Build a file the regulator can approve.
Business plan and legal documentation drafting for Labuan FSA licence applications: the three-year plan, constitutional documents, board resolutions and policy manuals, prepared by a licensed trust company.
Make an enquiryThe plan carries the application, or sinks it.
When applicants assemble a Labuan FSA file, the business plan carries most of the weight. Reviews stall when the model reads thin, the financials feel generic, or the governance and controls do not match the licence category applied for.
We draft the business plan and the full document set as part of our wider legal services. We know what Labuan FSA looks for. The constitutional documents, resolutions and policy manuals align with the plan, so the file reads as one credible, fundable operation rather than a collection of templates.
See what we handleA licensed Labuan trust company drafting your file.
QX Trust Co. Ltd is a Labuan Managed Trust Company headquartered in Labuan IBFC. We draft the documents as a licensed operator, with external counsel coordinated where needed. 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 draft for your file.
Six documents that carry a Labuan FSA licence application, drafted to the sector, structure and capital plan, and aligned to the relevant application form.
Business plan
The business model, target markets and operating structure, supported by financial projections. The document Labuan FSA reads first and weighs most.
Constitutional documents
The memorandum and articles, or equivalent constitutional documents, for the applicant entity. Drafted to match the licence category and the intended governance structure.
Board and shareholder resolutions
Resolutions authorising the application, appointing directors and officers, and approving the business plan and capital arrangements. The paper trail the regulator expects.
Compliance and AML manuals
Policy manuals covering compliance, anti-money laundering under the AMLA (Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001), KYC procedures and the reporting framework, matched to the business profile.
Risk and internal control framework
Internal policies and controls covering operations, corporate governance and, where the sector requires it, technology risk and cyber hygiene. Calibrated to the risks the business actually runs.
Director and shareholder profiles
Profiles evidencing the competency and experience of directors, controllers and senior managers. The fit-and-proper picture that sits behind the licence application.
From source information to filed document set.
Four steps to a complete, coherent documentation pack, run by the team that coordinates the rest of your Labuan FSA file.
Scope and intake
We map the licence category, the structure and the capital plan, then gather the business model, ownership details and financials. We flag any point that needs external counsel before drafting starts.
Business plan drafting
We draft the three-year plan: model, markets, projections, governance and controls. Written to read as a credible operation the regulator can assess, not a generic template.
Documentation build
We draft the constitutional documents, resolutions and policy manuals, and align them to the plan and to the relevant Labuan FSA application form so the file reads as one submission.
Review and handover
We review the full set for consistency, coordinate external counsel where a formal opinion is needed, and hand the documentation into the application for filing under our licence.
One coherent file, not a stack of templates.
Labuan FSA reads the documents together. When the plan, the constitutional documents and the policy manuals tell the same story, the review moves. When they contradict each other, queries follow. We draft the set as a single, consistent file.
- The business plan and financials match the capital plan and the licence category applied for.
- Resolutions authorise exactly what the plan describes, with no gaps in the paper trail.
- Compliance, AML and risk manuals reflect the real business profile, not a borrowed template.
- Director and shareholder profiles support the fit-and-proper picture the regulator assesses.
- Where a formal legal opinion is needed, we coordinate external counsel and keep it aligned to the file.
Frequently asked.
Direct answers on the business plan, the document set, timing and the role of external counsel.
What goes into a business plan for a Labuan FSA licence application?
A Labuan FSA business plan sets out the business model, the target markets and the operating structure, supported by financial projections covering a three-year horizon. It describes governance, internal controls and risk management, and profiles the directors, shareholders and senior managers behind the application. The plan must read as a credible, fundable operation aligned to the licence category applied for, not a generic template.
What legal documents are needed for a Labuan licence application?
The document set typically includes the business plan, constitutional documents for the applicant entity, board and shareholder resolutions authorising the application, and policy manuals covering compliance, AML, risk management and internal controls. Sector-specific licences call for additional items such as operational procedures and technology risk policies. We draft the set and align it to the relevant Labuan FSA application form.
Does QX Trust issue legal opinions?
No. We provide legal advisory and documentation support: drafting business plans, constitutional documents, resolutions and policy manuals for Labuan entities. Formal legal opinions on Malaysian or foreign law are issued through external counsel that we coordinate alongside our scope. This keeps the documentation work and any formal opinion in the right hands.
How long does it take to prepare the documentation?
Timing depends on the licence category, the complexity of the structure and how quickly source information is supplied. Straightforward applications move quickly once we have the business model, ownership details and financials. More involved sectors, with detailed policy manuals and substance plans, take longer. We scope the timeline at the outset and keep the drafting moving in parallel with the rest of the file.
Why does the quality of the business plan matter to Labuan FSA?
Labuan FSA assesses each application on the credibility of the business model, the adequacy of internal controls and the competency of the people running it. A thin or generic plan invites queries and slows the review. A well-prepared plan and internal control framework, matched to the business profile and its risks, gives the regulator what it needs to assess the file and reduces back-and-forth.
Can you draft documentation if I already have a draft business plan?
Yes. We review an existing draft against Labuan FSA expectations, identify gaps in the business model, financials, governance or controls, and rework the document set so it stands up to regulatory scrutiny. We then align the constitutional documents, resolutions and policy manuals to the plan so the whole file reads as one coherent submission.
Need the documentation drafted?
Tell us about the licence and the structure. We draft the business plan and the full document set, and coordinate external counsel where a formal opinion is required.
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