Chapter 7: Operations, Banking & Listing
After registration, a few practical bottlenecks remain — especially banking and listing.
7.1 Bank accounts: the most real challenge
Crypto-related businesses face banking difficulty worldwide; Malaysia is no exception.
- You need a local Malaysian bank for operating accounts, plus segregated trust/client accounts for client fiat.
- Banks do strict due diligence focused on your AML/CFT and SC registration status — so make compliance solid before seeking accounts.
- Engage multiple banks early, in parallel with the application — not as an afterthought.
7.2 Client fund & asset segregation
flowchart TD
Cust[Customer] -->|fiat deposit| Trust[Segregated trust/client account]
Cust -->|digital assets| ColdHot[Segregated client wallets
hot/cold] Trust -.strict segregation.- Own[Platform own-funds account] ColdHot -.strict segregation.- OwnW[Platform own wallets]
hot/cold] Trust -.strict segregation.- Own[Platform own-funds account] ColdHot -.strict segregation.- OwnW[Platform own wallets]
- Fiat: a separate trust/client account, never commingled with operating funds.
- Digital assets: separate client wallets, reconcilable and provable on the ledger.
- Regular third-party reconciliation/audit; disclose Proof of Reserves where appropriate.
7.3 Listing: every asset must pass assessment
Even with DAX status, every asset requires due-diligence assessment against SC criteria before listing:
| Dimension | Focus |
|---|---|
| Legality | Is it a security/restricted asset; any regulatory barrier |
| Project quality | Team, whitepaper, technology, genuine use |
| Security | Smart-contract audit, chain security, history |
| Liquidity & market | Depth, manipulation risk |
| AML | Extra scrutiny for privacy coins / high-risk assets |
- Produce and archive a written listing assessment report.
- Major listings/delistings may require notification or SC recognition.
- Currently tradable assets are concentrated in majors.
7.4 Ongoing operations & reporting
- Capital maintenance: continuously meet RM 5M shareholders’ funds.
- Periodic reporting: financial, compliance, operational, suspicious-activity, on cadence to SC / BNM.
- Material-change notices: ownership, key personnel, systems, custody.
- Audit: statutory + AML/technical special audits.
- Complaints & disputes: transparent, logged, traceable.
- Insurance: maintain commercial/cyber/crime cover.
7.5 Tax (LHDN / RMCD)
- Income tax: trading/service income under corporate tax (rates/treatment per your tax advisor).
- Service tax (SST): assess whether platform fees are taxable.
- Tax treatment of digital assets is still evolving — get a plan from a local tax advisor.
Summary / action items
- Pursue local bank accounts early and in parallel (operating + client trust).
- Implement client segregation for fiat and assets + regular reconciliation/audit.
- Build a listing-assessment process and report for the first assets.
- Stand up ongoing reporting and material-change notification.
- Arrange insurance and tax planning.
➡️ Next: Costs, Timeline & Checklist