Crypto broker licensing across APAC

Broker vs exchange — the regulatory difference

An exchange operates a multilateral trading venue with a matching engine and a captive client base. A broker intermediates between a client and one or more counterparties or venues. The broker model carries lower capital in most APAC regimes — useful when the business case is execution and advisory rather than running an order book.

Where we file broker licences

• Hong Kong — SFC Type 1. Dealing in securities, used for crypto-related securities and tokenised products. Often paired with VATP for full venue activity.
• Japan — JFSA CAESP broker. Sub-category for intermediary activity that does not custody assets — JPY 10M stated capital floor, JVCEA membership.
• South Korea — FSC/KoFIU VASP broker. Same SFTRA registration as exchanges; banking constraint less binding when not handling KRW retail.
• Thailand — SEC Digital Asset Broker. THB 25M with client assets, THB 5M asset-keeping no access, THB 1M non-asset-keeping. Three tiers depending on scope.
• Labuan — Money-Broking with virtual-currency endorsement. MYR 500k paid-up; commonly used for offshore-facing brokerage to non-Malaysian clients.

How a broker-only licence shapes product

• No captive order book. Routing into licensed exchanges or counterparty desks; pricing built on aggregator stacks.
• No custody required. In SEC Thailand non-asset-keeping mode the licence sits at THB 1M — broker hands custody to a separate licensed custodian.
• Suitability and disclosures. Retail-facing brokers carry meaningful conduct overlay — in HK and KR especially.
• Counterparty management. Onboarding a venue or liquidity provider becomes the operational core, not market-making.

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