Written by Written by Nicolas Tang and Lareina Chan
Cryptocurrency disputes are now routinely resolved through arbitration. In practice, however, the effectiveness of arbitration depends heavily on how the courts at the seat of arbitration approach and support arbitration proceedings. This is especially significant in cryptocurrency disputes, which often involve crypto assets accessed through private keys, transactions recorded on distributed ledgers, and platforms operating across multiple jurisdictions. These disputes frequently turn on questions of ownership, control, and access to information, sometimes in circumstances where key evidence is held by a single party.
A seat with a clear, consistent, and arbitration-supportive judicial framework provides the procedural certainty necessary for arbitration to function effectively in cryptocurrency disputes. Without that framework, a party may face the risk of a lawsuit being commenced in a foreign court, parallel proceedings, or an award that cannot be enforced. As the following sections explain, Singapore law and the approach taken by the Singapore courts offer a predictable and reliable framework for resolving such disputes through arbitration.
This article examines how Singapore law and Singapore courts support cryptocurrency arbitration in practice, and focuses on the following issues:
For arbitration to be effective, the dispute must involve rights that the law recognises and that courts are prepared to enforce. Under Singapore law, intangible crypto assets can be owned and protected by law, even though they exist only in digital form and are accessed using cryptographic keys rather than physical possession. This position was stated expressly in ByBit Fintech Ltd v Ho Kai Xin and others [2023] SGHC 199, where the Singapore High Court held that “the holder of a crypto asset has in principle an incorporeal right of property recognisable by the common law as a thing in action and so enforceable in court.” As a result, disputes involving cryptocurrency concern legally recognised rights that arbitration Tribunals can decide, and that Singapore courts can support and enforce when an arbitration award is issued.
Later Singapore cases have proceeded on the basis that cryptocurrency is property. In Cheong Jun Yoong v Three Arrows Capital Ltd [2024] SGHC 21 (“Cheong”), which arose from the collapse of a cryptocurrency hedge fund, the Singapore High Court treated cryptocurrency holdings as assets capable of being owned, controlled, and dealt with in liquidation. The Singapore High Court focused on how the crypto assets were held and who had rights to them under insolvency law, without needing to reconsider whether cryptocurrency itself could be the subject of ownership. That approach was extended in Re Taylor, Joshua James and another (Official Receiver, non-party) [2025] SGHC 104, which concerned the liquidation of a digital asset exchange. The Singapore High Court was required to decide who held legal and beneficial ownership of unclaimed cryptocurrencies held on the exchange. The Singapore High Court resolved that issue by analysing ownership of the crypto assets themselves, confirming that crypto assets can be subject to separate legal and beneficial ownership under Singapore law.
When an arbitration tribunal seated in Singapore decides who has rights to crypto assets, or how those assets should be handled, it can do so knowing that the courts will recognise those rights and give effect to them when the arbitration award is enforced. This makes arbitration a reliable way to resolve cryptocurrency disputes in Singapore, because the legal status of crypto assets is clearly recognised and does not need to be re-examined at the enforcement stage.
Singapore offers a predictable environment for cryptocurrency disputes because its courts analyse them using established principles of commercial law, rather than treating them as a fundamentally separate category of cases. This approach reduces uncertainty by ensuring that disputes are resolved by reference to familiar legal concepts, rather than the novelty of the underlying technology. This can be seen in Cheong, where the Singapore High Court dealt with claims arising from the collapse of a cryptocurrency hedge fund that had been placed into liquidation. The Singapore High Court treated crypto assets as property capable of ownership, control, and enforcement, and resolved the dispute by applying orthodox principles of trust and insolvency law, without developing any cryptocurrency-specific rules. This is also illustrated in Beltran, Julian Moreno and others v Terraform Labs Pte Ltd and others [2025] SGHC(I) 17, which arose after the Terra/Luna cryptocurrency lost most of its value. The Singapore High Court focused on the representations made to users, whether those statements were false, and whether investors had been induced to transact and had suffered losses as a result. The Singapore High Court noted in particular that the “Conceded Representations were false statements of fact fraudulently made”, and assessed whether investors had suffered “losses flowing from” those representations.
