Cryptocurrency Disputes and SIAC Arbitration: Three Procedures Explained

When a dispute arises between a user and a cryptocurrency exchange, the dispute is typically governed by the exchange’s user agreement, which sets out how disagreements must be resolved. In most cases, these user agreements require disputes to be resolved through arbitration rather than court proceedings. The key issue, therefore, is often not whether the dispute must be resolved through arbitration, but how that arbitration will be conducted.

Under the Singapore International Arbitration Centre (“SIAC”) 2025 Rules (“2025 Rules”), cryptocurrency disputes are not all treated in the same way. Depending on the amount in dispute and the circumstances of the case, an arbitration may be conducted under the Streamlined Procedure, the Expedited Procedure, or normal SIAC arbitration. Each of these procedures reflects a different balance between speed, procedural flexibility, and the level of Tribunal involvement, and is designed to ensure that the arbitration process remains proportionate to the nature and value of the dispute. For instance, some disputes involve relatively modest sums and turn primarily on contractual interpretation or transaction records, while others raise more complex issues involving large values, technical evidence, or contested factual and expert questions.

This article examines how cryptocurrency disputes are resolved through arbitration under the 2025 Rules, with a particular focus on:

• how the Streamlined Procedure applies to lower-value cryptocurrency disputes;

• how the Expedited Procedure operates for disputes requiring an accelerated timetable;

• how normal SIAC arbitration applies to higher-value or more complex cryptocurrency disputes; and

• how costs differ across the Streamlined Procedure, Expedited Procedure, and normal SIAC arbitration.

1. Streamlined Procedure for Cryptocurrency Disputes

1.1 What is the Streamlined Procedure?

The Streamlined Procedure under the 2025 Rules is intended to provide a fast and simplified arbitration process for disputes that do not require extensive procedural steps. This is particularly important in cryptocurrency disputes, where issues such as account freezes, forced liquidations, margin calls, or disputed on-chain transfers can have immediate and continuing consequences. As crypto assets can fluctuate rapidly in value, delays in resolving a dispute may affect the value of those crypto assets or a user’s ability to access, withdraw, transfer, or trade them.

The Streamlined Procedure is particularly relevant to certain cryptocurrency disputes involving sums of less than S$1,000,000. It operates on an accelerated basis, with the objective of delivering a final award within 3 months of the Tribunal being constituted. This timetable is achieved by limiting the arbitration primarily to written submissions and documentary evidence, with little or no document production, witness evidence, or hearings. In many cryptocurrency disputes, the central issues turn on the interpretation of the exchange’s user agreement, account records, transaction logs, or blockchain data, rather than contested oral evidence. A focused, document-based process, therefore, allows such disputes to be resolved efficiently and in a manner proportionate to their nature.

1.2 When does the Streamlined Procedure Apply?

The 2025 Rules set out two situations in which the Streamlined Procedure would apply to an SIAC arbitration:

• The Streamlined Procedure applies where you and the other party have agreed to its application before the Tribunal is appointed (Rule 13.1(a) of the 2025 Rules).

Or

• The Streamlined Procedure applies where the amount in dispute in the arbitration does not exceed S$1,000,000 prior to the Tribunal being constituted, unless the SIAC President, upon a party’s application, determines that it should not apply (Rule 13.1(b) of the 2025 Rules).

The SIAC Secretariat will notify you if your arbitration is to be conducted under the Streamlined Procedure (Rule 13.2 of the 2025 Rules).

The parties may agree to exclude the application of the Streamlined Procedure in writing (Rule 13.3 of the 2025 Rules).

1.3 How Does the Streamlined Procedure Work?

Once the Streamlined Procedure applies, the arbitration is conducted under Schedule 2 of the 2025 Rules (“Schedule 2”), which sets out the procedural framework governing the arbitration. Schedule 2 addresses the appointment of the Tribunal, the manner in which the arbitration is conducted, and the timeframe for issuing the final arbitration award. Together, these provisions define the structure of a Streamlined Procedure arbitration. We therefore set out the key features of Schedule 2 below:

1.3.1 Appointment of Arbitrator

The Streamlined Procedure provides for the appointment of a sole arbitrator to ensure that the Tribunal can be constituted quickly and without unnecessary procedural steps.

• A sole arbitrator shall be appointed (Paragraph 1 of Schedule 2).

And

• The parties may jointly nominate the sole arbitrator within 3 days after the date of the SIAC’s Secretariat’s notification that the Streamlined Procedure applies to the arbitration (Paragraph 2 of Schedule 2).

