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The Tale of Three Arrows Capital: The Rise & Fall of Crypto’s Most Iconic Hedge Fund

In 2018, leaning back against a well-cushioned leather sofa in a seaside bungalow in Sentosa Cove belonging to another cryptocurrency mogul, Su Zhu was basking in the aura of his power and influence as he nursed a 21-year-old whiskey at a “crypto insiders” party.

For Zhu, this was his moment of peak crypto.

Surrounded by hangers-on trying to pitch him their latest project, Zhu largely ignored the cacophony of voices that were droning around him as he sipped his drink.

Zhu and Kyle Davies, former high school classmates and founders of 3AC, a Singapore-based cryptocurrency hedge fund, had just secured an early investment in Terra Luna, giving them access to hundreds of millions of dollars’ worth of Luna tokens.

For 3AC, the investment in Terra Luna was made more special by the fact that some of the biggest names in crypto were also backing the algorithmic stablecoin project, including Galaxy Digital, whose CEO Mike Novogratz would soon go on to tattoo the Luna logo on his upper arm (a tattoo that would unfortunately not age well) and Pantera Capital.

Terra Luna also counted Lightspeed Venture Partners, Coinbase Ventures and Jump Crypto as backers, cementing 3AC’s status as a major player in the digital asset scene.

By the time that Zhu and Davies had backed Terra Luna, they were already one of the top cryptocurrency venture capitalists, backing such successful projects as Avax, Near Protocol, Aave, Deribit, Starkware and Axie Infinity, with their assets under management estimated to be as high as US$18 billion at one stage.

Even by late 2021, when Pantera Capital had sold most of its stake in Terra Luna, Zhu was busy buying, not Luna, but real estate.

As reported by Bloomberg, Zhu was shopping around for another Good Class Bungalow, Singapore’s most exclusive form of housing located in its toniest districts, to find an abode befitting his stature near the top of the crypto world.

When Zhu wasn’t busy buying high-end Singapore real estate or superyachts, he enjoyed using his considerable influence on social media, in particular Twitter, to shape sentiment and possibly profit from it.

With over 560,000 Twitter followers, Zhu was known for using psyops and playing mind games with his followers, creating a thread in November 2021 that flamed Ethereum, while taking advantage of the drop in prices to snap up some US$660 million worth of Ether.

Like the boy who cried wolf, Zhu’s frequent use of Twitter to talk up or spread fud (fear, uncertainty and doubt) about tokens made it difficult for followers to determine if he was gaming his audience for profit, or serious in his views, and often it appeared to be both.

Nevertheless, plenty of people held Zhu and 3AC in high regard, especially given that Zhu had correctly predicted the end of the “Crypto Winter” in 2018 and that Bitcoin would break its all-time-high in 2020.

However what Zhu and Davies had not factored in is that just as the U.S. Federal Reserve giveth, it also taketh.

Who turned off the firehose?

Image: Unsplash/Art Rachen

Zhu, in his characteristic deadpan, declared at a podcast recording for cryptocurrency exchange FTX,

“When there’s a lot of despair, you can start buying. You don’t have to follow the despair.”

Yet the despair in financial markets in general and the cryptocurrency markets in particular was not unwarranted.

With the U.S. facing the greatest inflationary pressures in four decades, Fed policymakers started to unwind many of the pandemic-era measures which had contributed in no small part to the success of both the cryptocurrency markets and 3AC.

Even as cryptocurrency veterans like Pantera Capital were unloading their stake in Terra Luna, Zhu continued to talk up the merits of the algorithmic stablecoin, leading some to wonder if the 3AC cofounder was in fact looking to offload his holdings.

On December 26, 2021, Zhu bragged about the future growth prospects of Terra Luna in a tweet,

“We’re seeing some of the earliest and most ambitious ideas in crypto starting to unfold. Crosschain decentralized stablecoin backed entirely by digitally native assets was the holy grail in 2016. Bless $BTC $LUNA.”

and further that day,

“People down 50x more from selling early than from buying top this year, and it’s not even close, SOL, LUNA, AVAX, MATIC, DOGE, SHIB, FTM, list goes on. Tops are emotionally memorable because plebs snapshot themselves to a portfolio all-time-high, yet nobody buys top while everyone sells early.”

