Define the service in operational terms
The SFC’s platform framework concerns centralised trading platforms and distinguishes relevant securities and anti-money-laundering regimes. Begin by describing the proposed matching, dealing and custody functions. A software company, broker and customer-asset platform can require different analyses even when their public websites all use the word exchange.
Prepare a customer journey showing onboarding, deposits, order handling, settlement and withdrawal. Identify every legal entity and third-party provider involved. State where clients are located and how the service will be marketed. Do not leave customer geography until the final marketing plan; it belongs in the initial regulatory brief.
Turn controls into operating responsibilities
SFC platform requirements address custody, KYC, AML, conflicts, token admission, market conduct, accounting and cybersecurity. Assign each relevant subject to a named internal owner and identify outsourced responsibilities. This creates an implementation map rather than a collection of policies that cannot be connected to actual system behaviour.
For a custody process, show who can initiate, approve and reconcile transfers. For token admission, explain who evaluates a proposed asset and maintains the record. For incidents, describe who communicates with customers and restores operations. These are preparation questions, not a complete regulator application checklist or a guarantee of approval.
Separate formation from launch readiness
Company formation, bank access, technology development and regulatory permission are separate workstreams. Track the evidence required for each and identify dependencies. Avoid promising a customer launch date solely because incorporation is complete or an application has been submitted; unresolved custody and permission questions can change the entire operating plan.
Use the SFC’s current licensing and conduct materials for the proposed model and obtain specialised advice on its scope. Keep a dated decisions register with the source reviewed, interpretation, responsible person and next action. Reopen the analysis whenever the business adds a product, customer class or new asset-handling function.
Sources & scope
Official sources support the jurisdiction context. The working checklists are CryptoGov’s editorial preparation suggestions, not an exhaustive application or filing requirement. Confirm the rules and your circumstances before acting.