The Question We Answer Before We Accept a Cross-Border Matter

8 September 2026 · Spyrrus Tech Pte Ltd

A client calls about a counterparty in Ho Chi Minh City. The commercial question is simple enough and the budget is real. Before we discuss either, we answer a different question: what is lawful to do there, by whom, and what does the answer rest on?

That is not caution for its own sake. A cross-border matter has two ways of failing that a domestic one does not. The work can be done competently and still produce material that cannot be used, because of how or where it was obtained. And an instruction can expose the client to a regime nobody in the chain had read. Both failures arrive late, after the invoice and usually after reliance.

So we settle the jurisdiction question at intake rather than at delivery.

What we are checking against

We work from a primary-source registry of private investigation law across the Asia-Pacific, published at ai9os.com/jurisdictions. It covers ten jurisdictions: seven ASEAN member states, plus Hong Kong, Japan and South Korea.

Three things about it decide whether it is useful at intake rather than merely interesting to read.

Every entry cites its instrument and provision. Not a summary of the position, and not a secondary article about the position. The section number, so it can be checked against the statute by anyone who doubts it, including opposing counsel.

Every entry carries the date it was last verified, and that date is only moved when the provisions are actually re-read. A verification date refreshed on a schedule rather than on a reading is worse than a stale one, because it invites reliance it has not earned.

Every entry declares what could not be confirmed. Where a register is not served publicly, where an official English translation lags the amending act, where an index does not read scanned documents: it is written down as a limit rather than smoothed over. Three ASEAN member states are not covered at all, and the registry says why instead of leaving a gap that looks like an answer.

Why the answers differ more than people expect

The instinct is to assume the region regulates investigation in roughly the same way, with local variation. It does not.

Singapore regulates the purpose. The Private Security Industry Act says nothing about method. Obtaining information about a person for reward is inside the definition whether it came from a doorstep or a database.

Japan regulates the method. The Detective Business Act turns on interviews, tailing and stakeouts, and work carried out solely by telephone enquiry or internet collection falls outside it. That is close to the inverse of the Singapore test, and an approach that is unremarkable in one place can be the regulated act in the other.

Hong Kong does not license private investigation at all. The constraint there is not a licence but a data protection regime with criminal teeth.

Three neighbouring markets, three different questions to ask. This is exactly the point at which a confident generalisation costs somebody their evidence.

What this changes about how we take instructions

We tell you what we will not do before we tell you what we will. For a cross-border matter that means naming the activities we decline in that jurisdiction, and if the honest answer is that the work cannot be done lawfully to the standard you need, we say so at intake. That conversation is cheaper then than at any later point.

We say which entity you are dealing with, and why. Spyrrus Tech Pte Ltd (UEN 202022197D) holds a private investigation agency licence under the Private Security Industry Act. Licensed investigative work is contracted with this company. Where a matter needs a licensed provider in another jurisdiction, our job is to establish what licence that provider must hold before they are instructed, not after.

And we do the paperwork the Act requires. Section 10 obliges a licensed agency to obtain identification documents from its client and s 12 imposes a record-keeping duty. If a provider has never asked you for identification, that tells you something about the provider.