Find the gaps before the regulator does.
A pre-licensing audit is a structured review of your business model, ownership, capital and substance against Labuan FSA licence criteria, run by us before you file.
Make an enquiryMost files stall on points the applicant never saw.
When applicants approach Labuan FSA, they meet a review that reads the file against published licence criteria, and that read changes by sector. A capital floor that looks comfortable on paper, a substance plan that does not match the stated activity, director profiles that fall short of the fit-and-proper standard.
We run the pre-licensing audit as a licensed Labuan trust company and part of our wider legal services. A criteria-mapped review of your documents, a written readiness report and a remediation plan close the gaps on your terms, before the regulator turns them into queries.
See what we handleA licensed Labuan trust company that finds the gaps first.
QX Trust Co. Ltd is a Labuan Managed Trust Company headquartered in Labuan IBFC. We run the readiness review 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 the audit covers.
Six areas checked against the relevant Labuan FSA licence criteria, each one a place where files commonly draw queries.
Business model and plan
The proposed activity and the business plan, including financial projections and the marketing approach. We test whether the plan matches the licence applied for and reads as a viable operation.
Ownership and group structure
The shareholding chain up to the ultimate beneficial owner, the group structure and any related entities. We check the chain is clear, documented and consistent across the file.
Capital adequacy
The paid-up capital against the capital floor for the licence (the minimum capital the regulator sets per licence type). Floors vary by sector, so we map the figure to the right category before filing.
Substance plan
The operational footprint the regulator expects: an office in Labuan, adequate full-time staffing and annual operating expenditure, calibrated to the stated activity under the substance regulations.
Fit-and-proper standing
The background of directors and controllers (the fit-and-proper check the regulator applies to the people behind the licence). We review profiles, declarations and supporting evidence for completeness.
AML and governance
The anti-money-laundering framework, KYC procedures and operational manuals aligned to the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA), plus the board and policy documents that show governance is in place.
From document set to readiness report.
Four steps to test the file against the licence criteria, run by the team that can take it to filing afterwards.
Scope and document request
A confidential conversation on the licence you are pursuing and the activity behind it. We confirm the right licence category and request the document set the audit needs.
Criteria-mapped review
We map each document to the relevant Labuan FSA criterion and read it the way the regulator does. Business plan, capital, ownership, substance, fit-and-proper and AML are each tested.
Readiness report
You receive a written report setting out where the file meets the criteria, where it falls short, and a remediation plan with concrete steps for each gap.
Remediation and handover
We close the gaps with you, drafting or revising documents where needed, then hand a regulator-ready file to filing or coordinate the submission ourselves.
A report you can act on, not a checklist.
The value of the audit is in the remediation plan. A list of gaps changes nothing on its own. We set out what each gap means against the criteria, what closing it requires, and who needs to do it, so the path to a filable file is clear.
- Each gap is mapped to the Labuan FSA criterion it touches, not flagged in the abstract.
- Capital and substance are tested against the floor and footprint for your sector, not a generic standard.
- Documentation gaps come with a drafting plan, since we can draft the missing documents ourselves.
- Points needing a formal legal opinion are routed to external counsel we coordinate, not left open.
- The report carries into filing, run by the same team under our own Labuan FSA licence.
Frequently asked.
Direct answers on what the audit is, what it covers, and where it stops.
What is a pre-licensing audit?
A pre-licensing audit is a structured review of an applicant's business model, ownership, capital and operational readiness against Labuan FSA licence criteria, carried out before a formal application is filed. It identifies gaps in documentation, substance or governance and reduces the risk of regulator queries during the application.
Why run an audit before filing with Labuan FSA?
Labuan FSA reads each application against its published guidelines, and the read changes by sector. A file with missing director profiles, a thin business plan or an unclear substance plan draws queries that extend review. An audit surfaces those gaps before submission, so the file you send is closer to what the regulator expects and the review runs with fewer detours.
What does a Labuan pre-licensing audit cover?
The audit covers the business model and three-year plan, the ownership and group structure, capital adequacy against the sector capital floor, the substance plan including office, staffing and operating expenditure in Labuan, the fit-and-proper standing of directors and controllers, and the AML and governance framework. Each area is checked against the relevant Labuan FSA licence criteria.
Does QX Trust issue legal opinions as part of the audit?
No. We provide advisory and documentation support, including the readiness report and a remediation plan. Formal legal opinions on Malaysian or foreign law are issued through external legal counsel that we coordinate alongside our scope, so the points that need a formal opinion are handled by the right party.
How long does a pre-licensing audit take?
The timeline depends on the licence type and the state of your documents. A clean, well-documented file moves quickly. A file with gaps in the business plan, ownership chain or substance plan takes longer because each gap has to be closed before filing. We give an indicative timeline once we have seen the document set.
What happens if my Labuan licence application is rejected?
Labuan FSA can decline an application that does not meet its criteria, and it can ask for changes before it decides. If an application is unsuccessful, the usual route is to address the reasons given, strengthen the file, and submit again. A pre-licensing audit is designed to lower that risk by finding and closing the gaps before you file, rather than after a decision. We cannot guarantee the regulator's decision, but we can make the file as strong as the criteria allow.
Is a pre-licensing audit required by Labuan FSA?
No. Labuan FSA does not require a pre-licensing audit. It is a voluntary readiness step taken by the applicant to test the file against the licence criteria before filing. It is not a substitute for the statutory audit obligations that apply to a licensed entity after the licence is granted.
Considering a Labuan licence?
Send us the file you have. We map it to the criteria, report the gaps, and set out the steps to a regulator-ready application.
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