Business models involving:

• Digital wallets

• Payment gateways

• Merchant acquiring

• Cross-border payment infrastructure

May be structured in Labuan depending on transaction flows, safeguarding arrangements and whether the activity is considered regulated.

Certain fintech models fall closer to capital markets or investment business for fund raising purposes, including:

• Digital investment platforms

• Online private placement platforms

• Tokenised investment structures

• Digital fund distribution models

• Structured finance platforms

Projects involving security tokens or investment-like features typically require careful classification and alignment with investment business or securities-related frameworks.

For more information, refer to the Fund Raising & Investment Structuring

Tokenisation of real-world assets (e.g. private credit, funds, real estate, commodities) is increasingly explored in Labuan.

There is no standalone RWA licence. Such projects are assessed based on:

• The nature of the underlying asset
• What the token represents economically
• Whether the activity resembles investment business, platform services or fund structures

RWA projects are therefore usually structured using combinations of:

• Labuan companies or trusts
• Fund or investment business frameworks
• Platform or intermediation models

All such structures are subject to feasibility analysis and regulatory mapping.

Labuan FSA recognises Company Management Business as a regulated licence category for entities providing operational, administrative and processing support services to financial and corporate businesses.

This licence is commonly relevant for fintech and digital businesses that provide:

• Back-office processing services (e.g. transaction processing, reconciliation, record maintenance)
• Treasury and operational support functions
• Administrative support for financial platforms or service providers
• Shared services or processing hubs for regional fintech or financial services groups

It is often used where fintech businesses wish to:

• Separate front-end commercial activity from regulated operational functions
• Establish a regulated processing or support entity
• Strengthen governance, transparency and credibility with partners and stakeholders

Activities conducted under this licence must remain within the scope approved by Labuan FSA and supported by appropriate governance and internal controls.

For more information, refer to the Company Management License

Labuan FSA places strong emphasis on:

• Governance frameworks
• Technology risk management
• Cybersecurity controls
• Operational resilience
• AML/CFT effectiveness

Common regulatory-ready documentation includes:

• Enterprise risk assessment (ERA)
• AML/CFT policies and procedures
• Client onboarding and monitoring frameworks
• Technology and cybersecurity governance policies
• Outsourcing and vendor governance
• Business continuity and incident response plans

These frameworks are often critical for licensing, banking relationships and investor due diligence.

For more information, refer to the Governance, Compliance & Regulatory Support

A Labuan digital banking licence allows banking activities to be conducted primarily through digital channels and carries significantly higher regulatory expectations.

Applicants are typically assessed on:

• Business model viability
• Governance and management capability
• Technology architecture and cybersecurity resilience
• AML/CFT systems
• Capital adequacy and financial strength
• Consumer protection and data governance

This pathway is generally suitable for established financial institutions, well-funded fintechs and institutional consortia.

For more information, refer to the Digital Banking