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ANLIAN GROUP

Case study · C7

Hong Kong Crypto Fund: 13O Path with MAS CMSL Sister Entity

Disclaimer

This case study is anonymized. Identifying details have been changed and the engagement described may combine multiple Anlian Group engagements with similar features. Outcomes are illustrative; individual situations vary.

Client profile

Industry
Digital Asset / Crypto Fund Management
Origin
Greater China (Hong Kong)
Engagement period
Scenario timeline: 9-12 months for both 13O award and CMSL licensing
Size
Multi-strategy crypto fund with traditional assets allocation; AUM in 13O qualifying range

The situation

A Hong Kong crypto fund manager wanted to relocate the fund-management activity to Singapore. The mandate combined crypto allocations with traditional Designated Investments. The fund qualified for Section 13O on the traditional-asset portion; the crypto allocations needed careful framing because not all crypto-asset holdings fit within the Designated Investments definition. A separate question was whether the fund management activity itself required a Capital Markets Services Licence (CMSL) from MAS, given the regulated scope of crypto-asset fund management under MAS rules. The principal wanted both questions resolved in a single coordinated MAS engagement.

What we did

  1. Step 1

    Mapped the asset base against the Designated Investments list

    We worked through which crypto-asset holdings sat within the Designated Investments list (where applicable) and which fell outside. The traditional-asset portion clearly qualified; the crypto portion required article-by-article analysis.

  2. Step 2

    Engaged MAS on the integrated 13O + CMSL pathway

    We approached MAS with both the 13O application and the CMSL licensing question in a coordinated package. MAS engagement on integrated requests is more efficient than serial engagement when the substance overlaps.

  3. Step 3

    Built the substance for both the SFO / fund manager and the CMSL entity

    For 13O, we built the SFO with the qualifying investment professional and the local capital deployment commitment. For the CMSL entity (a sister legal entity), we built the licensed-fund-manager substance per MAS guidelines.

  4. Step 4

    Onboarded with MAS-licensed financial institutions for crypto and traditional asset custody

    Custody arrangements differ for crypto versus traditional Designated Investments. We coordinated with Singapore-licensed custodians and prime brokers to set up dual-track custody that satisfies both the 13O Designated Investments custody side and the CMSL operational side.

Outcome

Section 13O was awarded for the fund vehicle on the traditional-asset Designated Investments portion. The CMSL was issued for the sister entity covering the regulated fund management activity. The crypto allocations were structured per the MAS-aligned framing — sitting outside the 13O exemption where the holdings did not fit Designated Investments, but within the CMSL-regulated scope.

What this case illustrates

Crypto fund managers relocating to Singapore face a two-track engagement with MAS: 13O for the qualifying traditional-asset portion of the fund vehicle, and CMSL for the regulated fund management activity. Integrating both tracks into a single MAS conversation is more efficient than treating them as independent. The Designated Investments scope question for crypto holdings requires asset-by-asset review, not a generic answer.

Could this be your situation?

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