Despite roiling markets, Zhu walked with the cocky confidence of someone who had made it from humble beginnings to being hounded by global media and many believed that the bulk of 3AC’s funds were proprietary, making them bulletproof when in fact, they were not.

A venture investor in some of the best-known cryptocurrency startups, in many cases, 3AC also served as a manager of their corporate treasuries, which helped it to circumvent the regulatory restrictions of its Registered Fund Management Company (RFMC) license.

A Different Kind of License

Image: Jievani/Pexels

As early as 2013, 3AC held an RFMC, a type of fund management license administered and governed by the Monetary Authority of Singapore (MAS), but which came with specific restrictions that few investors were aware of.

An RFMC only allows up to 30 professional investors and a maximum of S$250 million in assets under management, limitations which 3AC got around creatively.

Instead of managing a fund which promised a return on investment, 3AC would borrow money from investors, and promise a projected coupon rate, structuring these investments as loans instead of what they were marketed as — investment products, and thereby declaring these funds as “proprietary capital,” which was misleading to say the least.

But by September 2021, concerned that these workarounds would eventually surface, 3AC novated the management of its only fund to an offshore entity in the British Virgin Islands, notifying MAS in February 2022 that it intended to cease fund management activity in Singapore from May.

By late 2021, Zhu also publicly declared that 3AC was relocating to Dubai, an uncontroversial move at the time, given that many other cryptocurrency companies were doing the same.

However, 3AC had not applied for any fund management license in Dubai nor notified regulators in the United Arab Emirates of its intention to do so.

Publicly, Zhu remained sanguine on the prospects of cryptocurrencies, arguing on Twitter that 2022 would mark the year of peak adoption, even as investors were fleeing risk assets in the face of rising interest rates and tighter monetary conditions.

Many believed that Zhu was engaging in his usual psyops, to get other investors to soak up the bags of cryptocurrencies that he was looking to offload.

In reality however, Zhu, having correctly predicted market turnarounds in the past, was convinced that this time was no different, borrowing heavily to bet big that cryptocurrencies would eventually rebound.

In May this year, 3AC attempted to plug the hole caused by the collapse of Terra Luna, soaking up some US$559.6 million worth of Locked Luna tokens, a stake which would be worth around US$600 by late June, and go on to become worthless.

Unfortunately, 3AC’s bid to shore up Terra Luna was ultimately futile, and the price of Luna kept falling, taking the rest of the cryptocurrency market with it, at a time when sentiment was already weak.

Nothing Says Rich Quite Like a Superyacht

Sanlorenzo 52Steel. Image: Sanlorenzo

Even as things started looking bleak in January, Zhu was still showing off pictures of his latest trophy acquisition, a 171-foot Sanlorenzo 52Steel superyacht, that was intended for delivery this month, to investors and friends, presumably to maintain an air of invincibility.

It would later turn out that 3AC was only able to pay the down payment on the US$50 million superyacht, and it’s been suspected that even that was paid for with borrowed money.

As Zhu and Davies were going hat in hand to investors to raise more money, 3AC was keeping secret its massive margin long position on Bitcoin, with a liquidation price of US$24,000, betting that the cryptocurrency would never fall that low.

Some have speculated that Zhu and Davies may have engaged in “revenge trading” where a trader borrows even more money to trade (gamble) their way out more quickly of a hole they’ve dug themselves in by using leverage.

Unfortunately, by mid-June, 3AC had started missing margin calls from the companies funding its trades, including many major crypto lenders, who are now known to have offered the hedge fund undercollateralized loans.

Given how volatile cryptocurrencies are, most lenders are only willing to lend a fraction of the value of digital assets pledged as security for a loan, yet somehow Voyager Digital, a crypto broker and lender, lent around US$700 million to 3AC, undercollateralized.

Voyager Digital was hardly alone in extending undercollateralized loans to 3AC, with fellow cryptocurrency broker and lender Genesis alleged to be facing losses of as high as 9-figures.

It has now surfaced that BlockFi and BitMEX have exposure to 3AC as well and the list of affected counterparties reads like a who’s who of the crypto world, including Cumberland DRW, Galaxy Digital and crypto options exchange Deribit.

