Rajah & Tann Singapore LLP

Partner, Rajah & Tann Singapore LLP

Samuel Lim is a Partner in the firm’s Financial Institutions Group, a specialist advisory practice in the area of financial services. The group’s wide range of work expertise and experience covers the entire spectrum of legal solutions for problems including structuring of products and services to achieve the right-sized regulatory outcomes, compliance with business conduct and other regulatory requirements,  advice and assistance with commercial transactions with a regulatory angle, and legal documentation drafting and negotiation.

Samuel has assisted in providing a wide range of clients advice on a range of legal and regulatory problems, with a particular emphasis in recent times for those at the cutting edge of financial industry innovation, including those in the financial technology (“FinTech”), payments, crowdfunding and virtual and digital currencies space.

Notable Cases & Transactions

Financial Institutions

Advising one of the largest local banks in Singapore on their proposed joint venture with a sovereign wealth fund, and one of the largest global banks to develop a technology platform that would facilitate bank-to-bank payment transactions without the need for nostro accounts Advising one of the world’s largest social media platforms on its proposed global issuance of a novel “stablecoin” virtual currency. Advising one of the world’s largest messaging applications on their global initial coin offering of digital tokens as well as exchangeable notes redeemable for digital tokens, raising in the region of USD100 million in one week. Advising Baring Private Equity Asia on its acquisition of Tricor Group Advising one of China’s largest fintech companies on their provision of credit analysis services supporting a bank’s microlending platform, and whether provision of a service warranty for the credit analysis would be regulated under the Insurance Act or other financial service laws. Advising an online direct life insurer in Singapore on their novel hybrid product combining life insurance elements with payment services elements including formulating regulatory strategy for seeking exemptions from licensing and business conduct requirements. Assisting 5 of the largest e-wallet providers with the review and very involved negotiation of extensive documentation relating to their entry into the local banks’ electronic funds transfer system and central addressing system. Advising one of the world’s largest messaging applications on their global initial coin offering of digital tokens as well as exchangeable notes redeemable for digital tokens, raising in the region of USD100 million in one week. Assisting one of the world’s largest payment service providers with preparing for the regulatory impact of the Payment Services Act 2019 and compliance with the same, and providing very substantive feedback to the Monetary Authority of Singapore on new laws. Assisting a local Singapore bank with the drafting of the documentation to support their regional liquidity management and cash sweeping solution services for their regional clients Assisting a real estate tokenization platform with the drafting and review of their trading rules, listing rules and other customer-facing documentation Advising on the Singapore regulatory issues involved in the merger of one of the world’s largest private markets firms with one of the largest private markets firms in Asia, and assisting with the relevant applications to the MAS in Singapore for approval of the transaction Advising one of the largest global cryptocurrency exchanges on their setup of a cryptocurrency futures trading platform in Singapore. Advising one of the world’s largest travel booking sites on their suite of 30 or more financial and payment solutions and restructuring to achieve their desired regulatory classification. Acting as lead instructing counsel to provide multi-jurisdictional advice to a major mobile e-wallet provider through our firm’s Singapore, Thailand, Malaysia, Indonesian and Philippines offices on their intended cross-border payments project involving a centralized switch. Assisting a leading global bank with the drafting of their accredited investor “opt-in forms” and to satisfy their requirement for drafting that was clearer and less unwieldy than the industry standard templates. Advising a global payment card network on the application of the payment services laws in Singapore. Assisting a Chinese consortium in preparing and submitting an application for a digital wholesale bank licence from the Monetary Authority of Singapore. Assisting one of Singapore’s largest widely accepted stored value facilities (under the then applicable laws) with conducting a gap analysis and review of their anti-money laundering policies to address an audit by the MAS Advising in relation to an accounts receivable platform on the licensing and regulatory implications of its business under the Securities and Futures Act, Payment Services Act and Insurance Act. Advising a Chinese precious metals trading platform on the licensing and other regulatory implications of their complex products and structuring of the products to fall outside the scope of regulation. Assisting a foreign exchange trading platform with the drafting of their standard terms and conditions with the liquidity providers on the platform and their retail customers. Assisting a joint venture between one of the largest financial market infrastructures in Europe and an Asia-based digital asset company with their setup of an institutional grade platform for the trading, listing and offering of security tokens and digital payment tokens, including assistance with the relevant licence applications and the drafting of various documentation including the listing and trading rules.

LLB (Hons), National University of Singapore Advocate & Solicitor, Singapore