have since been remediated, with corresponding recommendations provided for these matters.

 

SkyArk Chronicles

#GameFi

  • Year Established: 2021
  • Ecosystem: BNB Chain
  • Financing: USD 15 million
  • Project Overview: SkyArk Chronicles is a Triple-A fantasy JRPG featuring interoperable NFTs. SkyArk Chronicles is a trilogy comprising two GameFi titles (“House of Heroes” and “Legends Arise”) and one SocialFi metaverse (“Mirrorverse”).

SkyArk Chronicles was developed by SkyArk Studio, a Singapore-based blockchain gaming company. The studio aims to replicate the success of Hong Kong unicorn Animoca Brands by building an ecosystem that incubates crypto projects and leveraging SkyArk Studio’s proprietary resources.

The token system of SkyArk Chronicles includes two tokens, $SAR and $REO, which are used in various scenarios within the game and metaverse. These tokens enable players to participate in the game economy, purchase in-game items, and earn rewards. Currently, SkyArk has not officially launched its token sale.

SkyArk Chronicles addresses compliance matters related to virtual currencies in the terms of service on its official website.

First, it clearly defines virtual currencies and commodities, stating that while virtual currencies may function as cryptocurrencies, they do not constitute investment instruments such as securities. They are not registered with any government entity or regulatory authority, and holders possess only limited utility rights.

Second, it imposes strict purchase restrictions. Not all individuals are eligible to participate; purchasers must comply with the regulations of their country or region of residence. Participation is open only to experienced purchasers familiar with cryptocurrencies and blockchain technology. Marketing, offering, and sales are strictly limited to persons who can legally purchase and use the tokens in specific jurisdictions. Such activities in permitted jurisdictions do not constitute regulated investment or financial products.

Finally, with respect to prohibited jurisdictions, certain regions explicitly prohibit or restrict crypto asset-related transactions, while others may require licensing or other regulatory approvals. SkyArk may, at its sole discretion, prohibit the sale of virtual assets in specific regions to ensure that the game operates within a compliant framework.

Nansen

#Tools #Data & Analytics #On-Chain Data

  • Year Established: 2019
  • Financing: USD 88.2 million; completed a USD 1.2 million seed round in October 2020, a USD 12 million Series A round in 2021, and a USD 75 million Series B round in 2021.
  • Project Overview: Nansen is a blockchain analytics platform that enriches on-chain data with millions of wallet labels. Crypto investors use Nansen to discover opportunities, conduct due diligence, and protect their portfolios through its real-time dashboards and alerts.

As an analytics platform, Nansen does not directly facilitate crypto asset trading for end users; rather, it focuses on analysis and data mining. Additionally, through its partnership with Kaiko, leveraging Kaiko’s market data and Nansen’s blockchain data, it provides regulatory compliance reference prices for digital assets on centralized exchanges (CEXs) and decentralized exchanges (DEXs).

Nansen is not entirely free to use. The platform offers limited free features, but advanced analytics and data access services typically require a subscription. Users may select different paid plans to unlock more advanced tools and deeper on-chain data analysis. Accordingly, Nansen’s on-chain data platform ensures compliance by adopting a Master Services Agreement (MSA), which is the standard agreement formulated for customers purchasing products and/or services via purchase orders. The MSA delineates the responsibilities of both parties, including provisions on the timing, method, and quality standards of product delivery, thereby ensuring that customers receive products and services that meet their expectations. It also includes corresponding clauses regarding payment methods, payment terms, and potential refunds or exchanges. These provisions help safeguard the fairness and transparency of transactions, prevent situations where disputes lack a legal basis, and thus protect the legitimate rights and interests of both the platform and its customers, ensuring that commercial operations comply with applicable laws, regulations, and industry standards.

Mask Network

#SocialFi

  • Year Established: 2018
  • Ecosystems: Ethereum, Polygon, BNB Chain, Solana, Avalanche, Arbitrum, Optimism, Fantom, Gnosis Chain, Scroll, Harmony, Aurora, Conflux, Flow, Astar
  • Financing: Nearly USD 200 million
  • Project Overview: Mask Network is a Web3 portal designed to connect Web2 users to Web3. By introducing the decentralized application ecosystem into traditional social networks, Mask Network provides decentralized alternatives to features familiar to Web 2.0 users. Users can enjoy secure, decentralized social messaging, payment networks, file storage, and file sharing without leaving mainstream social media platforms. Version 2.0 of Mask Network includes a multi-chain Mask Wallet, a MaskID login system that aggregates users’ social media accounts and Web 3.0 addresses, and a dApp marketplace called D.Market.