Even before the walls started closing in on 3AC, in a desperate bid for liquidity, Zhu and Davies were said to have solicited Bitcoin from large holders known as “whales” as well as other trading firms and are thought to have lied about their assets under management in a bid to secure fresh loans.

Undeterred by the rapidly deteriorating market conditions, Zhu and Davies are said to have promised yields of as high as 20 per cent to potential Bitcoin lenders despite liquidity and speculation, the main driver of lending yields, rapidly drying up, but most potential lenders detected something amiss and declined doing business with the pair.

And although Zhu tweeted that 3AC was working with relevant counterparties and remained “fully committed to working this out,” in reality both he and Davies had been ghosting their creditors for some time.

When cryptocurrency prices started to falter in the wake of the Terra Luna collapse in May, lenders approached 3AC to ask for collateral, but struggled to contact the pair, forcing these lenders to liquidate the fund’s positions and causing Bitcoin to fall even further from US$24,000 to US$20,000.

Those liquidations sparked off a spiral of cascading defaults and triggered a run on several major crypto lenders, some of which have already gone into bankruptcy.

Catch Me if You Can

Image: Executium/Unsplash

Throughout the debacle, creditors claim that Zhu and Davies were nowhere to be found, although some suspect that they may have decamped to Dubai.

According to one source, Zhu was urgently trying to sell a US$35 million house in Singapore, which was being held in trust for his daughter, and with the proceeds of the sale to be transferred to a bank account in Dubai.

A search of registry records suggests that Zhu, Davies, and parties connected to the duo (as opposed to 3AC) own a fleet of high-end cars, and at least five high-end properties in Singapore, including the US$35 million Good Class Bungalow and another US$28.5 million property of the same type held by Zhu’s wife, Tao Yaoqiong.

Most, if not all of these assets are likely to remain out of the reach of Three Arrow Capital’s liquidators who are now desperately trying to seize them.

For starters, the 3AC that is being liquidated was incorporated in the British Virgin Islands and the process of liquidators in that jurisdiction attempting to enforce any judgments in Singapore will be complicated and drawn out.

To make matters worse, Zhu is only known to have held in his own name a US$4.5 million strata bungalow at Goodwood Grand, located in the ritzy Balmoral Road neighbourhood.

3AC’s liquidators will likely have their work cut out for them if they want to go after the assets of the fund’s founders because they would need to prove beyond a reasonable doubt that Zhu and Davies were guilty of criminal misconduct.

Although 8 Blocks Capital, a smaller market maker which claims it used 3AC’s trading accounts for fee discounts, and alleges that the hedge fund misappropriated as much as US$1 million of their funds without permission, possibly in an attempt to meet margin calls, no other counterparties have alleged any criminal behaviour.

Complicating the job of liquidators, 3AC filed a petition in the U.S. Bankruptcy Court for the Southern District of New York and seeking protection from creditors in the U.S. under Chapter 15 of the U.S. Bankruptcy Code, which allows foreign debtors to shield U.S. assets.

For now, nobody really knows where Davies and Zhu are, with the former having surfaced for a Wall Street Journal interview only to disappear soon thereafter, with the latter resurfacing only for the occasional tweet.

The Monetary Authority of Singapore has issued a reprimand of 3AC and is investigating, and Solitaire LLP, the Singapore lawyers retained by the fund, claim that the firm is keeping regulators apprised of developments, but such investigations typically take a considerable amount of time.

It’s unclear whether Zhu and Davies are guilty of any impropriety or financial misconduct towards the end of their reign as princes of the crypto world, but their very visible public absence and attempt to dispose of assets is disconcerting to say the least.

The Goodwood Grand bungalow where Zhu was last seen has been put up for sale and neighbors claim that no one has been witnessed entering or leaving the house in weeks.

Mail is piling up outside the Suntec City offices that 3AC operated out of, while staff say that they have been unpaid and unable to contact Zhu and Davies since early June.

Given the amount that both Davies and Zhu have contributed to the cryptocurrency space, their fall from grace and manner of exit from the industry is disappointing to say the least.

While Zhu was known to have been dismissive and arrogant to those he deemed not his intellectual equal, Davies and he were also approachable to founders and willing to write checks that would fund the further development of the cryptocurrency ecosystem.

