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Licence guide

Labuan money broking licence.

Agency forex and money market brokers serving institutional and high net worth clients across Asia choose Labuan for a 3% tax rate on audited profits and a client charter measured in weeks.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
Labuan FSARegulator
RM1,000,000Paid-up capital
2 to 3 monthsOur realistic timeline
US$5,000Annual fee
30 working daysClient charter

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

2 to 3 monthsLicence granted

Our realistic timeline from submission, set against the regulator’s own published figures.

Day oneReady to trade

Client money and liquidity provider accounts arranged alongside the application, so you trade on authorisation.

Your teamKey people in place

Candidates introduced for a principal officer and two staff in Labuan, each assessed against the regulator’s standard.

Same dayWritten proposal

A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.

How the firm obtains the licence

  1. Scoping and proposal. The scope, conventional or with digital asset broking, the agency model outside principal dealing and market making, the capital with the shareholder reserve and the Labuan office and staffing plan are confirmed in writing.
  2. Application pack. Form LFB-MB with the business plan, group structure, track record evidence, the home supervisor’s letter of awareness and the governance, compliance and AML policies before filing with the Head of Authorisation and Licensing.
  3. Banking and liquidity. Client money accounts marked per client, the operating and settlement accounts and regulated principal broker, custodian and liquidity provider relationships are arranged through the firm’s relationships before licensing, each notified to Labuan FSA.
  4. Regulator engagement. Labuan FSA’s information requests are answered through one process until approval, then the certified capital injection, the Labuan office and staff and the annual fee are completed; the client charter is 30 working days.

Key people, banking and technology

You will need two directors, a principal officer to run the firm, a Labuan contact person and two full-time staff in Labuan for the 3% tax rate.

Key peopleThe firm introduces candidates for a principal officer and two staff in Labuan from its register of senior compliance, financial crime, risk and finance professionals, and assesses each against the regulator’s approval standard before they are put forward.
BankingClient money, operating and settlement accounts and liquidity provider onboarding, arranged through the firm’s relationships in parallel with the application.
TechnologyWhite-label client onboarding, wallet and payment technology, built and ready to go live with the licence.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

The licence in detail

The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.

Key takeaways
  • Money broking is arranging transactions between buyers and sellers in the money or foreign exchange markets as an intermediary for brokerage or commission; dealing as principal, liquidity provider or market maker is outside the licence.
  • Minimum paid-up capital under the September 2024 guidelines is RM1,000,000, or RM1,500,000 where digital asset broking is added, unimpaired by losses at all times, with evidence of deposit at a bank in Labuan or Malaysia.
  • The processing fee is US$350 under the guidelines (US$500 on the current fee schedule, US$1,500 fast track); the annual fee from 1 January 2026 is US$5,000 for conventional broking and US$10,000 with digital assets.
  • Labuan FSA’s client charter is 30 working days for a money broker licence, about 1.5 months, or 15 working days fast track.
  • An operational office in Labuan, at least two board members, a Labuan contact person, and at least two full-time employees and RM100,000 of annual operating expenditure in Labuan for the 3% tax rate.
  • Leverage is capped at 100:1 for money and foreign exchange and 1:1 for digital assets; clients are intended to be institutional and high net worth with retail less than half the book; brokers transact in foreign currency only and may not deal with Malaysian residents other than authorised dealers.

Who needs the licence

A business arranging transactions between buyers and sellers in the money or foreign exchange markets as an intermediary, for brokerage or commission, from Labuan needs a money broking licence under Part VI of the Labuan Financial Services and Securities Act 2010. Forex brokers operating an agency model are the main applicants. The licence excludes buying or selling currency as principal, liquidity provider or market maker, and products outside the money and foreign exchange markets, including CFDs whose underlying is not money or foreign exchange. Brokers transact in foreign currency only, use Ringgit solely for administrative and statutory expenses, and may not deal with Malaysian residents other than authorised dealers under the Exchange Control Act 1953. Audited net profits are taxed at 3% where the substance requirements are met.

