Topics · Domains · Onchain capital markets
Custody and client assets.
Custody rules exist because of past failures: client assets must be segregated, mostly kept in cold storage, and held on trust so they survive the custodian's collapse.
Some markets now license custodians separately, opening the door to banks and trust companies.
By market · 80 sources across 24 markets
East Asia
Hong Kong7 sources
Background brief on the proposed regulatory regime for providers of VA dealing, custodian, advisory and management services (LC Paper No. CB(1)530/2026(07))
LegCo's own summary of where the regimes stand: 13 licensed VATPs at end-May 2026, two stablecoin licensees, and the four-regime bill still to be introduced.
Read the originalConsultation Conclusions on Legislative Proposal to Regulate Virtual Asset Custodian Services
Confirms an SFC licence for custodians that safeguard private keys of client virtual assets outside licensed platforms. The bill had not been introduced into LegCo as of 5 October 2026.
Read the originalCircular on expansion of products and services of virtual asset trading platforms
Loosens token admission rules, lets platforms distribute tokenised securities and licensed stablecoins, and updates custody requirements; issued with a companion circular on shared order books.
Read the originalGuideline on Supervision of Licensed Stablecoin Issuers
Sets detailed rules on reserve asset composition and segregation, redemption, risk management, disclosure and cross-border issuance for licensees.
Read the originalPolicy Statement 2.0 on the Development of Digital Assets in Hong Kong
Introduces the LEAP framework and commits to a unified licensing regime covering exchanges, stablecoin issuers, dealers and custodians.
Read the original"A-S-P-I-Re" for a brighter future: SFC's regulatory roadmap for Hong Kong's virtual asset market
Sets out 12 initiatives under five pillars (Access, Safeguards, Products, Infrastructure, Relationships), including shared global liquidity and new OTC and custody regimes.
Read the originalGuidelines for Virtual Asset Trading Platform Operators
The core rulebook for licensed platforms: custody in a subsidiary with mostly cold storage, token admission criteria, retail suitability checks, market surveillance and 12 months of liquid capital.
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Mongolia2 sources
Regulation on Virtual Asset Service Provider Operations (FRC Resolution No. 258)
Current rulebook (Mongolian), published by the FRC on 27 August 2026: MNT 400 million capital per service, a board of at least five with two independent members, ISO 27001 security, listing and market abuse policies, a 100x custody cap and Travel Rule data from MNT 3 million.
Read the originalRegulation on Virtual Asset Service Providers Operations (FRC Resolution No. 175)
The first operating regulation, which capped custody at 100 times a VASP's own equity and introduced the MNT 3 million Travel Rule threshold. Repealed by FRC Resolution No. 657 of 27 December 2024; Resolution No. 258 of 2026 is the current text.
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South Korea3 sources
Act on the Value-Stable Digital Asset Issuance Business (bill no. 2212298)
Would license stablecoin issuers, require segregated reserves at least equal to the coins in issue and redemption on demand, and set rules for foreign stablecoins traded on Korean exchanges. One of several competing bills awaiting a merged government and ruling party draft.
Read the originalCapital Markets Act amendment to allow spot crypto ETFs (bill no. 2211117)
Would let crypto assets designated by the FSC serve as the underlying asset of funds and derivatives, with trust companies holding them through qualified custodians: the legal route to spot bitcoin ETFs.
Read the originalThe Act on the Protection of Virtual Asset Users to Take Effect from July 19
FSC summary of the Act: bank custody of user funds, cold storage and insurance duties, the ban on unfair trading, and FSC/FSS supervisory powers over VASPs.
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Taiwan2 sources
FSC launches themed pilot for virtual asset custody business
Lets financial institutions apply from 1 January 2025 to pilot virtual asset custody; four had applied by April 2025.
Read the originalGuiding Principles for the Management of Virtual Asset Platform and Transaction Service Enterprises (VASP)
Interim conduct rules pending legislation: segregation of client assets, whitepaper and listing reviews, and no solicitation by foreign platforms that have not registered locally.
