Bilateral crypto trades for institutional and HNWI clients — under explicit OTC regimes (Hong Kong's upcoming SFC VA Dealer regime), implicit licences (Singapore DTSP, Thailand SEC Broker, Japan intermediary, Labuan Money-Broking), and the AML/CFT obligations specific to OTC flow.
OTC crypto trades sit between an exchange's order book and pure private treaty — bilateral, often institutional or HNWI, and historically a regulatory grey zone. APAC is closing the gap. The map for 2026:
Not yet. Hong Kong's SFC-led VA Dealer regime, expected to legislate in 2026, will be the first dedicated OTC framework. Most other regimes capture OTC under broader licences (broker, intermediary, money-broking, MPI/DTSP).
Only with a DTSP licence under FSMA Part 9, which MAS has stated it will grant rarely. The pragmatic alternatives are MPI under PSA (also serving Singapore clients) or restructuring to Hong Kong or Labuan.
OTC desks face the heaviest banking scrutiny of any crypto sub-sector. We pair the licence with a banking-partner introduction strategy and provide legal opinions on licence status and permissible activities for the bank's compliance team.
A 30-minute scoping call with the country lead. Banking-friendly structure, AML programme and Travel Rule design.