What each side has said
Hyperliquid Labs, the company behind one of the most talked-about perpetual futures venues in crypto, says it is based in Singapore. It confirmed as much to the Financial Times this week; its recent job advertisements asked candidates whether they could work in the Singapore office, and company documents seen by the paper give Singapore as its registered headquarters.1 The Monetary Authority of Singapore has said little on the record. It warned investors in June that it did not regulate Hyperliquid’s perpetual futures, and it told the FT that it was not aware of Hyperliquid being regulated in any major jurisdiction. People familiar with its thinking told the paper that MAS did not believe Hyperliquid was based in Singapore, given its “decentralised nature”, and so did not consider it to fall within its jurisdiction.1
The company told the FT that Hyperliquid “is not, and has never claimed to be, licensed or authorised by MAS”.1 In the United Kingdom the Financial Conduct Authority has placed Hyperliquid on its Warning List as a firm that is not authorised and may be targeting people in the UK. The entry is a consumer warning about an unauthorised firm and records no assessment of the protocol as a whole. It names two websites, one for the trading application and one for a foundation.2
Two statements about different subjects
Read quickly, the FT’s account looks like a contradiction, with the company placing itself in Singapore and the regulator placing it elsewhere. The reported positions in fact concern different subjects. Hyperliquid Labs is describing a company, with an office, staff and a registered seat. MAS, so far as the reporting goes, is describing the protocol and the perpetual futures traded on it. A company’s location does not by itself settle how local law applies to software the company has written or to the trading that software supports, and nothing in the reporting suggests that MAS has formed a view on Hyperliquid Labs as a company.
Whether those two subjects can be separated in practice is the more difficult question. The FCA’s entry lists a foundation’s website alongside the trading application, but the public reporting does not explain which body does what.
Singapore’s own perimeter
Singapore’s recent legislation indicates that, for the services it specifies, a business operating from Singapore does not escape the regulator’s concern merely because every customer is abroad. Under the regime for digital token service providers in the Financial Services and Markets Act 2022, in force from 30 June 2025, providers of services in digital payment tokens or tokens representing capital markets products who serve customers exclusively outside Singapore became subject to licensing. MAS said it would generally not grant those licences, citing money-laundering risk and the difficulty of supervising regulated activity conducted outside Singapore, and existing providers without one were required to cease that activity when the regime took effect.3 The regime reaches Singapore corporations, and individuals operating from Singapore, even where all of their customers are overseas.4 MAS has said that services involving other tokens, such as those used only for utility or governance, are not subject to it, so whether a given service is caught turns on the category of token involved and the service provided.3
The FT described the measure as one that obliged unlicensed exchanges to close or move abroad within weeks.1 Its relevance here lies in the connecting factor Singapore chose. The 2025 regime attaches to the provider’s presence in Singapore and leaves the customers’ location aside. That choice sits uneasily beside a reported view that a protocol’s decentralised character takes it outside MAS’s jurisdiction. It also raises a narrower question the reporting does not answer: whether anything Hyperliquid Labs does from Singapore amounts to providing a digital token service, and whether the perpetual futures traded on the protocol involve tokens of the kind the regime covers.
The Ooki DAO comparison
The United States has tested a related argument in court. In CFTC v Ooki DAO, the Commodity Futures Trading Commission sued a decentralised autonomous organisation directly, alleging that it had operated a trading platform without the registration the Commodity Exchange Act requires. Judge Orrick in the Northern District of California held that the DAO was an unincorporated association and therefore a person that could be sued under the Act, and on 8 June 2023 he entered default judgment and ordered the removal of its website.5,6 The decision carries limited weight. Ooki DAO never appeared, so the merits went uncontested, and the court left open which token holders count as members of the association.6,7
Ooki DAO concerned legal capacity and liability under a federal statute. It says nothing about where a protocol is located, or about the territorial reach of a regulator over a company that builds one. What it offers the Singapore question is narrower: a US court declined to treat decentralised governance as a reason why nobody could be held to account for a trading platform.
