Structure Power: The Advantage Nobody Talks About
How small jurisdictions exercise geopolitical agency through the standards others adopt.
Saint Clair Market Intelligence | May 2026
In January 2026, at the World Economic Forum in Davos, Singapore’s Minister for Digital Development and Information announced what was billed as the world’s first governance framework for agentic AI. The document was technical, restrained, and carried Singapore’s institutional cadence. Within weeks, the framework had been parsed by every major international law firm with a digital-economy practice. Commentary surfaced across Brussels, London, Tokyo, and Singapore itself. None of the commentary disputed Singapore’s positioning. The question being asked was how to align.
The framework matters most for what it demonstrates. A small jurisdiction has acquired a category of geopolitical agency that sits outside the standard taxonomy of national power.
A third form of power
Hard power moves armies. Soft power persuades cultures. Susan Strange named a third in States and Markets (1988): structural power, the capacity to shape the architectures within which others operate. The contemporary form we examine here is sharper, and for small jurisdictions, more available than the literature suggested.
We will call it structure power: the ability to articulate the technical standards that others end up adopting, and through that articulation to set the operating conditions of an entire sector before any treaty is signed.
The mechanism has three components. Early articulation: the standard is written before the rest of the field has formed an opinion. Technical credibility: the institution doing the writing is taken seriously by practitioners. Interoperability: the standard is designed so that adopting it costs less than diverging from it. Where the three combine, the framework travels.
The combination is, paradoxically, most available to small jurisdictions. The constraints that prevent a small country from projecting force or culture are the same constraints that push it toward building the technical infrastructure others find convenient to adopt. Structure power, in this sense, is an inheritance of smallness disciplined by institutional depth.
Digital finance
The Monetary Authority of Singapore convened Project Guardian in 2022 as a sandbox for asset tokenisation. By 2026 the initiative had drawn in more than forty institutions across seven jurisdictions, including Japan’s Financial Services Agency, the UK Investment Association, Citi, HSBC, and Standard Chartered. More than fifteen industry trials had been run across six currencies. The trials were the visible activity; the structural move was elsewhere.
In November 2024, MAS published the Guardian Fixed Income Framework. The International Capital Market Association, the global standard-setter for fixed-income markets with members in more than seventy countries, agreed to lead the workstream. Twelve months later, ICMA published its own technical deliverables: a delivery-versus-payment settlement guide and a custody-arrangements review for DLT-based debt securities, formally branded as an addendum to the Singapore framework. At the same Singapore FinTech Festival, the Deutsche Bundesbank signed a memorandum of understanding with MAS naming Project Guardian as the collaborative platform for cross-border tokenisation. Singapore wrote the foundation; the international standards body built on it.
AI governance
Singapore’s Model AI Governance Framework, first released in 2019 and updated in 2020, established the architecture later inherited by the ASEAN Guide on AI Governance and Ethics in 2024. The same seven principles (transparency, fairness, safety, robustness, human-centricity, privacy, accountability) anchor both. The Guide was released at the fourth ASEAN Digital Ministers’ Meeting; Singapore was its convening host.
By 2026 the technical layer had deepened. The AI Verify Foundation, run as a not-for-profit with AWS, Dell, Google, IBM, Microsoft, Red Hat, and Salesforce among its premier members, mapped its testing methodology against ISO/IEC 42001, the US NIST AI Risk Management Framework, and the Hiroshima Process. In May 2026 Singapore tabled ISO/IEC 42119-8, a proposed international standard for the testing of generative-AI systems, with thirty-five national bodies and more than two hundred and fifty AI experts represented at the plenary. The agentic-AI framework launched at Davos was the next iteration: the discipline that defines the category before the rules harden.
Climate disclosure
The Singapore Exchange began incorporating IFRS Sustainability Disclosure Standards into mandatory climate reporting from financial year 2025, with phased extension running through 2030. Scope 1 and Scope 2 emissions reporting became mandatory across all listed companies; Scope 3 became mandatory for STI constituents from 2026; ISSB-based broader disclosure for the rest of the market followed in tiers tied to capitalisation. The architecture is detailed, the timeline is published, and the sequencing logic is explicit.
Bursa Malaysia adopted the same ISSB-aligned framework on a parallel timeline, applying it to Main Market issuers above two billion ringgit from 2025. The Indonesian Institute of Chartered Accountants published draft sustainability standards in late 2024, structured to align with IFRS S1 and S2 from January 2027. Coordination runs through the ASEAN Capital Markets Forum. The regional sequence is observable: SGX first, Bursa Malaysia within twelve months, Indonesia within twenty-four. None of these jurisdictions was compelled. Each chose adoption over divergence.
The pattern and its limits
Three frameworks, three sectors, three documented adoption sequences. The mechanism is consistent. An institutional layer with technical depth (MAS, IMDA, SGX RegCo) articulates a position; an international body or a regional peer evaluates the work and finds it credible; adoption flows because the cost of building an alternative outweighs the cost of joining.