The Mask Network team maintains offices in Singapore and conducts certain management and operational activities there; however, its legal entity, “Mask Network Pte. Ltd.,” has been deregistered. Consequently, Mask Network primarily operates through its affiliates and partners: Mask Network has established funds with partners such as Bonfire Union, headquartered in Singapore, to promote the development of Web3 and decentralized social networks. In addition to commercial activities, Mask Network has established a non-profit organization, Mask Academy, which supports Web3 research and education through collaborations with universities and research institutions worldwide.

Mask Network’s privacy compliance measures are based on its user privacy policy and cover areas such as data management, user autonomy and control, and integration with third-party decentralized applications (DApps). The platform states in its privacy policy that it is only responsible for DApps developed by itself, while DApp services provided by third parties are not under its direct control; therefore, users must assume certain risks when using these services.

Furthermore, Mask Network has clarified its principles of data encryption and privacy protection to ensure that users’ social information and data are properly protected when using Web3 decentralized applications. Meanwhile, the platform adopts a self-sovereign control mechanism, whereby users retain control over their wallets, private keys, and other information, and the platform does not store such sensitive data.

Regarding data access permissions, Mask Network also requires users to cooperate with necessary identity verification to ensure transaction security.

 

Bitget

#CeFi#CEX

  • Year of establishment: 2018
  • Financing: USD 30 million
  • Project Overview: Founded in 2018, Bitget is a crypto asset exchange and Web3 company. As of early 2024, Bitget provides services in more than 100 countries and regions worldwide, helping over 25 million users achieve intelligent transformation in trading through leading trading solutions such as copy trading.

Bitget has registered as a Virtual Asset Service Provider (VASP), particularly in countries such as Poland and Lithuania. These registrations enable Bitget to legally provide crypto asset trading and related services in these jurisdictions, ensuring compliance with local and international financial regulatory requirements.

With respect to know-your-customer (KYC) requirements, Bitget implemented mandatory KYC verification effective September 1, 2023. All new users must complete KYC verification to use the platform’s services, such as spot trading, futures trading, and other features. Users who have not completed KYC will, after October 1, be limited to certain operations such as withdrawals and order cancellations, and will be unable to create new trades. This measure aims to enhance platform security and ensure compliance with global and regional anti-money laundering (AML) and counter-terrorist financing (CFT) requirements.

In terms of auditing, Bitget publishes monthly Proof of Reserves (PoR) reports demonstrating the health of its asset reserves to ensure the safety of user funds. In 2023, these reports showed that its reserve ratio remained at approximately 200%, significantly higher than the industry standard of 100%.

Additionally, in 2023, Bitget launched an auditable protection fund worth USD 300 million to strengthen compliance and transparency. The platform’s protection fund primarily consists of BTC, along with small amounts of ETH and USDT. These funds are used to protect assets stored on the platform from hacking, theft, and other threats. Bitget has committed not to utilize these funds for at least three years and maintains publicly accessible wallet addresses. The fund, which has recently received support, currently totals USD 300 million and is held in seven public wallet addresses to enhance transparency.

The crypto asset group BGX has made a strategic investment in BC Technology Group Limited (HKG: 0863), a Hong Kong-listed company and the parent company of OSL, a licensed virtual asset exchange in Hong Kong, by subscribing to new shares worth HKD 710 million.

 

Paradigm

#CeFi

  • Year of establishment: 2018
  • Financing: Completed a USD 35 million Series A financing in December 2021.
  • Project Overview: Paradigm is a liquidity network for crypto derivatives traders spanning both CeFi and DeFi. The platform provides traders with on-demand, unified access to multi-asset, multi-protocol liquidity without compromising price, scale, cost, or immediacy. The company’s mission is to create a platform that enables traders to trade anything with anyone and settle anywhere. Paradigm boasts the largest network of institutional crypto counterparties, serving over 1,000 institutional clients with monthly trading volumes exceeding USD 10 billion, including hedge funds, over-the-counter (OTC) desks, lenders, structured product issuers, market makers, and prominent family offices.

In Singapore, the entity behind Paradigm is Paradigm Pte. Ltd., which focuses on liquidity provision and innovation in the digital asset market. Paradigm has also recently incubated a decentralized perpetual derivatives appchain named “Paradex,” aiming to integrate its liquidity and provide a more transparent trading environment.

Its official website’s relevant terms and agreements demonstrate significant efforts in compliance: clearly restricting the provision of services to restricted persons (including individuals of specific nationalities and those subject to sanctions); imposing strict regulations on system and software usage licenses, including authorized user management; emphasizing that users must use the services in compliance with applicable rules and must not engage in non-compliant operations; addressing fees, term, and termination provisions; providing detailed stipulations on confidentiality and intellectual property rights; clarifying the responsibilities of all parties, including users’ liability for compensation and Paradigm’s exemptions from liability; and specifying the application of Singapore law and arbitration as methods for dispute resolution, thereby ensuring compliant business operations.