Washington’s route
American policy has meanwhile moved towards bringing perpetual products onshore through regulated venues. Coinbase Derivatives self-certified nano bitcoin and nano ether perpetual-style futures with the CFTC on 26 June 2025.8 At a White House event on 19 August 2026, President Trump said that the CFTC’s chair was working to bring Hyperliquid into the United States in a fully compliant and legal fashion. He gave no detail of what an onshore Hyperliquid would look like or what approvals it would need, and his remarks did not mean the CFTC had approved the exchange.9
What remains open
MAS distinguishes Hyperliquid from SGX, the local exchange, which launched perpetual futures in Singapore last year. It says the two differ fundamentally in their regulatory position and that SGX’s products were designed for institutional investors.1 The line MAS draws is one of regulatory status. The reasoning for placing Hyperliquid outside it, as reported by people familiar with the regulator’s thinking, rests on decentralisation.
The reporting leaves open whether MAS’s view extends to Hyperliquid Labs or reaches only the protocol. It does not say whether any activity the company carries on from Singapore falls within a regime written to reach Singapore-based providers with no Singapore customers. Nor does it say, if decentralisation is indeed what places the protocol beyond MAS’s reach, what degree of decentralisation is required and who decides when a protocol has attained it. Ooki DAO cannot answer those questions for Singapore. It does show that a court, asked to find someone answerable for a decentralised trading platform, was willing to find one.
References
1. Owen Walker, “Singapore distances itself from ‘dangerous product’”, Financial Times (FT Weekend, Companies & Markets), 10/11 October 2026.
2. Financial Conduct Authority, Warning List entry “Hyperliquid”, first published 21 May 2026, last updated 7 June 2026, https://www.fca.org.uk/news/warnings/hyperliquid.
3. Monetary Authority of Singapore, “MAS Clarifies Regulatory Regime for Digital Token Service Providers”, media release, 6 June 2025, https://www.mas.gov.sg/news/media-releases/2025/mas-clarifies-regulatory-regime-for-digital-token-service-providers.
4. Eng Han Goh (Resource Law LLC), “MAS finalises and clarifies regulatory regime for digital token service providers”, Reed Smith, https://www.reedsmith.com/articles/mas-finalises-clarifies-regulatory-regime-digital-token-service-providers/.
5. CFTC v Ooki DAO, US District Court for the Northern District of California, Order Granting Motion for Default Judgment (8 June 2023), https://cftc.gov/media/8736/enfookidaoorder060923/download.
6. Baker McKenzie, “Court holds DAO may be sued as person and orders the shutdown of Ooki DAO website” (13 June 2023), https://blockchain.bakermckenzie.com/2023/06/13/court-holds-dao-may-be-sued-as-person-and-orders-the-shutdown-of-ooki-dao-website/.
7. Herbert Smith Freehills Kramer, “Ooki DAO default judgment: regulators still face many technical and legal challenges in regulating smart contracts” (June 2023), https://www.hsfkramer.com/insights/2023-06/ooki-dao-default-judgment-regulators-still-face-many-technical-and-legal-challenges-in-regulating-smart-contracts.
8. Commodity Futures Trading Commission, Designated Contract Market Products, Coinbase Derivatives (COIN) futures listing, entries for nano Bitcoin and nano Ether Perp Style Futures, status Certified, 06/26/2025, https://www.cftc.gov/IndustryOversight/IndustryFilings/TradingOrganizationProducts?Organization=COIN&Type=Future.
9. Helene Braun, “HYPE jumps 11% as Trump says CFTC is working to bring Hyperliquid to U.S.”, CoinDesk, 19 August 2026, https://www.coindesk.com/markets/2026/08/19/hype-jumps-11-as-trump-says-cftc-is-working-to-bring-hyperliquid-to-u-s.