Crypto custody licensing across APAC

Where we work on custody

Custody is a separate authorisation in some APAC regimes and a sub-service of broader licences in others. The map for 2026:

• Hong Kong — SFC. Mandatory wholly-owned subsidiary as the VA custodian under the VATP regime, ≥98% client VAs in cold storage, insurance covering ≥50% of hot-storage VAs.
• Malaysia — SC DACS. Digital Asset Custodian framework under the Guidelines on Digital Assets — segregation, audit, cold-storage controls.
• Japan — JFSA CAESP custody. Cold-storage segregation of user crypto-assets with equivalent own-balance backup; trust-segregation of user fiat at a Japanese trust bank.
• Singapore — MAS MPI. Custody of client crypto-assets is a sub-service inside the Major Payment Institution authorisation — segregation of customer assets tightened in 2023.
• Kazakhstan — AFSA. Providing Custody (digital assets) at USD 500,000 base capital under the AIFC Rules on Digital Asset Activities.
• Thailand — SEC Custodial Wallet Provider. THB 50M paid-up plus THB 20M owner's-equity capital fund (KorThor 28/2567, effective 1 November 2024).

Operational requirements we cover

• Cold/hot wallet architecture. ≥95% cold storage standard across SFC, JFSA, AFSA — designed against HSM and multi-sig controls.
• Insurance. Hot-storage cover at the regime-specific minimum (50% in Hong Kong VATP context, scaled in others).
• Proof-of-reserves. Cadence and methodology aligned with the regulator's expectations; published evidence on a defined frequency.
• Segregation. Named, ring-fenced client-asset accounts; daily reconciliation and audit trails.
• Insolvency planning. Trust structures for client-asset bankruptcy-remoteness where the regime allows.
• Sub-custody arrangements. Where outsourcing to a licensed sub-custodian reduces capital — e.g., Australia DAP indicative 0.5% of assets held vs AUD 5M direct NTA.

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