And

• If the parties are unable to jointly nominate the sole arbitrator within that 3-day period, or if at any time, a party so requests, the SIAC President shall appoint the sole arbitrator as soon as practicable (Paragraph 3 of Schedule 2).

1.3.2 How the Streamlined Procedure Is Conducted

The Streamlined Procedure is conducted on a simplified, predominantly document-based basis, reflecting its emphasis on speed and procedural efficiency to support the issuance of a final arbitration award within 3 months.

Unless the Tribunal determines otherwise after considering the views of the parties, the following rules apply under Schedule 2 of the 2025 Rules:

• The arbitration shall be decided on written submissions and any accompanying documentary evidence (Paragraph 11(a) of Schedule 2).

And

• No party shall be entitled to request document production (Paragraph 11(b) of Schedule 2).

And

• No party shall be entitled to file any fact or expert witness evidence (Paragraph 11(c) of Schedule 2).

And

• No hearing will be conducted unless the Tribunal determines that a hearing is necessary under the circumstances, or a party requests a hearing and the Tribunal accepts that request. Any hearing will be conducted by videoconference, teleconference, or other electronic means, unless the parties agree or the Tribunal determines that an in-person or hybrid hearing is appropriate (Paragraph 12 of Schedule 2).

1.3.3 Time Limit for the Award

• The final award shall be made within 3 months from the date of the Tribunal being constituted, unless the Registrar extends the time for making the award (Paragraph 15 of Schedule 2).

2. Expedited Procedure for Cryptocurrency Disputes

2.1 What is the Expedited Procedure?

The Expedited Procedure under the 2025 Rules is designed for cryptocurrency disputes that require a faster resolution than normal SIAC arbitration, but which are not suitable for the highly simplified Streamlined Procedure. Under the 2025 Rules, the Expedited Procedure is generally available where the amount in dispute exceeds S$1,000,000 but does not exceed S$10,000,000, or where the Streamlined Procedure does not apply. The Expedited Procedure reflects a middle ground between speed and procedural flexibility, allowing disputes to be resolved on an accelerated timetable while still accommodating more complex factual, technical, or evidentiary issues.

This procedure is particularly relevant to cryptocurrency disputes involving higher values, more extensive transaction histories, or issues such as margin trading, liquidation mechanics, platform system behaviour, or disputed account actions, where a documents-only process may be insufficient. In such cases, limited document production, witness evidence, or hearings may be necessary to properly address the issues in dispute.

Under the Expedited Procedure, the Tribunal retains greater discretion over the conduct of the arbitration than under the Streamlined Procedure, but the proceedings remain subject to shortened timelines. In particular, the 2025 Rules provide that a final award must be issued within 6 months of the Tribunal being constituted, unless an extension is granted.

2.2 When does the Expedited Procedure Apply?

Whether the Expedited Procedure applies to a particular arbitration depends on a combination of the parties’ agreement, the amount in dispute, and the circumstances of the case. The arbitration shall be conducted in accordance with the Expedited Procedure set out in Schedule 3 of the 2025 Rules (“Schedule 3”), provided the parties have agreed to its application prior to the constitution of the Tribunal. Any agreement by the parties to the application of the Expedited Procedure under a previous rule reference shall be deemed to be an agreement unless the parties have agreed otherwise (Rule 14.1 of the 2025 Rules).

The 2025 Rules set out two situations in which the Expedited Procedure would apply to an SIAC arbitration:

• At the time of the application, the amount in dispute does not exceed the equivalent amount of S$10,000,000 but exceeds the equivalent amount of S$1,000,000 (Rule 14.2(a) of the 2025 Rules).

And

• At the time of the application, the amount in dispute does not exceed the equivalent amount of S$1,000,000, and the President has determined under Rule 13.1(b) of the 2025 Rules that the Streamlined Procedure shall not apply to the arbitration (Rule 14.2(b) of the 2025 Rules).

Or

The circumstances of the case warrant the application of the Expedited Procedure (Rule 14.2(c) of the 2025 Rules).

The President shall, after considering the views of the parties, determine whether to grant an Expedited Procedure application. Where the President grants the application, the Expedited Procedure set out in Schedule 3 shall apply (Rule 14.3 of the 2025 Rules).

• The parties may agree to exclude the Expedited Procedure by agreement in writing (Rule 14.4 of the 2025 Rules).

2.3 How Does the Expedited Procedure Work?

Once the Expedited Procedure applies, the arbitration is conducted on an accelerated basis under Schedule 3. The procedure imposes shortened timelines, with the objective of resolving the dispute efficiently and without unnecessary procedural steps.

