A-Book Only: What a Labuan Money Broker May and May Not Do

Flat gold poster headline: a Labuan money broker brings counterparties together and never takes the other side

A B-book does not fit inside a Labuan money broking licence. It puts your firm opposite every client trade, with your own money at risk. That is dealing as principal, and the guidelines rule it out.

In broker slang, an A-book broker passes a client's order to a counterparty, while a B-book broker keeps the order and takes the other side. The guidelines use neither broker term. Labuan FSA's money broking guidelines of 9 September 2024 talk about principals, liquidity providers and market makers, and a B-book broker is the principal in its client's trade.

The licence is built around the intermediary role

Paragraph 1.1 describes money broking as arranging transactions between buyers and sellers in the money or foreign exchange markets, for a brokerage fee. It then excludes buying or selling currencies as a principal, a liquidity provider or a market maker, and Labuan FSA gives its reason there: the line keeps the intermediary clearly apart from the parties to the trade, so that dealing stays transparent and fair. Paragraph 6.1 repeats the point: the licensee acts as a mediator and is "strictly not permitted to act as a principal". A footnote to that paragraph restricts position-taking and says the broker may not speculate or engage in proprietary trading.

The name causes the confusion, in our view. What brokers often call a Labuan forex licence sounds like permission to deal in foreign exchange. It is the money broking licence, and it gives permission to broker foreign exchange. The guidelines never use the word forex.

The platform test is where each order ends up

The test comes from paragraph 6.1, where the licensee mediates and never acts as a principal. Paragraph 9.5 adds that the broker must make the capacity it acts in absolutely clear to its clients.

A platform where any order can end up in the broker's own book falls outside the licence.

Where every order goes to a counterparty, the requirements that remain include capital, substance and, for a broker regulated elsewhere, a letter of awareness or written consent from the home regulator.

Five more limits sit beside the principal rule

Topic What the rules say Source
Instruments Money and foreign exchange products. CFDs on other underlying assets are not permitted, which in practice means shares, indices and commodities. Digital assets are covered below. Guidelines, paragraphs 6.1 and 6.2
Client leverage Broker expected to cap it at 100:1, a minimum margin of 1%. Guidelines, paragraph 7.6
Client leverage, digital assets Broker expected to cap it at 1:1. Guidelines, paragraph 7.6
Market approvals The broker obtains the necessary approvals from the governing authorities in the domestic markets it serves. Guidelines, paragraph 7.15; Labuan FSA FAQ
Clients The business is intended for institutional investors and high-net-worth individuals, which Appendix II defines. Guidelines, paragraph 7.6

The leverage figures limit what your clients can take on and say nothing about your own gearing, and Labuan FSA words them as an expectation.

Client money sits in accounts kept separate from the broker's own and marked client by client, is never mixed with its general assets and is not available to pay its debts. Labuan FSA expects client withdrawals to be completed within three working days of the request (paragraph 9.4).

Digital assets turn on whether the token is securities

A Labuan money broker may broker digital assets too (paragraph 6.2). It brings counterparties together and provides the system that matches their orders, but it cannot trade the assets as principal. Two limits come with digital assets. The asset must not have the features of securities as defined in section 2 of the Labuan Financial Services and Securities Act 2010, and Labuan FSA expects client leverage to be capped at 1:1. Minimum paid-up capital also rises from RM1,000,000 to RM1,500,000.

Whether a token is securities decides the route, and our piece on which Labuan licence a crypto exchange needs works through that question.

Separate guidelines on digital money broking platforms, issued in December 2025, take effect on 1 January 2027.

Frequently Asked Questions

Can a Labuan money broker run a B-book?

No. A Labuan money broker is strictly not permitted to act as a principal, a liquidity provider or a market maker, and a B-book puts the broker on the other side of its client's trade.

What is the maximum leverage for a Labuan money broker's clients?

Labuan FSA expects a maximum of 100:1 on clients' trading transactions, a minimum margin of 1%, and 1:1 on digital assets.

Can a Labuan money broker offer CFDs?

Only on money or foreign exchange products. CFDs on other underlying assets are not permitted under the licence, which in practice means shares, indices and commodities. Digital assets are a separate permitted activity.

Written by
QX Trust Co. Ltd

QX Trust Co. Ltd is a Labuan Managed Trust Company, licensed by Labuan FSA (Licence LMT0081) since 2019 and part of QX Group. We help founders, corporates and families set up and run licensed Labuan structures, and lodge as the recognised party, with English and Chinese desks.

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Speak to QX Trust about whether your broking model sits inside a Labuan money broking licence. We are a Labuan Managed Trust Company, licence LMT0081, with English and Chinese desks.