Labuan IBFC Licensed Trust Company
Our Services

Labuan Legal Services

Trust deeds, shareholders agreements, AML/CFT/CPF policies, TFS policies, foundation charters and corporate documents. Drafted under the supervision of Ms. Tiong Ik Ing (LLB, Advocate and Solicitor of the High Court of Malaya) to Labuan FSA requirements including the AML/CFT/CPF and TFS Guidelines.

Licence
Labuan FSA Trust Licence
Scope
Policies, Agreements & Corporate Documents
Approach
Bespoke Drafting, Not Templates
Framework
Aligned to AML/CFT/CPF and TFS Guidelines

The right documents, drafted for Labuan.

Signature Trust prepares all legal documentation required for Labuan entities and FSA licence applicants: trust deeds, shareholders agreements, AML/CFT/CPF policies, foundation charters and business plans. Every document is drafted in-house to meet the requirements of the Labuan legal and regulatory framework and Labuan FSA expectations under the AML/CFT/CPF and TFS Guidelines.

Our legal team works within the framework of the Labuan Financial Services and Securities Act 2010, ensuring every document and structure is compliant from day one.

We draft to fit your specific structure, not from a generic template. The same team also reviews and revises existing documentation when policies or agreements need updating to reflect current regulatory requirements.

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What our legal services cover

Why Signature Trust

Regulated, So We Know the Rules

As a Labuan FSA licensed trust company, we draft documents that meet the specific regulatory requirements of Labuan entities, from trust deeds to compliance manuals and shareholder agreements.

21+ Years Drafting Experience

Our directors are approved Trust Officers who have reviewed and drafted documentation for a wide range of Labuan structures, giving them firsthand knowledge of what Labuan FSA expects.

In-House Legal Team

Legal professionals work alongside a multi-disciplinary team, ensuring every document is both legally sound and aligned with the broader regulatory and financial framework.

Strict Document Confidentiality

Legal documentation often contains sensitive commercial terms and personal details. We apply strict access controls and confidentiality protocols to every engagement.

From instruction to execution-ready documentation

1

Consultation

We discuss the structure you have in mind or the regulatory requirement you are addressing. We identify which documents are needed and flag any legal considerations specific to Labuan FSA requirements.

2

Proposal

We confirm the scope of documentation, the drafting timeline and the fixed fee. Complex structures involving multiple parties or jurisdictions are scoped individually before any drafting begins.

3

Onboarding

We collect the information required to draft accurately: party details, intended governance terms and any existing agreements that the new documents must align with.

4

Execution

We produce the documents in final form, coordinate execution by all relevant parties and retain copies on file. Where Labuan FSA submission is required, we manage that process directly.

Frequently asked questions

Common questions about legal document drafting for Labuan entities.

What documents does a Labuan entity typically need?

A Labuan entity requires constitutional documents as a minimum: a Memorandum and Articles of Association for a Labuan company, or a Charter and Articles for a Labuan Foundation. Labuan Licensed entities additionally require a full suite of internal policies covering AML/CFT/CPF (including Counter Proliferation Financing), risk management, digital governance, Targeted Financial Sanctions (TFS) and business continuity, as well as commercial agreements such as shareholders agreements, management agreements and outsourcing agreements. Signature Trust prepares all of these documents in-house.

Can Signature Trust draft a trust deed or foundation charter?

Yes. Drafting trust deeds and foundation charters is a core part of our legal services offering. We prepare trust deeds, deeds of settlement, deeds of revocation and deeds of indemnity for Labuan trusts, as well as the Charter and Articles for Labuan Foundations. Each document is drafted to reflect the specific objectives of the structure and to meet the requirements of the applicable Labuan legislation.

What policies and procedures are required for a Labuan FSA licensee?

Labuan FSA licensees are required to maintain a comprehensive set of internal policies. These include:

  • AML/CFT Policy and Procedures manual (aligned with the AML/CFT/CPF and TFS Guidelines)
  • Counter Proliferation Financing (CPF) Policy
  • Targeted Financial Sanctions (TFS) Policy
  • Risk Management Policy
  • Digital Governance Policy
  • Business Continuity Management plan
  • Terms of Reference for the Board of Directors and Internal Audit Committee
  • HR Handbook
  • Code of Conduct Policy
  • Whistleblowing Policy
  • Terms of Business
  • Privacy Statements
  • Client Complaint Handling Procedures

The exact requirements depend on the licence type. We also align your framework with the findings of the National Risk Assessment (NRA) issued by the NCC, as required by the AML Guidelines. Signature Trust can assess your obligations and draft the full documentation suite.

Do you assist with Labuan FSA licence application documentation?

Yes. We conduct a preliminary assessment and pre-licensing audit of your business model against Labuan financial products and Labuan FSA expectations, and perform eligibility checks for applicants seeking to carry out regulated activities under the Labuan legislation. We also align your application with the National Risk Assessment (NRA) issued by the NCC. We prepare the business plan required for regulated activity applications. This work runs alongside the drafting of the policies and agreements required to support a complete application.

Is a shareholders agreement required for a Labuan company?

A shareholders agreement is not a statutory requirement for a Labuan company, but it is strongly advisable for entities with two or more shareholders. It governs the relationship between shareholders, sets out rights and obligations, addresses share transfer restrictions, and establishes decision-making procedures that go beyond what the Memorandum and Articles of Association cover. For licensed entities and joint ventures, a shareholders agreement is almost always part of the required documentation package. Signature Trust drafts shareholders agreements tailored to the specific structure and objectives of the entity.

What is the difference between a trust deed and a deed of settlement?

A trust deed is the founding document of a Labuan trust. It sets out the terms of the trust, names the trustee and beneficiaries, and defines the trustee's powers and the purpose of the trust. A deed of settlement is typically used to transfer specific assets into an existing trust, formally settling those assets onto the trustee under the terms of the trust. Both documents are required at different stages of establishing and operating a Labuan trust structure. Signature Trust prepares both.

Can you update or revise documents we already have?

Yes. We review and revise existing legal documentation for Labuan entities. This is common for entities whose policies or agreements were drafted some years ago and no longer reflect current Labuan FSA requirements including the AML/CFT/CPF and TFS Guidelines or the entity's current activities. We can prepare amending resolutions, deeds of variation, and updated versions of policies following a regulatory review or change in licence conditions.

What is the difference between Legal Services and Compliance Function?

Legal Services is a drafting service. We prepare the documents your entity needs: policies, agreements, resolutions, business plans and corporate correspondence. Compliance Function is an ongoing outsourced service where Signature Trust assists your entity's Compliance Officer in their responsibility for day-to-day regulatory compliance. The two services work together: Legal Services produces the documents, and Compliance Function implements and maintains them. Many clients engage both services, particularly Labuan licensed entities regulated by Labuan FSA.