Taken together, these cases demonstrate a consistent and predictable judicial approach. Across a wide range of cryptocurrency disputes, Singapore courts focus on the underlying commercial substance rather than the technical novelty of the blockchain or token involved. In a market where transactions commonly span multiple jurisdictions, exchanges, and counterparties, this clarity is a key reason why Singapore is increasingly chosen as a seat for cryptocurrency arbitration.
This position is reflected in the 2025 International Arbitration Survey conducted by Queen Mary University of London and White & Case. Singapore ranked among the top five most preferred arbitration seats worldwide, selected by 31% of respondents, placing it second globally. Respondents pointed in particular to Singapore’s strong judicial support for arbitration, the quality of its legal infrastructure, and the efficiency and predictability of its courts, including in complex cross-border enforcement scenarios.
A key reason Singapore is well-suited as a seat for cryptocurrency arbitration is that its courts actively enforce arbitration agreements and prevent parallel court proceedings from undermining them, even in cross-border disputes. Where parties have agreed to arbitrate in Singapore, the courts will intervene to ensure that the dispute is resolved in arbitration, rather than allowing one party to sidestep that agreement by commencing litigation in another jurisdiction. This principle was applied in TrueCoin LLC v Techteryx, Ltd [2024] SGHC 296 (“Truecoin”), where the parties had agreed to resolve their dispute through Singapore-seated arbitration, but one party nonetheless commenced court proceedings in Hong Kong. The Singapore High Court granted an anti-suit injunction, ordering that the Hong Kong lawsuit be halted so that the dispute could proceed in arbitration in Singapore. In doing so, the Singapore High Court rejected arguments that it should defer to the foreign court or tolerate parallel proceedings simply because different laws or documents were involved, emphasising that delay would “completely undermine” the purpose of anti-suit injunctions.
Singapore courts have also made clear that once their supervisory jurisdiction is properly engaged, their orders must be respected, even in complex cross-border insolvency or restructuring contexts. This was illustrated in Beltran, Julian Moreno and others v Terraform Labs Pte Ltd and others [2025] SGHC(I) 17, which arose out of the collapse of the Terra/Luna ecosystem and Terraform’s restructuring proceedings commenced in the United States. Although aspects of those foreign proceedings were recognised in Singapore, non-parties took steps that interfered with the effect of the Singapore court’s orders. The Singapore International Commercial Court responded firmly, imposing “full costs” on the non-parties and emphasising that parties who “knowingly” act in disregard of Singapore court orders, including orders recognising foreign proceedings, cannot expect to do so without consequence. The Singapore International Commercial Court made clear that recognition orders are not merely procedural in nature. Once granted, they are binding and must be complied with.
These cases demonstrate that where parties have chosen Singapore as the seat of arbitration, Singapore courts will protect that choice and prevent foreign court proceedings from disrupting the arbitration process. This is particularly important in cryptocurrency disputes, which frequently span multiple jurisdictions and create opportunities for tactical litigation.
While Singapore courts actively support arbitration, they have made clear that this support has defined boundaries. Court assistance is not automatic simply because an arbitration is seated in Singapore. Instead, the courts draw clear lines around when they will intervene, particularly where third parties or foreign actors are involved. This clarity enables parties in cross-border cryptocurrency disputes to realistically assess enforcement risks from the outset.
The mere fact that an arbitration is seated in Singapore is not, by itself, enough to justify court intervention against overseas non-parties. This was illustrated in Alphard Maritime Ltd v Samson Maritime Ltd and others [2025] SGHC 154, where the Singapore High Court considered whether interim court orders could be granted against non-parties in support of a Singapore-seated arbitration. The Singapore High Court made clear that it will not issue orders against overseas third parties simply because an arbitration is based in Singapore. Instead, the Singapore High Court noted it will only step in where there is a real connection to Singapore, for example, where the third party controls assets located in Singapore, or where court intervention is necessary to prevent the arbitration award from being undermined. The Singapore High Court further emphasised that support for arbitration “requires something more than just the arbitration being seated in Singapore”, and that restraining third parties without a proper jurisdictional basis had “no basis”.
