The licensing requirements under the FSA, IFSA and CMSA do not generally apply if the licensable activities are carried out wholly from a place outside of Malaysia. If the licensable services are carried out within Malaysia or from a cross-border basis into Malaysia, the licensing requirements will apply unless there are applicable exceptions.

Reverse solicitation may apply to be exempt from the licensing requirements under the CMSA, but it will not be applicable as an exemption from the licensing requirements under the FSA and IFSA. Alternatively, other statutory exemptions may apply.