Crowdfunding & Digital Asset Platform Compliance (SC Recognized Market Operators)
Running an equity crowdfunding, peer-to-peer financing, property crowdfunding, secondary trading or token offering platform means operating a market, not just a website. The Securities Commission registers these platforms as Recognized Market Operators, and the Guidelines on Recognized Markets set out what that involves: who may raise or borrow, who may invest and how much, what must be disclosed, how investor money is held, and what the operator answers for when something goes wrong. The guidelines have been revised twice recently, in January 2025 and again on 20 May 2026, and the 2026 revision raised the bar on governance, management competency and safeguarding investor assets.
This programme walks compliance, operations and business teams through those obligations as a platform actually lives them, from onboarding an issuer or borrower, to a campaign closing or a note being repaid, to shares changing hands on a secondary market. Examples are drawn from ECF, P2P and property crowdfunding as well as token offerings, and each module separates what is common to all Recognized Market Operators from what applies to one model only. It deliberately leaves out topics that have their own course, so nothing is taught twice: anti-money laundering is covered in Anti-Money Laundering for Crowdfunding & Digital Asset Platforms, campaign promotion in Investment Advertising & Finfluencer Compliance, technology risk in SC Cybersecurity & Technology Risk Guidelines, and conflicts of interest, inside information, PDPA and Section 17A in Capital Market Compliance Essentials.
HRD Corp SBL-Khas Claimable
Programme Agenda
Day 1, 9:00 AM - 9:15 AM
Welcome and Programme Overview
Introduction to the session, objectives, and housekeeping.
Day 1, 9:15 AM - 10:15 AM
The Recognized Market Framework and Where Your Platform Sits
How the Capital Markets and Services Act 2007 treats an online market, what registration as a Recognized Market Operator permits and what it does not, and how ECF, peer-to-peer financing, digital asset exchanges and initial exchange offerings sit under one set of guidelines with different chapters. What changed in the 13th revision in January 2025 and the 14th revision in May 2026, and which changes reach ECF and token offering operators rather than only exchanges.
Day 1, 10:15 AM - 10:30 AM
Break
Day 1, 10:30 AM - 11:30 AM
Governance, Fit and Proper, and Management Competency
Board and senior management responsibilities under the guidelines, the fit and proper expectations for directors, controllers and key staff, and the tightened management competency and shareholding requirements introduced in 2026. The compliance function's reporting line and independence. What the SC looks for when it asks who is accountable for a failure.
Day 1, 11:30 AM - 12:30 PM
Issuer and Borrower Eligibility, Due Diligence and Onboarding
Which companies may raise equity, issue notes or offer tokens on a platform and which may not. The operator's due diligence duty on the issuer or borrower, its directors and its business plan or repayment capacity, and how to document a decision to list or reject so it stands up later. Red flags in pitch materials, valuations and related-party arrangements. Case workshop: three applications, one ECF, one P2P and one token offering, one decision each, with written reasons.
Day 1, 12:30 PM - 1:30 PM
Lunch
Day 1, 1:30 PM - 3:15 PM
P2P Financing and Property Crowdfunding: Credit, Servicing and Defaults
What is different when investors fund debt or property rather than equity. Credit assessment and risk grading disclosed to investors, loan servicing, collections and the treatment of late payments and defaults, and what investors must be told when a note goes bad. For property crowdfunding, developer and project due diligence, how investor money is released against project milestones, and what happens if a project stalls. Continuity arrangements so notes keep being serviced if the platform exits.
Day 1, 3:15 PM - 3:30 PM
Break
Day 1, 3:30 PM - 4:45 PM
Investor Categories, Investment Limits and Risk Disclosure
Retail, angel and sophisticated investor categories, the investment and financing limits that apply to each across ECF, P2P and property crowdfunding, and how a platform verifies and enforces them in practice. Risk warnings, cooling-off rights and the acknowledgements investors must give before they commit. Common enforcement gaps, such as limits tracked per campaign rather than per investor.
Day 1, 4:45 PM - 5:00 PM
Day 1 Close
Recap and what to review before day two.
Day 2, 9:00 AM - 9:15 AM
Day 1 Review
Recap of day one and the questions it left open.
Day 2, 9:15 AM - 10:15 AM
Disclosure Documents, Campaign Conduct and Closing
What an offer or note disclosure document must contain, who is responsible for its accuracy, and the operator's review role. Material changes during a live campaign, oversubscription, minimum targets and what happens to investor funds when a campaign fails. Handling issuer updates and investor questions fairly while the offer is open.
Day 2, 10:15 AM - 10:30 AM
Break
Day 2, 10:30 AM - 12:30 PM
Client Money, Trust Accounts and Safeguarding Investor Assets
Holding investor money in trust, reconciliation, release conditions and the audit trail regulators expect. For token offerings, custody of digital assets and the stronger safeguarding requirements introduced in the 2026 revision. What a shortfall looks like before it becomes a breach.
Day 2, 12:30 PM - 1:30 PM
Lunch
Day 2, 1:30 PM - 3:15 PM
Secondary Trading on an ECF Market
The SC secondary trading framework for ECF shares: which securities may trade, who may trade them, price formation and matching, ongoing issuer disclosure once shares are tradable, and the operator's surveillance and suspension powers. Handling corporate events such as follow-on raises, share splits and exits while trading is open.
Day 2, 3:15 PM - 3:30 PM
Break
Day 2, 3:30 PM - 4:45 PM
Complaints, Ombudsman Readiness, Reporting and Wind-Down
Designing a complaints process that resolves issues before they escalate, and preparing for external dispute resolution through the Financial Markets Ombudsman Service, which digital asset exchange operators must join during 2026. Regulatory reporting and breach notification to the SC. Business continuity and orderly wind-down so investors are protected if the platform itself fails. Capstone: a compliance calendar and gap list for your own platform.
Day 2, 4:45 PM - 5:00 PM
Wrap-Up and Q&A
Key takeaways, next steps, and close.
Key Outcomes
- Explain how the Guidelines on Recognized Markets apply to ECF, P2P financing, property crowdfunding, secondary trading and token offering platforms, including the 2025 and 2026 revisions
- Apply governance, fit and proper and management competency expectations to your own board and key staff
- Run and document issuer and borrower due diligence and listing decisions that stand up to regulatory review
- Oversee credit disclosure, loan servicing, defaults and milestone-based fund release for P2P and property crowdfunding
- Enforce investor categories, investment limits and risk disclosure consistently
- Oversee disclosure documents, live campaigns, closing and failed-campaign refunds
- Safeguard investor money and digital assets through trust, reconciliation and custody controls
- Operate secondary trading with appropriate disclosure, surveillance and suspension
- Handle complaints, ombudsman referrals, regulatory reporting and wind-down planning
Training Mode Physical / Online / Hybrid / e-learning
HRD Corp SBL-Khas Claimable
Level Intermediate. Designed for compliance officers, operations and business heads, and senior management of SC-registered ECF, P2P financing, property crowdfunding, digital asset exchange and token offering platforms, and of firms applying for registration. Familiarity with the Capital Markets and Services Act is helpful but not required.
Duration 2 Days (16 Hours) | 9:00 AM to 5:00 PM daily
Venue In-house at the client's premises, or delivered via the client's preferred platform (Microsoft Teams, Zoom, or equivalent)
Assessment A platform gap assessment against the Guidelines on Recognized Markets, completed as a prioritised action list and compliance calendar, plus a written knowledge check
Certificate Certificate of Completion issued to all participants upon full attendance