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A Step-by-Step Guide to Your Labuan Digital Bank License

Navigating the application process with clarity. This guide visualizes the key stages, timelines, and requirements for establishing a digital bank in Labuan IBFC.

Reduced Capital Requirement

RM50M

Temporarily reduced minimum unimpaired capital until Dec 31, 2026.

Security Deposit

RM2.5M

A reduced non-interest bearing deposit, refundable after three years.

Fast Track Application

15 Days

Expedited processing time upon acceptance of complete documentation.

Application Journey: Estimated Timeline

The application process is a multi-stage journey involving preparation, submission, and regulatory review. This chart illustrates the estimated duration for each key phase, helping you plan your resources effectively. The total timeline can vary based on the complexity of the application and the speed of responses.

The Four Phases of Application

Phase 1: Preparation & Strategy

This initial phase is crucial for laying a solid foundation for your application. It involves strategic planning, engaging local expertise, and gathering all necessary corporate and personal documentation.

1

Define Strategy & Eligibility

Confirm that your business model aligns with the Labuan Digital Banking Framework.

2

Engage Labuan Trust Company

Appoint a licensed Labuan Trust Company to assist with incorporation and application submission.

3

Appoint Key Personnel & KYC

Appoint directors and a Principal Officer. Collect all necessary Know-Your-Customer (KYC) documents.

Phase 2: Documentation & Frameworks

With the structure in place, the focus shifts to creating the detailed documentation that forms the core of your submission to the Labuan Financial Services Authority (LFSA).

4

Develop Business Plan

Create a comprehensive 3-year business plan, including financial projections.

5

Draft Governance Frameworks

Prepare essential policies covering IT Governance, Cybersecurity, e-KYC processes, and AML/CFT.

6

Prepare Exit Plan

Develop a credible exit strategy to ensure an orderly wind-down if necessary.

Phase 3: Submission & Review

This phase marks the formal engagement with the regulator. Your compiled application package is submitted, and the LFSA begins its thorough review process.

7

Compile & Submit Application

Your Labuan Trust Company compiles Form LBB and all supporting documents for submission.

8

Pay Fees & Submit

Pay the non-refundable processing fee (and fast-track fee if applicable) via the LEPAY system.

9

LFSA Review & Queries

The LFSA assesses the application and may raise queries for clarification.

Phase 4: Approval & Operationalization

The final phase involves meeting the conditions set by the LFSA to move from in-principle approval to a full license, allowing your digital bank to commence operations.

10

Conditional Approval

Receive an in-principle approval from LFSA outlining conditions to be met.

11

Fulfill Conditions

Inject paid-up capital, place the security deposit, and set up the physical office in Labuan.

12

Final License Issuance

Submit proof of compliance to LFSA to receive the full, unconditional digital banking license.

Core Application Components

A successful application hinges on a set of comprehensive documents. The chart below breaks down the key components required, categorizing them for clarity. Each element is vital for demonstrating your venture's viability, governance, and compliance readiness to the LFSA.