Hong Kong VASP regime — what the new RO regime actually requires
Two Responsible Officers, real fitness-and-properness, and a 10—15 month review window. A practical read of the SFC's posture.
From the file room
Notes, briefings, and playbooks.
Practical writing on regulated-industries licensing — drawn directly from active dossiers. We publish when there is something substantive to say, not on schedule.
Regulatory Brief
MAS DPT 2024 — what the amended Payment Services Act actually changed
The April 2024 amendments reshape who qualifies as a regulated DPT service provider, tighten client-asset segregation, and bring cross-border activity in scope regardless of where customer funds are received.
Read the briefingAnjouan vs Curaçao — where the offshore iGaming licence market actually settled
After 18 months of LOK rollout and Anjouan's emergence, the practical answer for new B2C operators is clear. The why.
When tier-1 banks de-risk a regulated VASP — the first 72 hours
What to demand in writing, where to file the complaint, and how to triage parallel onboarding before the existing account ages out.
MiCA Phase II — what the August 2026 RTS draft changes for CASPs
Capital adequacy, complaints handling, and operational resilience finalised. A practical read for operators already authorised.
Mauritius FSC vs Labuan FSA — the principal-risk broker decision in 2026
After the FATF delisting, Mauritius is back in the institutional banking conversation. Where does that leave Labuan?
Lithuanian EMI year-one — what the Bank of Lithuania actually scrutinises in supervision
The first-year supervisory interactions are formative. The patterns we've seen across 24 EMI engagements.
Travel Rule implementation across SEA — six months in
Singapore live, Hong Kong live, Malaysia phased, Thailand pending. The state-of-play across the region.
PAGCOR after the POGO sunset — what the IGL pathway looks like
The replacement regime is stricter, slower, and more substance-heavy. A pragmatic read of the IGL framework.
UAE VARA Category 4 — when the licence cost is the easy part
Capital and licence fees are predictable. Substance, custody architecture, and proof of insurance are not.
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