This blog series has been named after the classic children’s categorisation game where one player names an object and the other player has to categorise it as an animal, vegetable or mineral. Whilst simple in concept, the difficulty of the game varies – some things are extremely easy to categorise (such as ‘cat’), whereas others are difficult to categorise, or might have features meaning that different people could categorise them in different ways (is ‘coal’ better categorised as fossilised vegetable matter or a mineral?).

As with that game, the difficulty of categorisation of tokens can vary greatly depending on their features and in this series we’ll look at some of the ways in which Singapore law seeks to do so.


Tokens can be categorised as asset-backed tokens for purposes of the Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act 2019 (PSPMA). The PSPMA regulates the manufacture and dealing in precious stones, precious metals and related products in Singapore for anti-money laundering purposes, imposing registration requirements on applicable dealers and requirements with respect to policies and adequate safeguards to ensure compliance with the anti-money laundering and countering of terrorism financing obligations (AML/CTF Obligations) set out in the PSPMA.

Tokens backed by precious stones, precious metals or related products may constitute an “asset-backed token” under the PSPMA if the holders of such tokens are entitled to the precious stones, precious metals or related products backing the tokens.

The dealing in “asset-backed tokens” is a regulated activity under the PSPMA. Dealers in “asset-backed tokens” within scope of the PSPMA would be subject to the applicable registration requirements and AML/CTF Obligations under the PSPMA.


Coming soon…