Global FinTech Guide
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DLT and cryptocurrencies
FinTechs belonging to this category offer financial services using crypto currencies. This category also includes FinTechs utilising blockchain and distributed ledger technologies (DLT) upon which Bitcoin and Ethereum are based, among others. FinTechs develop and do research in this field in order to create new services – e.g. crypto currency exchange markets, wallet providers, NFTs-related services, new payment services, "smart contracts" or new clearing and settling services.


Attitude of the country towards financial services using crypto currencies

Recent years have seen the rise in the popularity of crypto currency, which is recognised as a digital asset, with about RM 21 billion in digital assets traded in Malaysia in 2021. Although there are legal frameworks in place to regulate the trading of cryptocurrencies as a digital asset, crypto currencies are not recognised as valid legal tender due to the volatility of digital currencies and high exposure to cyber threats.

Legal affairs

Obligations and requirements to provide financial services using crypto currencies described above

Crypto currency trading platforms are required to be registered as a Digital Asset Exchange (“DAX”) with the SC under the RMO Guidelines. DAX operators must be a locally incorporated entity and have a minimum paid up capital of RM 5 million (approximately USD1,140,000). 

The registration fee for recognised market platform operators is RM5,000 (approximately USD1,440).

Additional comments regarding the legal situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area

Under the RMO Guidelines, DAX operators must abide by the requirements imposed therein which include implementing appropriate policies and procedures to manage conflicts of interest and risk management.

Economic conditions

Market size for financial services using crypto currencies and biggest companies in this business area

It is estimated that over one (1) million people, 3.1% of Malaysia’s total population, currently own crypto currency. Currently, there are only four SC-recognised DAX operators in Malaysia: Luno Malaysia Sdn. Bhd., MX Global Sdn Bhd, SINEGY Technologies (M) Sdn. Bhd., and Tokenize Technology (M) Sdn. Bhd.

Additional comments regarding the economic situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area




© 2022, Lee Hishammuddin Allen & Gledhill. All rights reserved by Lee Hishammuddin Allen & Gledhill as author and the owner of the copyright in this chapter. Lee Hishammuddin Allen & Gledhill has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.


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