For cryptocurrency disputes, this clarity is especially important. Cryptocurrency ecosystems often involve exchanges, lenders, custodians, counterparties, and creditors located in multiple jurisdictions. By clearly defining the limits of court intervention, Singapore provides parties with a transparent framework for understanding when its courts will step in, and when enforcement must instead be pursued through other jurisdictions or mechanisms.
5. How Singapore Courts Safeguard Procedural Fairness in Cryptocurrency ArbitrationIn cryptocurrency disputes, procedural fairness is extremely important. Such cases often involve disputed transaction histories, wallet access, platform controls, or representations made in white papers, on websites, or on social media. They may also turn on information held by one party alone, such as internal exchange logs, custody arrangements, algorithmic parameters, or platform communications. Where a party is not given a fair opportunity to place relevant evidence before the Tribunal, the dispute cannot be properly resolved.
Singapore courts have therefore emphasised that arbitration procedures must always preserve each party’s right to be heard, even where efficiency or procedural flexibility is prioritised. Procedural rules are acceptable only if they allow the Tribunal to reach a properly informed decision. This principle was articulated by the Singapore Court of Appeal in China Machine New Energy Corp v Jaguar Energy Guatemala LLC [2020] SGCA 12, which stressed that arbitration must provide parties with “a fair opportunity to prepare and present [their] case before a neutral and unbiased decision-maker”.
Singapore courts have also made clear that the final and binding nature of arbitration makes procedural fairness even more important. In DJP and others v DJO [2025] SGCA(I) 2, the Singapore Court of Appeal reaffirmed that where arbitration produces a final outcome, “particular attention must be paid to the integrity of the process by which a decision is reached”. If that integrity is compromised, court intervention may be justified.
For users involved in cryptocurrency disputes, this approach provides confidence that arbitration in Singapore will be conducted efficiently without sacrificing procedural fairness and that the arbitration process will remain both practical and reliable.
In cryptocurrency disputes, arbitration does not operate independently of the courts. Court decisions can determine whether crypto assets are treated as enforceable property, whether arbitration may proceed without interference from foreign litigation, and whether an arbitration award will ultimately be recognised and enforced.
Singapore provides a legal environment in which these issues are addressed clearly and predictably. This allows parties to resolve cryptocurrency disputes through arbitration with greater certainty about how courts will approach questions of ownership, court support, and enforcement. For parties involved in cryptocurrency disputes, decisions about where an arbitration is seated and how court applications are handled can have a material impact on the dispute outcome. Understanding the approach taken by the courts at the seat is therefore an important part of cryptocurrency dispute strategy.
Farallon Law Corporation is a legal firm that advises clients on cryptocurrency and crypto asset disputes, including Singapore-seated arbitrations and related court proceedings. For guidance on cryptocurrency disputes, please contact Farallon Law Corporation by email or via our contact form.
Cryptocurrency disputes commonly arise from frozen or restricted accounts, unauthorised transactions, failed withdrawals, forced liquidations, alleged fraud or misrepresentation, and disagreements over asset ownership or custody. Disputes may also involve exchange insolvency, smart contract failures, and token valuation losses. The applicable forum and governing law depend on the exchange’s user agreement.
Yes, but the process depends on which cryptocurrency exchange was used and the terms of its user agreement. Most exchanges require disputes to be resolved through arbitration rather than court proceedings. The applicable jurisdiction, arbitral rules, and pre-arbitration notice requirements will determine whether a cryptocurrency exchange dispute can be effectively pursued. If you are considering pursuing a claim, contact a cryptocurrency litigation lawyer for advice on your legal position and options.
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Singapore 049320
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