KuCoin

#CeFi #CEX

  • Year Established: 2017
  • Financing: USD 180 million in total; completed a USD 20 million Series A financing in November 2018; completed a USD 150 million financing in 2022; and completed a USD 10 million strategic financing in 2022.
  • Project Overview: KuCoin was established in September 2017 and is a global cryptocurrency exchange offering spot trading, margin trading, peer-to-peer (P2P) fiat trading, futures trading, staking, and lending services.

Since July 15, 2023, KuCoin has implemented mandatory KYC verification. All new users must complete KYC verification to fully access the platform’s services, including spot trading, futures trading, leveraged trading, and other financial products. For users who registered before this date but have not completed KYC, their account functions are restricted to limited operations, such as selling spot positions and withdrawing funds, but they cannot make new deposits.

While introducing KYC, KuCoin has also strengthened the security management of user data. The platform commits to using encryption and secure storage methods to protect users’ personal information, ensuring the security of data submitted during identity verification. Furthermore, KuCoin continues to provide withdrawal functionality, allowing users to withdraw funds from their accounts at any time, even if they have not passed KYC verification.

 

Paxos

#CeFi #Custody #StablecoinIssuers

  • Year Established: 2013
  • Financing: Approximately USD 535 million in total; completed USD 3.25 million in 2013; completed a USD 25 million Series A financing in 2015; completed a USD 65 million Series B financing in 2018; completed a USD 142 million Series C financing in 2020; and completed a USD 300 million Series D financing in 2021.
  • Paxos is a U.S.-headquartered fintech company focused on blockchain and digital assets. It issues the Pax Dollar (USDP), a stablecoin pegged 1:1 to the U.S. dollar, and provides secure digital asset custody services to help institutional clients manage crypto assets. In addition, Paxos has developed blockchain infrastructure supporting the operation of its financial products, committed to promoting the integration of traditional finance and digital assets, and building enterprise blockchain solutions for institutions such as PayPal, Interactive Brokers, Mastercard, Bank of America, Credit Suisse, and Société Générale.

Operating under a trust company charter approved by the New York State Department of Financial Services (NYDFS), Paxos offers a range of digital asset services, including stablecoins (such as Pax Dollar (USDP) and PayPal USD (PYUSD), launched in collaboration with PayPal) and gold tokens (PAXG). By virtue of its trust company charter, Paxos is able to provide regulated financial services, including custody, trading, and clearing, subject to a higher level of regulatory oversight than typical cryptocurrency exchanges or payment institutions.

On July 1, 2024, Paxos announced that its Singapore entity, Paxos Digital Singapore Pte. Ltd., had received formal approval from the Monetary Authority of Singapore (MAS) and obtained a Virtual Asset Service Provider (VASP) license, becoming a Major Payment Institution authorized to issue stablecoins in Singapore. Companies holding a VASP license must comply with specific laws and regulations to ensure compliance: they must implement anti-money laundering (AML) and know-your-customer (KYC) measures to mitigate the risk of financial crime; submit regular reports and undergo audits; and remain subject to supervision by financial regulators.

Furthermore, as a digital asset custody provider, Paxos discloses on its website that it achieves bankruptcy remoteness. In the unlikely event that Paxos Trust becomes insolvent, client assets will be protected. Paxos states that its operational model differs from that of banks, particularly in that it does not operate on a fractional-reserve basis; instead, it holds all client assets on a 1:1 basis, ensuring that client funds are always available for redemption and that client assets are never lent out.

 

Mankun Lawyers’ Summary

Based on the above, although Singaporean authorities have begun advancing crypto regulation and established a virtual asset (VA) licensing regime, the practical regulatory environment remains relatively open and ambiguous. Nevertheless, this has facilitated the entry of crypto industry participants and projects into Singapore, which continues to rank among the most popular global hubs for startups.

However, for Web3 projects, compliance is inevitably the future trend. Beyond business development, entrepreneurs should also ensure the implementation of compliance measures, such as obtaining relevant licenses for financial projects, ensuring that decentralized application (dApp) projects comply with data and privacy requirements, and closely monitoring changes in Singapore’s regulatory rules to avoid regulatory impacts during periods of rapid growth.

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Recommended Reading:

  1. Event Recap | Mankun Law Firm x Conflux Research Institute: Compliance-Driven Financial Innovation Powered by Web3
  2. Mankun Web3 Research: DePIN Promotes Greater Network Democracy and Easier Compliance

 *This article is an original work of Mankun Law Firm and reflects only the personal views of the author(s). It does not constitute legal advice or a legal opinion on any specific matter. Submissions and tips from more Web3 practitioners are welcome. For reprints and legal consultations, please contact customer service at: MankunLawFirm.

 

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