The Expedited Procedure does not require the dispute to be decided solely on a documents-only basis. Instead, it permits hearings, document production, and written witness evidence where appropriate, while allowing the Tribunal to limit or dispense with these steps in light of the applicable timelines.

2.3.1 Appointment of Arbitrator

In all arbitrations conducted under Schedule 3, a sole arbitrator shall be appointed unless the President determines otherwise (Paragraph 1 of Schedule 3).

2.3.2 How the Expedited Procedure Is Conducted

Unlike the Streamlined Procedure, the Expedited Procedure does not require the dispute to be determined solely on a documents-only basis. Instead, it permits hearings, document production, and written witness evidence where appropriate, while allowing the Tribunal to limit or dispense with these steps to ensure that the arbitration proceeds efficiently within the applicable timelines.

We set out the key features of Schedule 3 below:

• The dispute shall be decided on the basis of written submissions and any accompanying documentary evidence, unless any party requests a hearing or the Tribunal decides that a hearing would be appropriate (Paragraph 3(a) of Schedule 3).

And

• The Tribunal shall hold any hearing by videoconference, teleconference, or any other form of electronic communication unless the parties agree or the Tribunal determines that it is appropriate to conduct an in-person or hybrid hearing (Paragraph 3(b) of Schedule 3).

And

• The Tribunal shall have the power to adopt any procedural mechanisms as it considers appropriate, taking into account the timelines under the Expedited Procedure (Paragraph 3(c) of Schedule 3).

And

• The Tribunal may, after considering the views of the parties, decide not to allow requests for document production or to limit the number, length, and scope of written submissions and written witness evidence (Paragraph 3(d) of Schedule 3).

2.3.3 Time Limit for the Award

• The final award shall be made within 6 months from the date of constitution of the Tribunal, unless time is extended for making such a final award (Paragraph 6 of Schedule 3).

3. Normal SIAC Arbitration for Cryptocurrency Disputes

Where a cryptocurrency dispute does not qualify for the Streamlined or Expedited Procedures, it will be resolved under the normal SIAC arbitration. This is the default procedure for SIAC arbitrations and applies to higher-value or more complex disputes.

Arbitrations conducted under the normal SIAC arbitration are subject to a structured and institutionally supervised process. Published SIAC statistics indicate that SIAC arbitrations have an average duration of approximately 13.8 months and amedian of around 11.7 months, measured from the commencement of the arbitration to the issuance of the final award. These figures provide a practical indication of the typical timeframe for a normal SIAC arbitration.

The normal SIAC arbitration allows the Tribunal greater procedural flexibility than the Streamlined or Expedited Procedures. In particular, the Tribunal may permit document production, fact and expert witness evidence, and hearings where this is appropriate. This makes the normal SIAC arbitration suitable for cryptocurrency disputes involving detailed transaction histories, complex contractual arrangements, technical issues related to digital assets, or disputed valuation questions. At this level of complexity, instructing a law firm with SIAC arbitration experience from the outset is advisable.

4. Comparison of Arbitration Costs Across SIAC Procedures

Beyond procedural differences, the choice between the Streamlined Procedure, the Expedited Procedure, and normal SIAC arbitration has a direct and often significant impact on costs. Each procedure is subject to a different fee structure under the SIAC Schedule of Fees 2025, and these differences can substantially affect the overall financial exposure of a cryptocurrency dispute, particularly as the amount in dispute increases.

The examples below illustrate how SIAC administration fees and Tribunal fees compare across the 3 procedures for disputes of differing values.

For ease of reference, SIAC also provides an online cost calculator that allows you to estimate applicable fees before commencing arbitration.

SIAC Cost Calculator: https://siac.org.sg/fee-calculator

SIAC Schedule of Fees 2025: https://siac.org.sg/siac-schedule-of-fees-2025

4.1 Streamlined Procedure Fees

Under the SIAC Schedule of Fees 2025, a S$1,000,000 dispute (with a sole arbitrator) would attract the following fees:

4.1.1 SIAC Administration Fee (Maximum)

Formula:

S$10,000 + 1.0% of the excess over S$500,000
1.0% × S$500,000 = S$5,000

Total SIAC Administration Fee: S$15,000

4.1.2 Arbitrator’s Fee (Maximum)

Formula:

S$35,000 + 5.0% of the excess over S$500,000
5.0% × S$500,000 = S$25,000
Total Arbitrator’s Fee: S$60,000

4.1.3 SIAC Administration and Arbitrator’s Fees (Maximum)

S$60,000 + S$15,000 = S$75,000 (excluding GST, filing fee, and other expenses)

4.1.4 50% of SIAC Administration and Arbitrator’s Fees (Maximum)

The Streamlined Procedure caps the SIAC administration fees and the Tribunal’s fees at 50% of the maximum amounts otherwise payable under the SIAC Schedule of Fees 2025 (Rule 16 of the 2025 Rules).