Licence types

TypeScopePaid-up capitalAnnual fee from 2026
Money broker (conventional)Money and foreign exchange market activities (paragraph 6.1 of the guidelines)RM1,000,000US$5,000
Money broker with digital asset activitiesAdds bringing counterparties together to trade digital assets without securities features and operating an order-matching facility (paragraph 6.2)RM1,500,000US$10,000
Islamic money brokerThe same activities under the Labuan Islamic Financial Services and Securities Act, with a Shariah adviserAs aboveAs above

What Labuan FSA requires

  • Eligibility. Money broking expertise and a good track record, typically at least three years, assessed case by case; a credible business plan and group structure; and, for a broker regulated abroad, a letter of awareness or consent from the home supervisor.
  • Office and staff in Labuan. An operational office in Labuan used only for the business and properly furnished, with staff covering finance and accounting, statistical submissions and record keeping, a Labuan contact person, and accounts and records kept in Labuan. For the 3% tax rate: at least two full-time employees in Labuan and at least RM100,000 of annual operating expenditure in Labuan.
  • Board and fit and proper. At least two board members; persons in control, directors and the principal officer fit and proper at all times; Labuan FSA’s prior approval for shareholding changes of 10% or more, appointments of directors and the principal officer, capital reductions, additional offices and outsourcing.
  • Capital. Paid-up capital of RM1,000,000 (RM1,500,000 with digital asset broking) or the foreign currency equivalent, unimpaired by losses at all times, evidenced by a certified bank deposit; Labuan FSA may require more by risk and scale, and expects shareholders to hold a further 20% in reserve.
  • Client money and counterparties. Client money in separate accounts marked per client, never mixed with the broker’s assets and readily identifiable, with withdrawals paid within three working days of request, monthly reconciliation and no availability for the broker’s debts. Principal brokers, custodians, payment providers and liquidity providers must be regulated with a good track record, with due diligence and notification to Labuan FSA at least seven days before a new arrangement.
  • Conduct and leverage. Leverage of at most 100:1 (1% minimum margin) for money and foreign exchange and 1:1 for digital assets, with stop-loss safeguards; a written client agreement; disclosure of order routing, introducing brokers, spreads and fees; monthly performance updates; complaints handling; clients intended to be institutional and high net worth, with retail less than half the book.
  • Governance and controls. Internal policies for operations, compliance, governance and risk; a compliance function under the September 2025 compliance guidelines; anti-money laundering under the Anti-Money Laundering Act 2001 and Labuan FSA’s guidelines; board oversight of capital, liquidity, risk, financial crime, business continuity and systems; technology risk management with dedicated IT staff for electronic models; a Shariah adviser for Islamic broking; annual audit by a Labuan-approved auditor with accounts filed within six months of year end.
  • Application pack. Form LFB-MB with supporting documents and the processing fee to the Head of Authorisation and Licensing, Labuan FSA; on approval, capital is injected with certified bank evidence, the Labuan office and staff are in place and the annual fee is paid.

Capital

RequirementAmount
Money broking (money and foreign exchange)RM1,000,000
With digital asset brokingRM1,500,000
Shareholder reserveA further 20% expected in reserve
Tax substance2 full-time employees and RM100,000 annual operating expenditure in Labuan

Capital must be unimpaired by losses at all times, with certified evidence of deposit at a bank in Labuan or Malaysia; Labuan FSA may require more by risk and scale. Brokers licensed under the 2017 guidelines had one year to raise capital by at least half and two years to comply in full.

Timing

FigureValueSource
Statutory decision periodNo statutory decision period published; Labuan FSA applies its client charterLabuan Financial Services and Securities Act 2010, Part VI
Regulator’s published figure30 working days, about 1.5 months, for a money broker licence; 15 working days, about 0.75 month, fast trackLabuan FSA client charter
Application preparation4 to 6 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline2 to 3 months after submission, allowing for information requests and the capital injection and office set-up on approvalThe firm’s own figure, from the regulator’s published data and its own applications