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Southeast Asia
Indonesia4 sources
List of Digital Financial Asset Trading Providers as of 22 September 2026
OJK's latest register of licensed providers, with each licence decision and date: two exchanges, two clearing houses, two custodians and 28 trading platforms.
Read the originalOJK Regulation No. 23 of 2025 amending POJK 27/2024
Adopted 31 October 2025 and in force from 10 November 2025. Brings digital asset derivatives under OJK licensing and moves customer funds into segregated accounts held in the clearing house's name at OJK-licensed commercial banks, with 12 months (extendable) to adjust.
Read the originalOJK Regulation No. 27 of 2024 on the Implementation of Trading in Digital Financial Assets Including Crypto Assets
The core crypto rulebook, issued 10 December 2024 and effective 10 January 2025 when OJK took over from Bappebti. Sets licensing, capital, custody (at least 70% with a licensed custodian) and listing rules for exchanges, clearing houses, custodians and traders.
Read the originalBappebti Regulation No. 8 of 2021 on Guidelines for Physical Crypto Asset Market Trading on Futures Exchanges
The commodity-era rulebook that created the bourse, clearing, custodian and trader structure OJK inherited. Superseded when supervision moved to OJK in January 2025.
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Malaysia6 sources
Guidelines on Recognized Markets (SC-GL/6-2015(R14-2026))
Chapter 15 sets the DAX regime: RM15 million paid-up capital, an institutional shareholder, operator-led listing assessments and at least 80% offline storage of client assets. The current revision took effect on 20 May 2026.
Read the originalPractice Note 1/2026: Offering of Broking Services for Digital Assets
Lets stockbrokers holding a Capital Markets Services Licence offer digital asset broking after notifying the SC. It requires cash-upfront trades, no margin and full segregation of client assets.
Read the originalDigital Assets (SC overview and list of registered operators)
SC landing page listing registered DAX operators, IEO operators and digital asset custodians, with application routes. It notes that IEO registration is currently closed.
Read the originalPublic Consultation Paper No. 3/2025: Proposed Amendments to Guidelines on Recognized Markets (Digital Asset Exchange)
Proposed the liberalised listing framework and tougher financial, shareholding and custody rules for exchanges; comments closed on 11 August 2025. Superseded by the revised Guidelines on Recognized Markets in force from 20 May 2026.
Read the originalGuidelines on Digital Assets (SC-GL/1-2020(R3-2024))
Sets registration and conduct rules for IEO operators, token issuers and digital asset custodians. First issued in 2020, the current revision dates from 19 August 2024.
Read the originalSC Registers Three Digital Asset Exchanges
Announces the first registrations: Luno Malaysia, SINEGY Technologies and Tokenize Technology. Unapproved exchanges were told to cease operations and return client assets.
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Philippines2 sources
SEC Memorandum Circular No. 5, Series of 2025: Guidelines on the Operations of Crypto-Asset Service Providers
Companion guidelines, also dated 30 May 2025, that set registration conditions (a Philippine corporation with at least ₱100 million paid-up capital, excluding crypto-assets, and a staffed local office) and operating rules, including legal and operational segregation of client crypto-assets, disclosure and marketing.
Read the originalCircular No. 1108, Series of 2021: Guidelines for Virtual Asset Service Providers (VASP)
The core VASP regime: a Certificate of Authority for exchange, transfer and custody services. Minimum capital is ₱50 million with custody and ₱10 million without, plus AML, travel rule, cybersecurity and consumer protection duties.
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Singapore2 sources
MAS Expands Scope of Regulated Payment Services; Introduces User Protection Requirements for Digital Payment Token Service Providers
Commences the Payment Services (Amendment) Act 2021 in stages from 4 April 2024. It brings DPT custody and facilitation into scope and lets MAS impose user protection rules.
Read the originalPayment Services Act 2019
The core licensing law for payment services, in force since 28 January 2020. It makes DPT dealing, exchange, transfer and custody licensed activities.
