Singapore Exchange (SGX)
Team size: 17
Key team members: Glenn Seah (MD and head legal, compliance and corporate secretariat), Karen Ding (head legal (equities)), Yvonne Quek (head legal (FICC)), Dominic Tan (VP, legal), Maria Ho (VP, legal)

What are the most significant cases or transactions that your legal team has recently been involved in?

In July 2023, SGX launched a pioneering derivative Connect linking Singapore and India, opening with US$9 billion in open interest for Indian equity index derivatives (the Nifty). The GIFT Connect, a first-of-its-kind financial corridor, offers international investors a novel route to tap into India’s expanding equities market. Significantly, it brings together SGX’s international client network and domestic Indian participants in a robust liquidity pool for the first time.

The GIFT Connect was the culmination of many months of intense negotiations by the SGX legal team, navigating complex legal, regulatory, and government frameworks in both Singapore and India. It involved aligning shared and conflicting interests, along with highly complex risk management, operational, and technological setups to ensure a high-speed, high-resilience, low-friction experience for all market participants.

The SGX legal team negotiated numerous agreements covering aspects between exchanges and clearing houses, participants, and brokers, such as cost-sharing, revenue distribution, netting, taxation, brokerage, data, technology, and infrastructure, to arrive at a win-win situation for all parties. Additionally, the team introduced innovative solutions to adapt and amend existing conventions, rules, and regulations to meet the novel requirements of the GIFT Connect, requiring ongoing engagement with regulators on both sides. Throughout this process, the SGX legal team went beyond their traditional legal advisory role, offering strategic business leadership that was pragmatic and patient, ultimately aligning the parties with their overarching goals.

In addition to their role in the GIFT Connect, the legal team was deeply involved in the acquisition and integration of several subsidiaries into the SGX Group. SGX’s expansion strategy involved entering related and complementary industries, such as financial technology platform providers and data and benchmarks. Some notable past transactions include the acquisitions of BidFX and MaxxTrader in the OTC FX sector, the Baltic Exchange and Scientific Beta in the data and benchmarks space, as well as investments in businesses like the Wilshire index business, ADDX for private markets, and the Climate Impact Exchange.

In addition to their transactional work, the team played a crucial role in the integration of subsidiaries into the Group. This involved providing direct legal services, along with compliance and corporate secretarial support. This was a significant task as they needed to balance the need to instil the Group’s culture while also preserving the unique and effective qualities of each subsidiary.

Can you sum up the team culture or ethos?

The team is compactly organised, yet it effectively manages all SGX Group’s needs, spanning diverse geographic regions in Asia, Europe, and the US. The team handles various asset classes, including equities, FX, and commodities, as well as data and infrastructure needs. Moreover, the team addresses a comprehensive range of legal and regulatory aspects, encompassing financial regulation, data protection, financial crime, corporate finance, and litigation. In short, we do everything. This compels the team to adopt a can-do attitude, to work as one, and to extract efficiencies across our highly talented team. Every individual officer is expected to be clever, connected, and courageous. To analyse intelligently, engage stakeholders deeply, and ultimately make brave, intelligent decisions, even amidst the fog of war.

Apart from legal matters, has the team worked on other company initiatives?

The legal team provides direct leadership and oversees various corporate culture initiatives, particularly SGX Group’s extensive charitable outreach efforts carried out under the SGX Bull Charge umbrella. The entire team lends their support to these initiatives.

From the perspective of the corporate secretariat, the team is a strong advocate for gender diversity, the promotion of board succession plans, and is actively involved in ESG matters, with a particular focus on the “social” and “governance” aspects.

From a compliance perspective, the team leads the Group’s initiatives to engage with regulators worldwide and meet the complex regulatory requirements that arise in multiple jurisdictions. These requirements range a wide spectrum, encompassing anti-money laundering, anti-bribery, data protection, tax reporting, and financial market infrastructure regulations.