Some of the most successful companies in the cryptocurrency business today were funded out of the coffers of 3AC, and in some cases, personally, by Zhu and Davies.

The cofounders of 3AC were also known to have taken time out to spend with founders, sharing with them their thoughts on technology, markets, and the general development of the industry and helping out through more than just money, but with connections and influence as well.

Ultimately 3AC’s legacy and contribution to the cryptocurrency industry will be forgotten under a deluge of allegations and litigation.

With just US$1.2 million in late 2012, 3AC started off trading emerging market currencies, before it’s been said that they were squeezed out of the already crowded trade and forced to switch to trading cryptocurrencies.

That fortuitous switch to cryptocurrencies by Zhu and Davies turned out to have been at an opportune time and which would help to propel the duo to fame and fortune, turning their million-dollar fund into billions and making them rich beyond the dreams of avarice in the process.

But like Bill Hwang’s Archegos Capital, one-directional leveraged bets on cryptocurrencies would ultimately also spell the demise of 3AC, one of the industry’s biggest success stories and also, one of its biggest cautionary tales.


By Patrick Tan, CEO & General Counsel of Novum Alpha

Novum Alpha is the quantitative digital asset trading arm of the Novum Group, a vertically integrated group of blockchain development and digital asset companies. For more information about Novum Alpha and its products, please go to https://novumalpha.com/ or email: [email protected]

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Crypto Remains for Those Who Can Afford To Lose

Image: Siam Blockchain

They are in no way currencies, even if the infatuation and the global greed of gain bestow upon it the flattering label of “cryptocurrencies”, in a doomed-from-the-start attempt to lend credibility and attract punters. You need to have a tough heart and stomach to trade in such currencies with unprecedented volatility.

Cryptocurrencies are in reality nothing more than an instrument — an umpteenth one — of pure speculation that has no intrinsic value. Buy a property and you will still have it if the market tanks. Buy shares on the stock market and you will still be part-owner of the company if the market collapses. Buy Bitcoin and you’ll be throwing your laptop in the bin if its value evaporates (as is currently the case) because this tool is just a bit of code that you can do absolutely nothing with and that someone else at the other end of the pyramid just had the bright idea of selling.

This widespread hysteria in fact tells a banal story that has happened before many times. It reflects a collective contagion that has in the past swelled the valuation of assets that are far more tangible than cryptocurrencies — that in turn are as ephemeral as a summer romance — but are also just as banal as a game of musical chairs where the number of seats are limited and the only people who can win are those who sell up first. This market — that is now worth a few trillion dollars and euros less than it did before, having been largely devalued these last few months — only has any value thanks to other players who are pushing it higher and higher.

 
 
 
 
 
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A post shared by ⠀𝘽𝙞𝙩𝙘𝙤𝙞𝙣 🌐 (@bitcoin.info.9)

Worse still — and far more worrying still is that crypto has prospered on a breeding ground of young and precarious speculators and investors who didn’t have the means to trade on the stock or in the property markets as it was too dear for them. Let us be realistic and honest: in a climate where new generations are much worse off than their predecessors, and in a situation where it seems so easy to make money by speculating thanks to deregulation and the complete liberalisation of capital flows, crypto has sold a dream to young people, who found in it an ideal way to distinguish themselves from their predecessors.

In a world where inequalities are aberrant, where the great majority of young people over the world can now be qualified as the new poor, the one and only weapon at their disposal allowing them to make a mark for themselves has been crypto. This scam was able to persuade them that they could follow in the footsteps of the rich and the powerful by taking advantage of an avant-garde instrument as a side hustle.

Alas for these young people and for the helpless, for whom crypto was literally an ideology so much so that they swore by it and it alone, rich investors have got even richer because it’s them alone who found themselves in the handcuffs of these platforms and this sham of a market. Today, thousands of gullible investors are suffering head-on and right up to their last penny this latest avatar in the era of rampant capitalism that only knows how to prosper off the backs of the most vulnerable cadavers. It remains those who can afford to lose the least who are the ones to have been wronged and ruined.

For more information about Michel Santi, visit his website: michelsanti.fr/en

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3 reasons cryptocurrencies were made for Southeast Asia

(Story adapted from CryptoInvestor.Asia)

Maria Santos is visibly nervous. She uses a well-worn handkerchief to dab at beads of sweat which have formed on her brow under the oppressive noonday sun in the sweltering heat that is downtown Manila.