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Thailand5 sources
SEC seeks public comments on draft notifications revising the NC requirements for digital asset business operators to support local activities
Draft rules, following a May 2026 consultation on principles, that would let brokers execute orders and hold client assets through Thai-licensed exchanges and add counterparty, settlement and fund management risk to net capital. Custodians would face tiered custody charges and per-customer wallet segregation.
Read the originalSEC seeks public comments on draft regulations for crypto ETFs in Thailand and enhanced qualifications for foreign digital asset custodians engaged by funds
Draft rules, following an April 2026 consultation on principles, for passive single-asset spot Bitcoin and Ether ETFs with at least 80 percent net exposure, held mainly with Thai-licensed custodians but with qualified foreign custodians allowed where needed. Comments closed on 20 September 2026.
Read the originalSEC amends digital asset business regulations to support greater variety of digital asset custodial wallet providers
Allows custodial wallet providers from qualified financial groups to serve affiliated operators, subject to independence rules. Previously only listed companies and their subsidiaries qualified.
Read the originalSEC amends regulations related to the use of digital assets as a means of payment and regulations supporting BOT Programmable Payment Sandbox
Extends the payment ban to custodial wallet providers and lets operators approved by the BOT take part in its Programmable Payment Sandbox. Effective 6 September 2024.
Read the originalSEC amends regulations on the initial coin offering of investment token, digital asset custodial wallet provider, and other provisions related to digital asset business operations
Removes the 300,000 baht retail cap for real-estate and infrastructure-backed investment tokens and requires SEC approval before operators take on other businesses.
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South Asia
Bhutan2 sources
Conduct of Business Rulebook (COBS)
Client classification, disclosure, client money and multilateral trading facility rules, including provisions specific to virtual assets; the Virtual Asset Guidance adds crypto risk warnings.
Read the originalGFSO Virtual Asset Guidance 2026 (Version 1.0)
Sets out accepted virtual assets, capital (US$200,000 for dealers and custodians, US$500,000 for an exchange), custody, technology and AML expectations, and the framework for stablecoin issuers.
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India1 source
Notification S.O. 1072(E): VDA activities notified under the Prevention of Money-laundering Act, 2002
Made businesses that exchange, transfer, safekeep or administer VDAs, or provide financial services for token offerings, reporting entities under the PMLA. This is the legal basis for FIU-IND registration.
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Pakistan4 sources
Pakistan Virtual Asset Services Regulations, 2026 (S.R.O. 1419(I)/2026)
Core licensing rulebook: minimum capital by licence category, governance, client asset segregation, 100% reserves for token issuers and a Travel Rule threshold of USD 1,000. Notified in the Gazette on 21 August 2026.
Read the originalPakistan Virtual Asset Services Activity Specific Regulations, 2026 (S.R.O. 1420(I)/2026)
Activity-by-activity rules for exchanges, brokers, custodians, lenders, asset managers, derivatives providers and issuers, including limits on margin and leveraged products.
Read the originalBPRD Circular Letter No. 10 of 2026: Authorizing Opening of Bank Accounts to PVARA's NOC/Licensed VASPs and their Customers
Replaces the 2018 ban and lets banks open accounts for PVARA-licensed VASPs and their customers, with segregated, non-remunerative rupee client money accounts, while banks themselves may not invest in or hold crypto.
Read the originalVirtual Assets Act, 2026 (Act No. XIII of 2026)
Pakistan's primary crypto law: it establishes PVARA, requires a licence for any virtual asset service in or from Pakistan and sets issuer, custody and AML duties. Signed by the President on 4 March 2026, published in the Gazette on 5 March and in force at once (section 1(3)).
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Central Asia
Kazakhstan2 sources
Law on amendments on improvement and digitalisation of the financial market (No. 352-VIII)
Amends the Digital Assets Law to require trading platforms to keep client money and digital assets in separate accounts and wallets, and extends NBK oversight to stablecoin reserve custodians. Signed 23 July 2026; most provisions take effect 60 days after its August 2026 publication.