The pattern is real, and it is bounded. Singapore wrote one of the region’s earliest comprehensive data-protection regimes in 2012 and amended it materially in 2020. The amendment was not followed regionally. Indonesia, Vietnam, Thailand, and the Philippines each built data-protection frameworks on different conceptual foundations, with materially divergent consent regimes. ASEAN responded with voluntary Model Contractual Clauses for cross-border transfers. The Singapore framework remained Singapore’s. The mechanism that delivers in finance, AI, and climate did not deliver in data protection. Structure power is selective; the same institutional weight does not transfer across every domain.
The Irreplaceability Diagnostic
The structural lesson sits one step away from the case. Every firm, every fund, every advisory practice, every jurisdiction operates on some mixture of two kinds of advantage. The first is replicable efficiency: the ability to run a process or produce an output at a cost or quality that meets the market standard. Replicable efficiency is table stakes. Over time, it commoditises. Competitors arrive; margins compress; the position is held by running harder; standing still loses it.
The second is structural irreplaceability: the position from which others reference you. A standards body cites your framework. A regulator builds on your methodology. A counterparty needs your jurisdiction in the deal architecture, or the architecture does not function. Structural irreplaceability is harder to build and harder to lose. It is the position the three Singapore sectors above have constructed.
We call this distinction the Irreplaceability Diagnostic. It applies anywhere a principal is willing to ask the question honestly: where am I structurally irreplaceable, and where am I merely efficient?
Where the floor sits
The honest answer is rarely flattering on first inspection. Most positions assumed to be irreplaceable turn out, under examination, to be efficient. Most positions assumed to be efficient turn out to be replicable. The diagnostic is uncomfortable because the floor of a position rarely matches the picture the principal carries of it.
Singapore’s example is instructive because the country has spent two decades engineering irreplaceability in three domains, while leaving the same machinery quiet in others. The discipline is portable. Whether a principal — firm, fund, or jurisdiction — runs it on themselves is a separate question.
Sources:
MAS Project Guardian — https://www.mas.gov.sg/schemes-and-initiatives/project-guardian
Guardian Fixed Income Framework v1.1 (November 2025) — https://www.mas.gov.sg/-/media/mas-media-library/development/fintech/guardian/guardian-fixed-income-framework-v1_1.pdf
ICMA — Project Guardian Fixed Income workstream addendum (November 2025) — https://www.icmagroup.org/News/news-in-brief/project-guardian-fixed-income-workstream-deliverables-led-by-icma-published-as-an-addendum-to-the-guardian-fixed-income-framework/
MAS–Deutsche Bundesbank MoU on tokenisation and cross-border settlement (Singapore FinTech Festival, November 2025) — https://www.mas.gov.sg/news/media-releases/2025/mas-and-deutsche-bundesbank-sign-mou-on-tokenisation-and-cross-border-settlement
Singapore Launches New Model AI Governance Framework for Agentic AI (22 January 2026, World Economic Forum) — https://www.mddi.gov.sg/newsroom/singapore-launches-new-model-ai-governance-framework-for-agentic-ai--/
ASEAN Guide on AI Governance and Ethics (February 2024) — https://asean.org/wp-content/uploads/2024/02/ASEAN-Guide-on-AI-Governance-and-Ethics_beautified_201223_v2.pdf
IMDA — Singapore Champions New Global AI Testing Standardisation Efforts (ISO/IEC 42119-8) — https://www.imda.gov.sg/resources/press-releases-factsheets-and-speeches/press-releases/2026/singapore-champions-new-global-ai-testing-standardisation-efforts
SGX RegCo — climate reporting incorporating IFRS Sustainability Disclosure Standards from FY 2025 — https://www.sgxgroup.com/media-centre/20240923-sgx-regco-start-incorporating-ifrs-sustainability-disclosure
IFRS Foundation — Singapore Jurisdictional Profile (2025) — https://www.ifrs.org/content/dam/ifrs/publications/sustainability-jurisdictions/pdf-snapshots/singapore-ifrs-snapshot.pdf
Susan Strange, States and Markets (Pinter, 1988) — foundational text on structural power in international political economy.
PDPC Singapore — Comparing Consent Rules in General Data Protection Laws across Asia-Pacific — https://www.pdpc.gov.sg/comparing-consent-rules-in-general-data-protection-laws-across-asia-pacific
Disclaimer: This article is for informational purposes only and does not constitute investment advice. All decisions should be made based on independent research and consultation with qualified advisors.
About Saint Clair – Advisory & Capital: Saint Clair practises Capital Diplomacy — fostering cross-border investment relationships between Europe and Asia through trust, insight, and strategic facilitation. Since 2016, we have specialised in the Europe-Asia investment corridor.
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