The octogenarian has been receiving payments regularly from her daughter Esther who works as a domestic helper in Singapore the same way for close to two decades and the money has always arrived the same way – through a string of intermediaries which with fees costing anywhere between 7 and 10 percent of the money which Esther sends across to Maria.

These fees contribute to a global honeypot of $38 billion in fees paid annually on remittances. (The remittance market is US$500 billion annually and average fees of 7.7 percent work out to approximately US$38 billion a year.)

Domestic workers lining up at a money remittance branch at a shopping mall popular with Filipino domestic workers in Singapore’s Orchard Road.

#1 The Value Transfer Revolution

For every $200 that Esther sends home, as much as $20 will be gone by the time it reaches her mother in Manilla. While $20 is the cost of bus fare and a meal in Singapore, in Manila it could buy food for a week. Over her lifetime, Esther has paid thousands of dollars to intermediaries such as Western Union to send money home.

But today is different, which is why Maria is nervous.

Enter Abra and companies like it. Abra is a decentralized smartphone application which leverages the blockchain to facilitate money transfers. Esther and her mother both downloaded the Abra app to their Android smart phones. Esther’s balance to start was in dollars. At the tap of a button, Esther converted the dollars to Bitcoins and initiated the transfer to Maria who got it in Bitcoins, almost instantly. At this point, Maria had the choice of keeping Bitcoins as a store of value on her phone or converting the Bitcoin to pesos. By creating a payment mechanism and store of value, Abra effectively displaces the conventional banking system’s two must lucrative roles – payments and value storage.

Filipino maid Nilda Sesaldo bought SMS codes through online portal BeamAndGo, which her teenage daughter used to redeem vouchers for groceries at the supermarket and a new phone at a local shop. (Photo source: ST PHOTO: DESMOND FOO)

But Maria’s story doesn’t end there – she wants cash. Maria pays her rent, buys her food and ironically, tops up her prepaid mobile SIM card using cash. She checks the Abra app and notices there are four other Abra users within a four-block radius of her. She messages them all to see who will exchange her pesos (which have since been converted from Bitcoin by Abra) for their services. One person will do it for 3 percent, another for 2 percent, and two more for 1.5 percent. Maria decides to go with the one offering 2 percent, not because it’s the cheapest (it’s not) but because the exchanger had a 5-star rating and agreed to meet her halfway. They meet and she swaps her Abra pesos for physical pesos and both walk away happy. Abra takes 0.25 percent on conversion and the whole process costs Maria well under 3 percent. “I get it now! That’s really cool!” says Maria, ecstatically.

The entire process, from the money leaving Singapore to Maria in the Philippines takes less than an hour and depending on who Maria chooses to do the swap from Bitcoin to pesos, will cost her well under 3 percent, or less than half of the lowest amount she would have paid through a traditional money transfer. Whereas every Western Union transaction requires up to seven or eight intermediaries, corresponding banks, local banks, Western Union, the individual agents, the Abra transaction required only three – two peers and the Abra platform.

But that’s not even considering the amount of time that has been saved by both Maria and Esther. Whereas Esther can expect to wait up to two hours in line at Singapore’s Lucky Plaza, home to dozens of money transfer agents, Maria in Manila would have had to line up to receive the money as well.

With the number of migrant workers across Asia, the savings of time and money from utilizing the blockchain to facilitate the transfer of value is very real.

According to KPMG, in 2016, only 27 percent of Southeast Asia’s population had a bank account. That’s some 438 million unbanked people. In countries like Cambodia, the number of unbanked people soars to 95 percent. Which is why the blockchain revolution is so critical to Southeast Asia and its estimated 20.2 million migrant workers.

Southeast Asia is one of the most linguistically, culturally and racially diverse regions in the world, making it an excellent proving ground for cryptocurrencies.

#2 The Diversity of Southeast Asia is the Clarion Call for Crypto

With a population of over 640 million people and a GDP of US$2.56 trillion, Southeast Asia represents a rare opportunity for the cryptocurrency revolution as a means of value transfer. Strategically located with China to the East and Europe and India to the West, Southeast Asia straddles some of the oldest and most lucrative trading routes.