Read the originalDecree on measures to stimulate and develop the digital asset industry (No. 1347)
Creates a Committee on Digital Assets and Payment Systems at the NBK. Orders a bill on stablecoin payments and crypto custody and the issuance of tokenised government securities by 31 December 2026, an approach to DeFi by 1 November 2026, and a bill by 1 April 2027 exempting individuals from income tax on 2026 to 2028 trades through Kazakh providers. In force from signing.
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Turkmenistan1 source
Law of Turkmenistan on Virtual Assets (official Russian translation)
Translation published by the state news agency: VASPs must be Turkmen-registered and licensed, custodians must use cold wallets, and offshore owners are barred.
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Middle East
Bahrain2 sources
CBB Rulebook Volume 6, Module CRA: Crypto-Asset
The core crypto regime: licensing, conduct, custody, technology, AML and market abuse rules for crypto-asset services. First issued February 2019; the current version applies from 6 May 2026.
Read the originalCRA-8: Crypto-asset Custody Services
Rules for safeguarding client crypto-assets, including segregation, wallet management and key controls for licensees that hold client assets.
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Israel1 source
Financial Asset Custody Provisions, Circular 2026-10-2
Binding custody rules for financial asset service licensees: client assets in trust in segregated accounts, a custody officer, a register updated at least daily, multi-party (e.g. multisig) approval of transfers, quarterly checks by an independent accountant and controls on outsourced custodians. Published 19 July 2026, in force six months after publication (January 2027).
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Jordan4 sources
Draft Executive Instructions for Virtual Asset Activities for 2026
127 draft articles on platform operators, custodians, brokers and offer providers, client dealings and investor protection, marketing, outsourcing, financial guarantees, audits and cybersecurity. Comment closed on 28 January 2026; the final instructions had not been published by 5 October 2026.
Read the originalThe Virtual Asset Service Providers Licensing Regulation for the year 2025 (Regulation No. 94 of 2025)
Issued under Article 7 of Law No. 14: two-step licensing (preliminary approval, then licence) for sole-purpose shareholding or limited liability companies or licensed foreign branches, with paid-up capital of JOD 3m (platform), 2m (custody), 1m (brokerage) and 0.5m (offerings). Published 16 December 2025, in force 30 days later (JSC English translation; Arabic text prevails).
Read the originalDraft Regulation on Licensing Virtual Asset Service Providers for 2025 (revised draft)
Revised draft setting minimum paid-up capital per activity (JOD 4 million for platforms, 2 million for custody, 1.5 million for brokerage, 1 million for offerings) and licence fees. Open for comment until 5 November 2025; the final Regulation No. 94 lowered the platform, brokerage and offering figures.
Read the originalOfficial Gazette Issue No. 5996, including Law No. (14) of 2025 Regulating Dealing in Virtual Assets
The gazette issue that enacted Jordan's virtual assets law, which requires a JSC licence for platforms, exchange, transfer, custody, brokerage and offerings. Published 16 June 2025, in force 14 September 2025 (the site uses a bot check; content confirmed via an archived copy).
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Qatar2 sources
Digital Asset Regulations 2024
Gives legal effect to tokens and smart contracts in the QFC and requires a QFCA licence for validation, token generation, custody, token exchange and transfer services. Article 9 defines cryptocurrencies and stablecoins as excluded tokens.
Read the originalALERT: QFC Regulatory Authority affirms that Virtual Asset Services may not be conducted in or from the QFC
Bars QFC firms from exchanging, transferring or safekeeping virtual assets, or dealing in them, until further notice. Digital forms of regulated securities are not covered.
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Turkey7 sources
Crypto Asset Service Providers: Operating List (provisional)
The public list of 52 firms (43 platforms and 9 custody applicants) that declared they will operate under transitional Article 11; being listed does not mean a firm is authorised. It notes the CMB's 23 September 2026 decision barring Bitexen from new customers and new listings.
