Eugene Ng on Geographic Arbitrage: How Regulatory Competition Between Jurisdictions is Reshaping Global Crypto Markets

There’s a moment in every serious crypto business conversation when someone asks: “So where are you actually registered?” The question reveals more than legal curiosity—it exposes the fundamental reality that in 2025, geographic location determines what’s possible in digital assets more than technology, capital, or team quality combined.

Eugene Ng learned this through direct experience obtaining Singapore’s registered fund management license from the Monetary Authority of Singapore, then becoming the first fintech project in Asia to secure Bermuda’s Digital Asset Business Act license. The process taught him what most operators eventually discover: regulatory frameworks aren’t just compliance hurdles. They’re strategic assets determining market access, product capabilities, and competitive positioning.

“Singapore has some very thoughtful regulations around cryptocurrency,” Ng explains, reflecting on his time leading Gemini’s Asia-Pacific expansion. “The ethos of Gemini really is to work with regulations. We like regulations. We welcome that.”

But welcoming regulation and strategically positioning across jurisdictions are different skills. The former is about compliance. The latter is about competitive advantage.

The New Geography of Digital Finance

Traditional finance has always involved regulatory arbitrage—witness London’s Eurodollar market, Delaware corporate law, or Swiss banking privacy. But cryptocurrency accelerates this dynamic to unprecedented levels. Unlike banks requiring physical branches, crypto platforms can relocate operations with relative ease. The constraint isn’t infrastructure—it’s regulatory permission.

By 2025, distinct regulatory hubs compete for crypto business through differentiated frameworks. Singapore offers clarity and institutional credibility through MAS oversight. Hong Kong is reopening, with the SFC planning to permit crypto derivatives for professional investors starting 2025. Dubai’s Virtual Assets Regulatory Authority granted the first full derivatives exchange license to Deribit in 2023. The EU implemented Markets in Crypto-Assets regulation with harmonized rules but strict sustainability disclosures and retail leverage caps.

The United States remains fragmented. The CFTC regulates commodity derivatives like Bitcoin futures. The SEC claims securities authority, though definitions remain contentious. States pursue independent agendas—New York imposed moratoriums on fossil-fuel-powered mining while Texas recruits miners with promises of grid participation.

Sophisticated platforms now maintain multiple licensed entities across jurisdictions, each serving different client segments under applicable frameworks. This isn’t regulatory arbitrage in the pejorative sense—it’s strategic adaptation to reality that different jurisdictions offer different advantages.

Singapore’s Institutional Credibility Premium

Singapore’s emergence as Asia’s primary crypto hub reflects deliberate policy. The Payment Services Act requires licensing with stringent requirements around AML compliance, technology risk management, and customer asset segregation. By early 2024, MAS licensed only 19 service providers—selectivity signaling quality over quantity.

For operators, the Singapore license provides institutional credibility across Asia. When Ng describes Singapore’s “very thoughtful regulations,” he recognizes that thoughtfulness translates into trust from institutional allocators. A Singapore-regulated entity can have conversations with Asian family offices, sovereign wealth funds, and corporate treasuries that offshore platforms cannot access.

Ng’s experience obtaining fund management licensing from MAS enabled managing institutional assets under supervision, opening doors closed to unregulated entities. When describing helping grow assets under management by close to $150 million within twelve months, regulatory structure provided the growth foundation.

“I’m not surprised, given that Singapore is positioning itself as a crypto fintech hub in Asia Pacific,” Ng notes about traditional banks like DBS launching crypto services. “I think it’s a great testimony that legitimizes the entire asset class. As the saying goes, a rising tide lifts all boats.”

Hong Kong’s Calculated Reopening

Hong Kong presents contrasting regulatory evolution. After years of restrictive policies driving crypto businesses to Singapore and Dubai, Hong Kong executed a calculated reopening. The SFC announced plans in February 2025 to expand frameworks covering crypto derivatives and margin lending on licensed platforms.

The timing reflects Hong Kong’s recognition that its historical advantage as Asia’s financial center requires digital asset adaptation. Unlike Singapore’s measured selectivity, Hong Kong appears more aggressive—issuing at least nine exchange licenses by early 2025. Licensed platforms can offer approved large-cap tokens to retail clients under strict suitability checks.

