SINGAPORE Law and Practice Contributed by: Kenneth Pereire and Lin YingXin, KGP Legal LLC
vices are marketed to the public, full compliance with licensing requirements will be triggered. These provisions are overseen by the MAS and are similar to the EU’s MiFID II regulations for third-coun - try entities providing services on a cross-border basis. 3. Robo-Advisers 3.1 Requirement for Different Business Models In the context of robo-advisers, the question of whether distinct business models are required for different asset classes revolves around the unique characteristics and risk profiles associated with each class. Different asset classes may require different business models and regulatory approaches. Robo- advisers offering advice on traditional capital markets products, such as listed equities, bonds or collective investment schemes are regulated under the FAA and the SFA and typically operate using model portfolio or discretionary management structures. Where robo-advisers incorporate digital assets or tokenised products into their offerings, additional considerations arise, including the classification of the underlying assets, custody and safeguarding arrangements, technology risk management, volatility management and enhanced suitability and disclosure obligations. In such cases, firms may need to adapt their business models to address higher operational and market risks and to ensure compliance with appli - cable digital asset and AML requirements. 3.2 Legacy Players’ Implementation of Solutions Introduced by Robo-Advisers Robo-advisory solutions have been adopted in Sin - gapore since 2018 with major banks like DBS, UOB and OCBC leading the way. By 2025, these banks have further expanded robo-advisory features, target - ing less experienced individuals by offering accessible investment strategies and general financial advice. For example, DBS introduced DBS DigiPortfolio, which allows customers to invest in diversified portfolios managed by algorithms, seamlessly integrating this service with their traditional banking and wealth man - agement services. Similarly, OCBC RoboInvest offers
automated portfolio management based on risk pref - erences, providing easy access to other financial products like loans and savings accounts. The integration process enables existing bank account holders to access the robo-adviser without the need for separate fund transfers, which typically take one to three working days. This streamlined approach allows customers to invest instantly from their deposit accounts, blending traditional wealth management with modern fintech solutions. 3.3 Issues Relating to Best Execution of Customer Trades Best execution in the context of robo-advisers is a regulatory framework ensuring that financial service providers act in the best interest of their clients, opti - mising outcomes based on factors like price, cost and speed. However, there are challenges such as: • limited access to high-quality data; • rapid market changes during volatility; • technological risks, like system outages and cyber threats; • difficulty in analysing large volumes of data; and • lack of robust best execution policies. In Singapore, robo-advisers like DBS DigiPortfolio and OCBC RoboInvest must ensure favourable execution for client trades, balancing automation with the duty to achieve best prices. These platforms rely on algo - rithms, which must prioritise factors like price and cost, while adhering to the FAA. Technological risks and data volume also add complexity, requiring care - ful monitoring and transparency to meet regulatory standards. 4. Online Lenders 4.1 Differences in the Business or Regulation of Fiat Currency Loans Provided to Different Entities In Singapore, a person who does not lend money to individuals or who lends solely to accredited investors will be an excluded moneylender under the Money - lenders Act 2008, who would not be required to obtain
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