Read the originalCMB Bulletin 2026/34: Authorisation of Crypto Asset Service Providers
Grants the first crypto asset custodian operating permits, to Akbank, Türkiye Garanti Bankası and Yapı ve Kredi Bankası, and establishment permits for two new platforms, Fiba and Goldtag.
Read the originalCMB Bulletin 2026/18: Extension of crypto asset service provider deadlines
Extends two deadlines under III-35/B.1: for platforms to sign custody contracts and file them with the CMB, and for listed firms to obtain authorisation. Both will be set once CMB-authorised custodians are widely serving platforms. It also grants Yapı Kredi an establishment permit for a new platform.
Read the originalCMB Bulletin 2025/68: Amounts updated for 2026
Revalues monetary thresholds for 2026, raising minimum capital to TRY 250 million for crypto trading platforms and TRY 630 million for crypto custodians.
Read the originalInformation Systems and Technological Infrastructure Criteria for Crypto Asset Service Providers
Announces the mandatory technical controls for crypto firms under the Capital Markets Law, covering hot and cold wallet security, key management, governance and business continuity.
Read the originalCommuniqué on the Working Procedures and Principles and Capital Adequacy of Crypto Asset Service Providers (III-35/B.2)
Governs permitted services, trading venues, custody and transfers, token listing, and minimum capital for platforms and custodians.
Read the originalLaw No. 7518 Amending the Capital Markets Law
Defines crypto assets and crypto asset service providers, requires CMB authorisation for trading platforms and custodians, and adds criminal penalties for unlicensed activity. Published and in force on 2 July 2024.
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UAE6 sources
ADGM FSRA Finalises Regulatory Framework for the Staking of Virtual Assets
Allows firms with Providing Custody or Managing Assets permissions to stake clients' Accepted Virtual Assets after notifying the FSRA, with rewards limited to Accepted Virtual Assets and Accepted Fiat-Referenced Tokens, following Consultation Paper No. 10 of 2025.
Read the originalThe CMA Issues the Virtual Assets Framework, Establishing an Integrated Regulatory Regime Comprising Five Core Modules and Eight Regulated Activities
Announces the federal framework for virtual asset service providers and alternative trading system operators (CMA Resolution No. (04/Chairman) of 2026): five modules and eight activities, from dealing and custody to advice, portfolio management and operating a trading facility.
Read the originalGuidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625)
The FSRA's consolidated guide to its virtual asset regime: Accepted Virtual Assets, capital, custody, technology governance and AML/CFT for multilateral trading facilities, custodians, brokers and managers. Current version dated 10 June 2025.
Read the originalVATP040: Amendments to the Executive Regulation of Federal Decree-Law No. 8 of 2017 on Value Added Tax (Cabinet Decision No. 100 of 2024)
Public clarification of the amendments that exempt the transfer and conversion of virtual assets from VAT, effective from 15 November 2024 with retroactive effect to 1 January 2018; paid custody and wallet services remain taxable.
Read the originalPayment Token Services Regulation
Licenses payment token issuance, conversion, custody and transfer; only licensed dirham payment tokens may be used for payments onshore, and foreign payment tokens must be registered. Issued as Circular No. 2/2024 on 7 June 2024, in force 31 August 2024.
Read the originalGuidance – Regulation of Digital Securities Activities in ADGM (VER02.240220)
Treats any token with the features of a security as a Security under ADGM's Financial Services and Markets Regulations, covering offerings, trading venues and custody for digital securities.
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Oceania
Australia3 sources
Corporations Amendment (Digital Assets Framework) Act 2026
Assented to on 8 April 2026. The whole Act commences the day after the 12 months from assent: 8 April 2027 under its commencement table and on the Register (ASIC's announcements say 9 April 2027). It makes digital asset platforms and tokenised custody platforms financial products that need an AFSL, with a small-platform exemption and a six-month transition to apply.