For derivatives, initial permissions target professional investors with appropriate risk disclosures. This phased approach mirrors Singapore’s strategy of building institutional infrastructure before broader retail access. Hong Kong’s advantage is existing financial services ecosystem—custody providers, prime brokers, legal expertise. Its challenge is overcoming reputational damage from the restrictive period when major platforms chose other domiciles.

Dubai’s Aggressive Courtship

Dubai represents the most aggressive regulatory competitor, using permissive frameworks and fast licensing to attract major platforms. VARA was established in 2022 with explicit goals of making Dubai a global crypto hub. By 2025, approximately 30 VASPs held licenses including Binance, Crypto.com, and Deribit.

Deribit’s Full Market Product license in 2023 marked a watershed, authorizing crypto derivatives exchange operations for professional clients—permission denied or delayed in many jurisdictions. For platforms seeking regulatory bases permitting sophisticated trading, Dubai moved faster than alternatives.

Broader UAE strategy extends beyond licensing speed. Free zones offer zero taxation, residency visas for crypto entrepreneurs, and business-friendly policies. Abu Dhabi’s ADGM has regulated crypto trading since 2018, targeting institutional participants with commodity-like treatment.

This creates interesting dynamics. Platforms can maintain operations across Singapore (institutional credibility), Hong Kong (China-adjacent access), and Dubai (permissive derivatives and tax efficiency). Each jurisdiction serves different strategic purposes rather than competing directly.

Strategic Implications for Multi-Jurisdictional Operations

For operators building crypto businesses, geographic strategy requires matching jurisdictional advantages to business models. Institutional asset managers prioritize Singapore and Hong Kong licenses for allocator credibility. Derivatives platforms look to Dubai for permissions. Consumer applications targeting Europe need MiCA compliance. U.S. operations require navigating CFTC-SEC fragmentation plus state considerations.

Sophisticated platforms increasingly operate multi-entity structures: parent company in business-friendly jurisdiction owning licensed operating entities in markets where they serve customers. This structure is expensive—each license requires capital, local staff, compliance infrastructure, and ongoing regulatory engagement. But it’s increasingly necessary for serving global customer bases.

Ng’s experience obtaining both Singapore fund management licensing and Bermuda’s DABA license illustrates this multi-jurisdictional reality. The Bermuda license enabled certain structured products and tokenization activities. The Singapore license provided institutional custody and fund management capabilities. Different licenses unlocked different capabilities, requiring strategic decisions about where to invest compliance resources based on target markets.

“When I first spoke with institutions six months ago, the response was very lukewarm,” Ng recalls. “Fast forward today, they’re actually sending us a lot of inquiries. It’s all in-bound.” That shift from outbound selling to inbound interest reflects institutional comfort increasing—but that comfort requires regulatory boxes checked through proper licensing in credible jurisdictions.

Jurisdiction as Competitive Moat

Looking forward, expect continued fragmentation and competition. Jurisdictions recognize that attracting crypto business means jobs, tax revenue, and positioning in emerging financial infrastructure. Singapore will maintain selective, quality-focused licensing. Hong Kong will compete more aggressively. Dubai will emphasize speed and permissions. The EU will prioritize comprehensive oversight. The U.S. will remain fragmented pending legislative clarity.

For serious operators, this means geographic strategy is product strategy. Where you can get licensed determines what products you can offer to which customers. Success requires understanding comparative regulatory frameworks—knowing which jurisdictions enable which activities, and how to structure entities compliantly across multiple regimes.

“Singapore, ideally, it has the right infrastructure. It has the skilled workforce. It’s got the right supportive regulations,” Ng emphasizes. “And with that sort of regime, it’s going to be really healthy for cryptocurrency companies.”

In an industry where “move fast and break things” was once the ethos, geographic regulatory strategy has become the competitive moat that matters. The platforms succeeding at institutional scale aren’t necessarily those with the best technology or most aggressive marketing. They’re those that understood early that in digital finance, jurisdiction is destiny—and invested accordingly in building the right licenses in the right places to serve the customers that matter most.

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