But Southeast Asia is also a diverse region, with no less than 11 sovereign countries, 800 native languages and over 22 different ethnic groups. Despite that level of diversity, the nations of Southeast Asia have generally lived in peace with one another, with conflicts limited to minor border skirmishes and territorial disputes.

That peace has ensured robust economic growth with the Asian Development Bank expecting Southeast Asia to grow 5.0 percent in 2017 and 5.1 percent in 2018. As the people of Southeast Asia become richer, they are also expected to trade more with each other, but Southeast Asia has no less than 11 different currencies, with less developed regions using the U.S. dollar as their primary currency, making cross-border trade particularly challenging given foreign exchange fees. Which is why many cross-border transactions are denominated in U.S. dollars.

Yet for a region as large as Southeast Asia, with a population almost double the United States, to base its cross-border trade on the vagaries of the U.S. Federal Reserve is risky at best and a surrender of sovereignty at worst.

Southeast Asia represents a tremendous opportunity for crypto advocates and enthusiasts to subscribe to a medium for value exchange that is independent of any foreign sovereign entity. With the region’s internet economy at an estimated US$50 billion at the end of 2017, more than half of Southeast Asians are monthly active internet users, leaving tremendous potential for growth, but providing the foundation for significant adoption of both cryptocurrency usage and cryptoasset trading. Southeast Asia has the opportunity to bypass the internet banking revolution and go straight to mobile value transfer the same way Africa avoided costly copper telephone lines and went straight to mobile.

Apps like Abra are well-positioned to harness that growth in mobile internet usage and the favorable regulatory climate adopted by global financial centers such as Singapore towards cryptocurrencies ensures that the seeds of the crypto revolution will continue to grow.

 

The Singapore skyline. Singapore serves as Southeast Asia’s legal and financial center.

#3 The Legal & Financial Center in the Heart of Asia

At the heart of the crypto revolution, is the legal and financial center that is Singapore. On March 15, Ravi Menon, the Managing Director of the Monetary Authority of Singapore (MAS), suggested that there is no reason why cryptocurrencies could not be accepted as money in the future. Speaking at the Money 20/20 Asia conference held in Singapore for global payments and financial services industry players, he emphasized that cryptocurrency activities in Singapore “do not currently prose a significant risk to financial stability.”

The pronouncement from the head of the central bank of Singapore is significant and demonstrates the enlightened and practical approach taken by one of the world’s leading financial centers. Singapore has long served as the region’s leader in the areas finance and technology and it’s clear from the pronouncements by the MAS chief that it intends to lead the way in the realm of fintech and crytpocurrencies as well.

But it’s not all free-wheeling unbridled crypto-capitalism in Singapore. On November 14 last year, the MAS  issued a statement stating that tokens sold through the blockchain funding model, otherwise known as Initial Coin Offerings or ICOs, may be considered securities under certain circumstances, citing Singapore’s Securities and Futures Act (SFA) as well as the Financial Advisers Act.

According to the MAS,

“OFFERS OR ISSUES OF DIGITAL TOKENS MAY BE REGULATED BY MAS IF THE DIGITAL TOKENS ARE CAPITAL MARKETS PRODUCTS UNDER THE SFA. CAPITAL MARKETS PRODUCTS INCLUDE ANY SECURITIES, FUTURES CONTRACTS AND CONTRACTS OR ARRANGEMENTS FOR PURPOSES OF LEVERAGED FOREIGN EXCHANGE TRADING.”

The new report includes several case studies, including one detailing a token tied to a computing power-sharing platform (which wouldn’t count as a security) and another that is focused on a token connected to a startup investment fund (which would count as a security).

Ravi Menon, Managing Director of the Monetary Authority of Singapore. The MAS chief has said that it’s not impossible for cryptocurrencies to become mainstream. (Photo credit: Reuters file photo)

The guidelines also shore up earlier statements from the MAS. In August last year, officials stated that some token sales would be subject to securities laws on the basis that the cryptographic data sold would constitute kinds of debentures or stakes in collective investment schemes.

