Technology risk
Singapore: Updates to the Guidelines on Licensing for Payment Service Providers
12 August 2024
Zhen Guang is a dual-qualified (Singapore and England & Wales) lawyer based in the Singapore office, specialising in the areas of Technology, Media & Telecommunications (TMT), Data Privacy and Protection, Cybersecurity, Digital Trade (e-commerce, markets and platforms, payment systems and e-contracting), IoT and Computing, Technology Procurement (technology contracting and vendor legal risk management), Digital Asset Management and Protection/Fintech and Regtech, Intellectual Property, and AI.
Direct Lines
+65 6544 6554 +65 9139 6380 zhenguang.lam@clydeco.comMain Office
Singapore
+65 6544 6500 +65 6544 6501Regional experience
Full Profile
Zhen Guang regularly advises clients in multiple sectors on transactional projects such as technology outsourcing and procurement, as well as advisory matters focusing on data privacy and protection, cybersecurity, Fintech (regulatory), and technology risk management. He also has extensive experience handling complex and sensitive investigations involving cybersecurity attacks and data breach incidents.
Zhen Guang is also:
- a legal advisor under the Payment Regulatory Evaluation Program (PREP), an initiative by the Monetary Authority of Singapore to assist payment services providers;
- an Accredited Specialist (Data and Digital Economy) appointed by the Singapore Academy of Law as part of the pioneer batch of accredited specialists (Data and Digital Economy); and
- a Committee Member of the Cybersecurity & Data Protection Committee of the Law Society of Singapore for 2023 (member) and 2024 (Co Vice-Chairperson).
Zhen Guang holds the Certified Information Privacy Professional/Asia (CIPP/A) and the Certified Information Privacy Professional/Europe (CIPP/E) data protection/privacy accreditation from the International Association of Privacy Professionals (IAPP). He is also certified in Cyber Incident Planning & Response based on a UK National Cyber Security Centre (NCSC) assured training course by the Cyber Management Alliance.
In addition, Zhen Guang has been on secondment to Ant Group in Hangzhou, China, where he advised on various commercial projects including collaboration arrangements and Blockchain-as-a-Service agreements.
Zhen Guang is fluent in English and Mandarin.
Experience
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Fintech/Digital Assets
- Advised a digital wallet subsidiary of an American social media conglomerate on regulatory and licensing requirements in its efforts to set up its custodial wallet software and services in various Southeast Asian countries for a new stablecoin payment system.
- Prepared and negotiated a participation agreement for a major Chinese fintech company concerning the former’s provision of a trade finance blockchain-based platform service to various financial institutions.
- Advised an international internet finance authentication alliance on the legal issues and requirements concerning its proposed establishment in Singapore and other ASEAN countries.
- Advised a non-profit organisation that represents the interest of the commercial and investment banking community in Singapore in its industry response to the MAS-issued consultation paper on guidelines for e-payments user protection.
- Advised a major global cryptocurrency exchange on a dispute involving a crypto mining agreement with a cryptocurrency mining company.
- Advised a Chinese multinational electronics company on its proposed provision of access to top-up service and payment process services.
- Advised a major global cryptocurrency exchange on the launch of its cold wallet storage product.
- Advised a major global cryptocurrency exchange on a crypto market maker agreement.
- Advised a major global cryptocurrency exchange on a cloud mining agreement.
- Advised an early-stage venture capital firm on a Simple Agreement for Future Tokens (SAFT) in respect of an NFT Game-Fi project.
- Advised a major global cryptocurrency exchange on a stablecoin-as-a-service agreement and stablecoin support agreement.
- Advised a major global cryptocurrency exchange on a staking-as-a-service agreement.
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Data Protection Compliance
- Advised a major Chinese fintech company on Singapore data protection laws relating to online payment fraud and risk management practices.
- Advised a multinational telecommunications company on data protection issues arising from COVID-19 with respect to various Southeast Asian countries including Singapore.
- Advised a leading French company in the business of medical diagnostic solutions on Singapore data protection and cybersecurity regulations in respect of connected medical devices.
- Assisted a national research university in Singapore in managing the review of its data protection documentation for GDPR compliance.
- Assisted a financial institution in the UAE on the applicability of China’s Personal Information Protection Law and Data Security Law on its UAE head office and Mainland China and Hong Kong branches.
- Advised an international life insurance organisation on the Singapore data protection requirements applicable to an outsourcing arrangement concerning the relocation of its Hong Kong data centre to Singapore.
- Advised a Japanese multinational sportswear corporation on its data protection obligations in respect of its internet platforms, mobile applications, and loyalty programmes.
- Advised, drafted and reviewed data protection compliance documentation for various financial institutions, e-commerce companies, and education institutions.
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Advising Organisations with respect to Data Privacy Regulators’ investigations
- Advised a major Japanese hedge fund database provider on investigations by the Singapore Personal Data Protection Commission (PDPC) concerning a cyberattack from which a positive result was achieved.
- Advised a Malaysian satellite television provider on investigations by the PDPC concerning the Consent Obligation from which a positive result was achieved.
- Advised a Southeast Asian leading payment service provider for online games and digital products on investigations by the PDPC concerning a data breach from which a positive result was achieved.
- Advised a Singapore HR and management consultancy business in its representations to the PDPC concerning breaches of its data privacy obligations from which a reduction of the original financial penalty was successfully achieved.
- Advised a major Singapore real estate group on investigations by the PDPC concerning a cyberattack from which an intermediate enforcement outcome was obtained in lieu of a full investigation outcome.
- Advised a leading APAC beauty and luxury brand distribution organisation in respect of a cyberattack including advising on its notification requirements and dealings with the Singapore Police Force.
- Advised a major Singapore marine offshore operator on investigations by the PDPC concerning a cyberattack from which a positive result was achieved.
- Advised an international ‘Magic Circle’ law firm on its data privacy obligations concerning data subject access requests launched by an ex-employee against it.
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TMT & IP
- Reviewed a source code escrow agreement for a major Chinese fintech company to be entered into between the former, an international theme park operator and an information assurance firm.
- Assisted a Mongolian legal technology company in the drafting of the terms of use and privacy policy for its lawyer-to-lawyer document marketplace.
- Advised a leading Myanmar insurer on a master services agreement and a software licensing agreement with an Indian multinational IT company concerning the former’s core IT system.
- Advised a British multinational telecommunications conglomerate on the telecommunication regulatory framework in Singapore.
- Assisted a multilateral development bank’s engagement with an African country on the strengthening of the country’s national digital identification system including the readiness of its existing legal and regulatory enabling environment.
- Prepared an event sponsorship agreement and a title sponsorship and syndication agreement for a Singapore-based mixed martial arts organisation to be entered into between the former and a Philippines telecommunications services provider.
- Carried out IP due diligence for a Singapore dating & networking app operator in connection with its proposed listing on the NYSE.
- Advised a leading multinational digital asset company on its wallet security service agreement with a UK digital asset protection company.
- Advised a major global cryptocurrency exchange on a sponsorship arrangement with a Spanish football club in respect of the latter’s development of a fan token project.
- Advised a major global cryptocurrency exchange on an NFT artwork agreement with a digital artist and an international music artiste.
- Prepared a data licensing agreement for a hybrid oil analytics provider in Singapore.
- Advised a leading Chinese petrochemical company on a data sharing agreement with a Singapore digital infrastructure service provider.
- Prepared influencer / KOL agreements and event sponsorship agreements for a major global cryptocurrency exchange.
- Assisted a leading global cloud communication service provider on its expansion into the APAC market including obtaining the necessary licences for regulatory compliance.