Run a clean compliance function from day one.
A complete compliance department setup for your Labuan licence: structure, policies, the compliance officer arrangement and reporting, built and operated to align with Labuan FSA guidelines.
Make an enquiryA licence comes with a function to run.
A new Labuan licensee moves from grant into operation, and the obligations land at once. A designated compliance officer, a documented framework, a board reporting line, and the AML and risk work the regulator expects in place from day one.
We build the compliance department around your licence and then operate it as your external compliance function. A structured framework and the compliance officer arrangement mean the function works on day one, with the board keeping genuine oversight.
See what we handleA licensed Labuan trust company as your compliance function.
QX Trust Co. Ltd is a Labuan Managed Trust Company headquartered in Labuan IBFC. We build and run the function under your licence, not through an intermediary. We serve you in English, Chinese and Malay.
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Labuan FSA licensed
LMT0081
Our Labuan licence
EN + ZH + MS
Language desks
Labuan IBFC
Headquartered
What we put in place.
Six building blocks that turn a licence obligation into a working compliance department, aligned to Labuan FSA guidelines and Malaysian AMLA.
Organisation structure
The shape of the function: where compliance sits in the entity, its reporting line into the board, and the independence it needs to challenge the business and escalate issues.
Policies and procedures manual
The written framework that governs how the entity operates. AML and CFT procedures, conflicts handling, escalation, record keeping and the controls the regulator expects to read.
Compliance officer arrangement
A designated compliance officer who is a fit and proper person with relevant experience, AML and CFT awareness, and the authority to take corrective action on the entity's behalf.
Compliance calendar
Every recurring obligation mapped to a date and an owner. Regulatory filings, reviews, training cycles and board reporting, so nothing is found missing at the deadline.
Reporting templates
Standard reports that give the board a clear read on the compliance and AML position. Consistent format, the right metrics, ready for each board and committee cycle.
Service agreement and approvals
A clear outsourcing agreement that defines scope, confidentiality and accountability, with notification to Labuan FSA, and prior approval where the arrangement is material, for an external compliance arrangement.
From gap review to a running function.
Four steps to stand up the compliance department, run by the team that operates it afterwards.
Gap review
We review the entity against Labuan FSA expectations for its licence type: what exists, what is missing, and where the AML, governance and reporting gaps sit before any documents are drafted.
Framework drafting
We draft the structure, the policies and procedures manual, the compliance calendar and the reporting templates, calibrated to the size and nature of the business rather than copied from a shelf.
Officer arrangement and approvals
We put the designated compliance officer arrangement in place, agree the service agreement, and handle notification to Labuan FSA, with prior approval where the arrangement is material, for an outsourced function.
Operate and report
We run the function on an ongoing basis: monitoring, the compliance calendar, board reporting, and support for the independent review that confirms the arrangement is working.
Outsourced, but never out of your hands.
Labuan FSA lets a licensee outsource the operational compliance work. It does not let the licensee outsource accountability. We run the function while the board keeps oversight, and the arrangement is built so the regulator can see that line clearly.
- We operate the function, you keep board-level accountability for it.
- A designated compliance officer carries the role, supported by our team.
- The arrangement is set out in a clear service agreement with defined scope.
- Notification to Labuan FSA, with prior approval where the arrangement is material, handled as part of the setup.
- Independent review supported, so oversight of the arrangement holds up.
- Fully outsourced or a hybrid model, scaling as the entity matures.
Frequently asked.
Direct answers on outsourcing, the compliance officer, board accountability and the independent review.
Can a Labuan licensee outsource its compliance department?
Yes. Labuan FSA permits operational compliance work to be outsourced to a suitably qualified external provider, provided the licensee keeps accountability through a designated compliance officer and board oversight. Outsourcing arrangements are subject to a clear service agreement and to notification to Labuan FSA, with prior approval where the arrangement is material, and the licensee assesses the arrangement on an ongoing basis.
What does a Labuan compliance department setup include?
A compliance department setup covers the organisation structure and reporting lines, a policies and procedures manual, a compliance calendar of regulatory deadlines, reporting templates for the board, and the designated compliance officer arrangement. It is built to align with Labuan FSA guidelines on the compliance function and with Malaysian AMLA requirements.
Does a Labuan licensee need a compliance officer?
Labuan FSA expects a licensee to appoint a designated compliance officer responsible for ensuring the entity meets its regulatory obligations. The officer must be a fit and proper person with relevant experience and AML and CFT awareness, and must hold the authority to take corrective action. The role can be supported by an external provider while accountability stays with the licensee.
What is the difference between a compliance officer and an MLRO?
A compliance officer is accountable for the entity's overall regulatory compliance: the framework, policies, monitoring and board reporting. The money laundering reporting officer, or MLRO, owns the AML and CFT reporting role, including evaluating and filing suspicious transaction reports. In many Labuan institutions one person carries both roles, where the institution's size and risk allow and independence is kept. We can act as, or support, either role.
What is the role of the board in the compliance function?
The board retains ultimate accountability for the compliance function. It approves the compliance framework and policies, receives regular reporting from the compliance officer, oversees the risk and AML position, and ensures the function has the standing and resources to operate independently. Outsourcing operational work does not transfer this accountability away from the board.
How is an outsourced compliance function reviewed independently?
Where the compliance function is outsourced, its work is subject to an independent review. This can be carried out by a group compliance function, an audit committee, an independent director, or an independent external reviewer. The purpose is to confirm the function is operating effectively and that the licensee retains genuine oversight of the arrangement.
How long does it take to set up a compliance department?
The timeline depends on the size of the entity, the licence type, and how much already exists. A typical build moves from a gap review to a drafted framework, then to the compliance officer arrangement and Labuan FSA notifications, and into ongoing operation. We confirm a realistic timeline once we have scoped the entity rather than quoting a fixed period in advance.
Building or outsourcing a compliance function?
Tell us about your entity and its licence. We run a gap review, build the framework, and operate the function under our Labuan FSA licence.
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