Token Offering


Token Offering




  1. Confirmation of the Quotation
  2. Preparation of Documents according to the Checklist
  3. Compilation of all required documents
  4. Submission to Authority
  5. Answering of Queries (if any)
  6. Approval of License


 1) Detailed business plan, which covers:

  • Business Objective
  • Type of Services / Products
  • Target Market & Territorial Scope (to specify whether it is individual and/or corporate client and the percentage) (to specify the country and percentage - i.e Singapore 50% Indonesia 50%)
  • Target Industry/Sector (to specify the industry/sector and the percentage)
  • Business Operational and Strategic Plan ((included but not limited to the following) – best to be presented in the schematic diagram)
  • Risk Management and Internal Control Process / Policy
  • Manpower planning
  • Marketing Strategy
  • Functional Structure of Management Office in Labuan 
  • Functional Structure of Marketing Office* if applicable 
  • Particular of Internal Control and Compliance Officer 
  • Proposed Financial Year End and Accounting Standard 
  • Company Organisation Chart 
  • Any other relevant supporting documents/information

2) Three years forecast financial statement (Please ensure the three years projection is realistic and reasonable and please provide the basis of assumption in deriving to the projected figure.)

3) Group Shareholding Structure

4) Framework on Know-Your-Customers’ policy and compliance to the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001

5) Risk Management and Internal Control Policy, if any. The policy must be available for inspection once the license is granted.

6) Investment Management Policy, if any. The policy must be available for inspection once the license is granted.

7) Draft services level agreement with a service provider for the function to be undertaken by third parties. (i.e: internal audit, etc)


For Individual Director & Shareholder

a) CTC Malaysia Identity Card / Passport (non-Malaysian)

b) CTC Address Proof (i.e most recent utility bill, which not more than 3 months old document)

c) Two (2) Professional Reference Letters issued to Labuan FSA (applicable for each Director), Sample Attached

d) Updated Resume (including roles & responsibilities in the proposed Labuan CT Company)

e) CTC Academic/Professional Certificates


For Corporate Shareholder

a) Group corporate shareholding structure including the applicant

b) CTC of Certificate of Incorporation

c) CTC of Certificate of License granted by the relevant authority(s) in its home country - (if applicable)

d) Letter of awareness or approvals of authorities from the home country, if applicable, which includes:

a. Statement of no objection towards the establishment of a subsidiary or branch in Labuan.

b. Confirmation that the applicant’s shareholder or head office is of good financial standing.

c. Agreement to co-operate in the supervision of the proposed subsidiary or branch in Labuan in terms of applicable regulatory standards.

e) CTC of board resolution which approved the establishment/setting up of the applicant

f) CTC of M&A, latest Register of Directors, latest Register of Members, latest Annual Return (if applicable)

g) CTC of two (2) years audited financial statements/annual reports


Operational Requirement

Effective from 1st January 2019, all Credit Token License Entity have to fulfill the following Economic Substance Requirement: 

  1. To employ minimum two (2) staff to be based in Labuan 
  2. To have a minimum annual administrative expenditure of RM100,000.