Chapter 4: The SC Application Process, Step by Step
This chapter takes everything you prepared and submits it through the SC’s process.
4.1 Overall flow
flowchart TD
A[Step 0: SC pre-engagement] --> B[Step 1: Prepare the document pack]
B --> C[Step 2: Submit RMO-DAX registration]
C --> D[Step 3: SC initial review + Q&A]
D --> E[Step 4: Due diligence
personnel/systems/compliance] E --> F{Step 5: SC decision} F -->|Conditional approval| G[Step 6: Meet conditions] F -->|Reject / more info| D G --> H[Step 7: Obtain RMO registration] H --> I[Step 8: Final readiness + go live]
personnel/systems/compliance] E --> F{Step 5: SC decision} F -->|Conditional approval| G[Step 6: Meet conditions] F -->|Reject / more info| D G --> H[Step 7: Obtain RMO registration] H --> I[Step 8: Final readiness + go live]
4.2 Step by step
Step 0: Pre-engagement (strongly recommended)
Before filing, proactively engage the SC: present your model, shareholder background and tech approach. Benefits:
- Surface fatal issues early (ownership, source of funds, architecture).
- Clarify the SC’s expectations for your specific model.
- Build a channel that smooths later supplementary submissions.
Step 1: Prepare the document pack
Typical materials (per the SC’s latest checklist):
| Category | Documents |
|---|---|
| Company | SSM cert, constitution, ownership chart, UBO declaration |
| Financial | Audited statements, RM 5M proof, source-of-funds, working-capital forecast, 3–5y model |
| Personnel | Director/exec/CO résumés, fit-and-proper declarations, clean records |
| Business | Business plan, trading rules, fee model, target market |
| Compliance | AML/CFT policy, KYC flows, risk assessment, compliance manual |
| Technology | Architecture, cybersecurity plan, custody/wallet design, BCP/DR, pen-test plan |
| Operations | Client-asset segregation, complaint handling, insurance |
| Listing | Proposed asset list + assessment reports |
Step 2: Submit
File the RMO (DAX) registration through the SC’s designated channel and pay applicable fees.
Step 3: Initial review & Q&A
The SC issues one or more rounds of queries:
- Answer fast, precise, complete — address every question head-on.
- Keep document version control; avoid inconsistencies.
- This is usually the longest stage and the toughest test of compliance/tech depth.
Step 4: Due diligence
- Personnel: deep fit-and-proper checks.
- Systems: possible tech demo, third-party security audit / pen-test reports.
- Compliance: live walkthrough of AML/KYC flows.
- May include interviews / on-site checks.
Steps 5–6: Decision & conditions
- The SC may grant conditional approval listing pre-launch conditions (complete pen-test, secure insurance, top up capital, confirm bank account).
- Satisfy each and evidence it to the SC.
Step 7: Obtain RMO registration
You’re listed on the SC’s Recognized Market Operators (DAX) list. Congratulations — but it’s only the start.
Step 8: Final pre-launch readiness
- Complete go-live readiness testing.
- Confirm client-asset segregation, custody, insurance and monitoring are all in place.
- Have ongoing compliance reporting ready.
4.3 Timeline expectation
From preparation to registration typically takes months — often 6–18 months or more, depending on document quality, shareholder complexity, tech/compliance maturity and SC scheduling. There is no fast track.
Summary / action items
- Arrange SC pre-application engagement.
- Assemble the full document pack (tick each row above).
- Assign an owner for rapid responses to SC queries.
- Plan the third-party security audit / pen-test timeline.
- List likely conditional-approval prerequisites and prepare early.
➡️ Next: AML/CFT Compliance