Read the originalPayments licensing reforms
Tracks the draft payment service provider law: AFSLs for payment functions, safeguarding of client money and APRA powers over major stored-value facility providers. The full Tranche 1 draft was released on 12 March 2026 for consultation that closed on 9 April 2026; no bill has been introduced yet.
Read the originalREP 705 Response to submissions on CP 343 Crypto-assets as underlying assets for ETPs and other investment products
Sets ASIC's expectations for crypto-asset ETPs and funds, including custody, pricing and which crypto assets are suitable underlying assets. This paved the way for listed crypto ETFs.
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Offshore hubs
Bermuda3 sources
Guidance Note: Digital Asset Business, Guidance for Prospective Applicants for Licensing
Sets out what the BMA expects in a DABA licence application, from the legal vehicle, head office and staffing to outsourcing, insurance, capital and custody. It names SAC, ISAC and trust structures as bankruptcy-remote options firms have used.
Read the originalDigital Asset Business (Custody of Client Assets) Rules 2025
Require licensees providing custodial wallet services to keep client assets separate from their own, account for them promptly and have client asset controls reviewed annually by a qualified person. In force 12 February 2025.
Read the originalDigital Asset Business Single Currency Pegged Stablecoins (SCPS) Guidance
Sets the BMA's expectations for licensed stablecoin issuers: segregated, high-quality liquid backing assets at least equal to coins in issue, monthly attestations, a published white paper, stress testing and recovery planning. Published with a stakeholder letter on 3 December 2024.
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British Virgin Islands2 sources
Virtual Assets Service Providers Act, 2022 (No. 17 of 2022)
Requires FSC registration to provide virtual asset services in or from within the BVI, in three categories: general services, custody and exchanges. Assented on 23 December 2022 and in force from 1 February 2023.
Read the originalBVI FSC Guidance on Application for Registration of a Virtual Assets Service Provider
Sets out what a complete application needs, including governance, capital and liquidity, technology audits and client asset safeguarding. Fees are US$10,000 for custody or exchange applicants and US$5,000 for others.
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Cayman Islands7 sources
Private Sector Consultation: Rule and Statement of Guidance on Tokenised Funds
Proposes requirements for tokenised mutual and private funds under the March 2026 amendments, covering governance, investor register integrity, transferability, valuation, custody and disclosures.
Read the originalRule: Obligations for the Provision of Virtual Asset Services, Virtual Asset Custodians and Virtual Asset Trading Platforms
Governance, capital, risk management, cybersecurity and listing rules for licensed custodians and platforms. Capital must be the higher of a risk-based amount or six months' fixed overheads; conduct sections moved to the Market Conduct Rule in February 2026.
Read the originalRule and Statement of Guidance: Market Conduct for Virtual Asset Service Providers
Applies to all VASPs: conflicts of interest, client asset segregation, insurance, marketing and risk warnings, onboarding, complaints, own-account trading, and specific duties for trading platforms and custodians.
Read the originalVirtual Asset Service Providers Registration Statistics
Quarterly counts of registered VASPs: 18 in Q4 2025, of which 3 ran trading platforms, 7 offered custody, 10 offered conversion and 1 issued virtual assets.
Read the originalDesk-Based Review: Registered Virtual Asset Service Providers
Findings from a review of 11 registered VASPs between September 2024 and February 2025, citing weaknesses in board composition, succession planning, business continuity, cybersecurity and custody arrangements.
Read the originalVirtual Asset (Service Providers) (Amendment) Regulations, 2025 (SL 19 of 2025)
Sets application documents and fees: KYD 1,000 to apply for registration, KYD 5,000 to apply for a licence, and grant fees of KYD 30,000 for custody and KYD 100,000 for a trading platform, lower for local companies.
Read the originalVirtual Asset (Service Providers) (Amendment) Act, 2024 (Act 22 of 2024)
Phase two amendments: licensing for custodians and trading platforms, at least three directors including one independent director, prior approval of senior officers and business plan changes, and wider enforcement powers.
Read the original