Further, the MAS said in its new guidelines that other Singapore laws may apply to token sales, including the ones that don’t ultimately come under its direct jurisdiction. The report adds,

“DIGITAL TOKENS THAT PERFORM FUNCTIONS WHICH MAY NOT BE WITHIN MAS’ REGULATORY PURVIEW MAY NONETHELESS BE SUBJECT TO OTHER LEGISLATION FOR COMBATING MONEY LAUNDERING AND TERRORISM FINANCING.”

In the area of money laundering and terrorism financing in particular, the MAS said that it would move to develop a new payments service framework that would cover companies involved in “the dealing or exchange of virtual currencies for fiat or other virtual currencies,” adding,

“SUCH INTERMEDIARIES WILL BE REQUIRED TO PUT IN PLACE POLICIES, PROCEDURES AND CONTROLS TO ADDRESS SUCH RISKS. THESE WILL INCLUDE REQUIREMENTS TO CONDUCT CUSTOMER DUE DILIGENCE, MONITOR TRANSACTIONS, PERFORM SCREENING, REPORT SUSPICIOUS TRANSACTIONS AND KEEP ADEQUATE RECORDS.”

The clarity provided by the MAS is timely and helps to provide certainty to a vibrant and growing crypto-sphere in the region. By making clear, unambiguous statements about the sort of activities that will come under the ambit of other laws and stating with clarity the examples that will not come under the purview of securities laws, MAS is ensuring just that level of legislation that will enhance growth in the space without stifling creativity.

A study by Funderbeam indicates that ICO funding started gaining traction in 2016 and exploded in 2017, where the funding increased from US$228 million to US$2.6 billion. In 2017, North America and Asia, when compared to Europe, have rounds almost twice as large, with average ICO rounds in North America valued at US$31.5 million, Asia averaging US$30.7 million and Europe averaging US$16.7 million.

The approach has rocketed Singapore to the world’s third largest ICO market globally, behind the United States and Switzerland. Last year, Japan’s Quione, the first licensed global cryptocurrency exchange in Japan, launched its ICO in Singapore which was oversubscribed and raised US$105 million in investment proceeds. When asked about how Singapore had emerged as an Asian ICO center, Mike Kayamori, co-founder and CEO of Quoine, explained,

“I THINK IT IS BECAUSE THE MAS HAS DONE A GOOD JOB COMMUNICATING WITH THE CRYPTO COMMUNITY. THEY HAVE ALREADY MADE SEVERAL OFFICIAL COMMENTS, ESPECIALLY AROUND ICOS. I THINK IT WILL CONTINUE TO BE A DESTINATION, ESPECIALLY FOR TOKEN ISSUERS.”

Singapore also protects less-sophisticated investors from the vagaries that are so closely associated with the crypto markets. For instance, ordinary investors are limited to transactions of S$3,000 a month through Xfers accounts, the only way to transfer money to Coinbase or CoinHako to purchase crypto currencies using a Singapore bank account. Whilst there are no regulations per se limiting these platforms to such numbers, one wonders why these profit-making behemoths would limit the transaction values of would-be cryptocurrency purchasers without some external pressure.

Overall, the Singapore approach is enlightened and serves as an example for the rest of Southeast Asia to follow. But with clear and well-defined laws, a stable government and an excellent judiciary, Singapore serves the role of clearing house for ICOs from all across Southeast Asia, adding to its already heady GDP growth.

Cryptocurrencies to Rule Them All?

Given the specific geo-political and demographic conditions of Southeast Asia, cryptocurrencies and cryptoassets have the potential to lift the region from economic potential to economic powerhouse. One of the biggest aspirations of the Association of Southeast Asian Nations (ASEAN), a regional grouping of nations which includes, Indonesia, Malaysia, Philippines, Singapore, Thailand, Brunei, Vietnam, Laos, Myanmar and Cambodia has been a common currency, similar to the likes of the Euro. But the experience of the Euro, the fallout for Greece and the sheer diversity in terms of stage of development of the individual Southeast Asian economies means that a common currency remains a pipe dream. Enter cryptocurrencies. Owned by everyone but controlled by no one, technically, cryptocurrencies can plug the gap to draw ASEAN closer together both politically and economically.

The time is ripe for cryptocurrencies and the time is ripe for ASEAN to embrace them. Keep calm and crypto.