Steady Counsel
for Regulated
Waters

BNM administers several licence categories under the Financial Services Act 2013 and the Islamic Financial Services Act 2013, including commercial banking licences, investment banking licences, money-lending licences, and money-services business licences for currency exchange and remittance operators. Fintech companies often seek approval under the Regulatory Sandbox framework before pursuing a full licence. The appropriate category depends on the activities your business intends to carry out.

Timelines vary considerably depending on the licence type, the completeness of supporting documents, and BNM's review cycle at the time of submission. Our Banking Licence Advisory engagement spans two to six months, which includes preparation, submission, and follow-up with the regulator. Applications that are well-prepared and free of material gaps tend to move through the process more steadily.

Our review covers the full suite of facility documents — term sheets, facility agreements, security arrangements, and any guarantee or intercreditor documents. We annotate the term sheet to highlight key obligations and flag terms that present risk or deviate from standard market practice. The review also assesses covenant packages and events of default provisions. Turnaround is typically two to four weeks per facility, depending on document volume and complexity.

Our Regulatory Compliance Programme is designed around the Financial Services Act 2013, BNM's policy documents and guidelines, and the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA). We also address relevant BNM circulars and industry codes. The programme is calibrated to the size and risk profile of your institution and is not a one-size-fits-all template.

Yes. A number of our clients are overseas financial institutions and fintech businesses exploring the Malaysian regulatory environment as part of their regional entry strategy. We assist with initial regulatory mapping, licence pathway analysis, and structuring advice — helping foreign operators understand what is required before committing to a market entry plan. Consultations are conducted in English.

All client matters are governed by solicitor-client privilege and our firm's professional obligations under the Legal Profession Act 1976. Engagement letters set out the confidentiality terms clearly. We do not disclose client information to third parties without explicit consent, except where required by law. Conflict checks are conducted prior to accepting any new engagement.