50% × S$75,000 = S$37,500

Therefore, for a S$1,000,000 dispute conducted under the Streamlined Procedure, the maximum SIAC administration fees and the Tribunal’s fees are capped at approximately S$37,500.

4.2 Expedited Procedure Fees

Under the SIAC Schedule of Fees 2025, a S$5,000,000 dispute (with a sole arbitrator) would attract the following fees:

4.2.1 SIAC Administration Fee (Maximum)

Formula:

S$36,000 + 0.24% of the excess over S$5,000,000

0.24% × S$5,000,000 = S$12,000

Total SIAC Administration Fee: S$48,000

4.2.2 Arbitrator’s Fee (Maximum)

Formula:

S$130,000 + 0.8% of the excess over S$5,000,000

0.8% × S$5,000,000 = S$40,000

Total Arbitrator’s Fee: S$170,000

4.2.3 SIAC Administration and Arbitrator’s Fees (Maximum)

S$170,000 + S$48,000 = S$218,000 (excluding GST, filing fee, and other expenses)

Accordingly, for a S$10,000,000 dispute conducted under the Expedited Procedure, the maximum SIAC administration fees and the Tribunal’s fees payable would be approximately S$218,000, excluding GST, filing fees, and other expenses.

4.3 Normal SIAC Arbitration Fees

Under the SIAC Schedule of Fees 2025, aS$10,000,000 disputeconducted under thenormal SIAC arbitration would attract the following fees:

4.3.1 SIAC Administration Fee (Maximum)

Formula:

S$36,000 + 0.24% of the excess over S$5,000,000

0.24% × S$5,000,000 = S$12,000

Total SIAC Administration Fee: S$48,000

4.3.2 Arbitrators’ Fee (Maximum)

Formula:

S$130,000 + 0.8% of the excess over S$5,000,000

0.8% × S$5,000,000 = S$40,000

Fee per Arbitrator: S$170,000

Total Arbitrators’ Fee (3 Arbitrators): S$170,000 *3 = S$510,000

4.3.3 SIAC Administration and Arbitrators’ Fees (Maximum)

S$510,000 + S$48,000 = S$558,000 (excluding GST, filing fee, and other expenses)

Therefore, for a S$10,000,000 dispute conducted under the normal SIAC arbitration, the maximum SIAC administration fees and the Tribunal’s fees payable would be approximately S$558,000, excluding GST, filing fees, and other expenses.

4.4 Summary Comparison of SIAC Administration and Tribunal Fees

Procedure	Amount in Dispute	Tribunal Composition	Maximum SIAC Administration & Tribunal Fees (Excluding GST, filing fees, and other expenses)
Streamlined Procedure	S$1,000,000	Sole Arbitrator	~S$37,500
Expedited Procedure	S$10,000,000	Sole Arbitrator	~S$218,000
Normal SIAC Arbitration	S$10,000,000	3 Arbitrators	~S$558,000

As the comparison above shows, the choice of SIAC procedure can result in a material difference in administration and Tribunal fees, particularly for higher-value disputes. Not all arbitration firms have the experience to advise on which procedure is most appropriate at the outset, and an incorrect election can have cost consequences that are difficult to reverse.

5. Farallon Law Corporation: Choosing the Right SIAC Procedure for Cryptocurrency Disputes

When disputes with cryptocurrency exchanges arise, how they are handled can matter just as much as the underlying issue. Under the SIAC 2025 Rules, disputes may proceed under the Streamlined Procedure, the Expedited Procedure, or normal SIAC arbitration, each with its own procedural and fee framework. Which SIAC procedure applies can affect how quickly the dispute moves, how many arbitrators are involved, and how much is ultimately paid in administration and Tribunal fees.

As this article shows, the SIAC procedure applicable to a cryptocurrency dispute depends largely on the amount in dispute and the complexity of the issues. In the cryptocurrency context, where values can change quickly, this can affect both timing and cost. Engaging a cryptocurrency litigation lawyer in Singapore at an early stage can help ensure that the correct procedure is identified and that the arbitration is commenced correctly from the outset.

Farallon Law Corporation advises clients on disputes involving cryptocurrency exchanges and crypto asset transactions, including arbitration under the 2025 Rules. For guidance on how the applicable SIAC procedure and fee structure may affect your dispute, please contact Farallon Law Corporation by email or via our contact form.