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

ItemAmountNotes
Processing feeUS$350With Form LFB-MB under the 2024 guidelines; the Labuan FSA fee schedule lists licence application US$500 and fast-track processing US$1,500
Annual licence fee, conventionalUS$5,000From 1 January 2026, payable on or before 15 January; existing licensees pay US$1,500 in 2026 and US$3,250 in 2027
Annual licence fee, digital assetUS$10,000From 1 January 2026; existing licensees pay US$1,500 in 2026 and US$5,750 in 2027
Marketing office outside LabuanUS$500Establishment; US$3,500 a year
Paid-up capitalRM1,000,000RM1,500,000 with digital asset broking
Tax3% of audited net profitsWith two full-time Labuan employees and RM100,000 of annual Labuan expenditure
Professional feesFixed, in writingQuoted after scoping

Geographic scope

The licence covers business from Labuan; there is no passport. Operating in Malaysia or in Ringgit needs prior approval from the Malaysian authorities. A marketing office outside Labuan is permitted under the marketing office guidelines. Where a client’s jurisdiction has no licensing regime for the activity, Labuan FSA may accept a local legal opinion; where it has one, the broker obtains the local approval. The firm obtains the EU, UK or Australian authorisation alongside the Labuan licence for groups serving those markets.

Why applications are delayed

Labuan FSA publishes its eligibility tests. It looks for money broking expertise and a track record, a letter of awareness or consent from the home supervisor of a broker regulated abroad, adequate financial resources, a credible business plan and a sound management structure. The 30-working-day charter runs from a complete submission; further information requests extend it. Non-compliance with the guidelines after licensing attracts administrative penalties or enforcement under the Labuan Financial Services Authority Act. Brokers that need more time to meet transition deadlines request an extension with mitigating measures, assessed case by case.

Banking and liquidity

A broker needs segregated client money accounts marked per client, an operating account and settlement accounts in the currencies it serves, and regulated principal broker, custodian, payment provider and liquidity provider relationships notified to Labuan FSA before they start. Banks and liquidity providers review the licence scope, the client money arrangements, the leverage policy and the financial crime framework before onboarding. The firm arranges each through institutions that serve Labuan licensees, in parallel with the application, so the firm trades on licensing. See banking and payment processing.

Questions firms ask

How long does a Labuan money broking licence take?

Labuan FSA’s client charter is 30 working days, about 1.5 months, or 15 working days fast track. The firm plans for two to three months after submission, allowing for information requests and the capital injection and office set-up on approval.

What capital is required?

RM1,000,000 paid up, or RM1,500,000 with digital asset broking, under the September 2024 guidelines; the earlier RM500,000 figure no longer applies. Labuan FSA expects shareholders to hold a further 20% in reserve.

Can a Labuan broker act as market maker?

No. Money broking is intermediation for brokerage or commission; dealing as principal, liquidity provider or market maker is outside the licence, and CFDs whose underlying is not money or foreign exchange are not permitted.

What leverage may we offer?

At most 100:1, a minimum margin of 1%, for money and foreign exchange; 1:1 for digital assets; with stop-loss safeguards.

Can we serve Malaysian clients?

Only authorised dealers under the Exchange Control Act 1953. Brokers transact in foreign currency only; operating in Malaysia or in Ringgit needs prior approval from the Malaysian authorities.

References

  1. Labuan FSA: guidelines on the establishment of money broking business in Labuan IBFC, September 2024
  2. Labuan FSA: frequently asked questions on the money broking guidelines
  3. Labuan FSA: fee schedule
  4. Labuan FSA: client charter
  5. Labuan FSA: money broking
  6. Labuan Business Activity Tax (Requirements for Labuan Business Activity) Regulations 2018

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.

A written proposal on cost, timing and requirements, the same day: speak to an expert.

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.

How we work.

  • Senior-ledEvery engagement is led by the practitioners who prepare the application and attend the regulator.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing, before you commit.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceEvery engagement runs in a shared workspace on Hector: documents, regulator questions, messages and progress in one place, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have taken firms through licensing, run regulated payments and consumer credit businesses, and signed the regulatory returns ourselves.
  • BankingSafeguarding, operating and settlement accounts arranged alongside the authorisation, through the institutions that serve this market.
  • FoundersThe firm is run by founders who have built and run regulated payments businesses, so every position is given with the launch date and the cost of waiting in mind.
  • One firmLicensing, key people, banking, compliance, technology and transactions from the same team, for the life of the regulated firm.

Apply for this licence.

The requirements, the cost and the timing for your business, in a written proposal the same day.