Dear BCMY Users,

Pertaining to the Securities Commissions Malaysia’s (“SC”) “List of Digital Asset Exchanges In Transitional Period” where the SC has published a list of Digital Asset Exchanges which were permitted to continue their operation for a transitional period from 15 January until 1 March 2019 on 6th March 2019 that read as follows;

“Following the release of the amended Guidelines on Recognized Markets on 31 January 2019, companies which have submitted their application to be registered with the SC as a digital asset exchange will be permitted to continue operations for another transitional period from 1 March 2019 until such period as may be notified by the SC. During the transitional period, these platform operators will not be permitted to accept new investors and will only be allowed to facilitate the withdrawal or transfer of client assets with the written instruction of the investor.

Companies which did not submit their application to the SC by 1 March 2019 are required to take necessary steps to cease their business and return all clients’ assets by 15 March 2019.

Members of the public should also take note that this notice does not constitute an approval, authorisation or endorsement by the SC of any digital asset platform operators or any digital assets traded on the platforms.”

Please be informed that BCMY (M) Sdn. Bhd. has been very committed to adhere to the guidelines issued by SC in order to be one of SC’s regulated Digital Asset Exchanges. BCMY (M) Sdn. Bhd an (affiliate of BCMY Pte. Ltd.) attended the SC’s first briefing on this matter on 17th January 2019, where SC has issued Requirements for Operating a Digital Asset Platform and Registration as a Recognized Market Operator. Please refer to the updates attached with regards to the briefing – http://bit.ly/2VJy3hf

Following the first briefing, SC has issued media statement on 17th January 2019 that summarized as follows;

“Existing platform operators who failed to or did not attend the engagement with the SC on 17 January 2019 are advised to contact the SC before the 25 January 2019. Failure to do so means that the SC will deem them to be operating a market in breach of the securities laws which could lead to RM 10 Million in fines or 10 years imprisonment. The SC also covered initial coin offerings (ICOs) in their announcement; no one can conduct an ICO without authorisation from the SC first. The regulator also confirmed that guidelines for ICOs will be issued by the end of Q1 2019. To that end, the SC ordered ongoing ICOs to cease all activities and return all the money or assets collected from investors.”

After complying with the 1st transitional period instruction from SC, we have been invited for the 2nd meeting session with SC on 19th February 2019. We were given a clearer direction on The Guidelines on Recognized Market SC-GL/6-2015 (R2-2019) where BCMY (M) Sdn. Bhd. has decided to initiate to register as Recognized Market Operators (RMO).

However, after seeking legal views on our product features and operations including series of official e-mail communication on 25th February 2019 at 4:41 PM (Singapore Time) with SC through their RMO Team as below;

1. We informed SC that BCMY Wallet is a mobile wallet platform that solely offer services for cryptocurrencies storing and Peer-to-Peer (P2P) transfer for asset storage ONLY. As such, we seek their advise as to the need for us to register as RMO.

The SC RMO Team replied (on the same date at 6:15 PM); “SC’s guidelines on Recognized Market, particularly, regulations on the Digital Asset Exchange (DAX) apply to those operating electronic platform which facilitate the trading of Digital Asset. We advise that you seek legal views on whether your operational activities fall within any regulations.”

After that reply, we take another initiatives to email SC on 28th February 2019 at 5:37 PM (Singapore Time);

2. We clarified further that BCMY Wallet is a platform for cryptocurrencies storing, we only cater for P2P transfer under Stored Valued Facilities (SVF) and we do not offer any Digital Asset Exchange (DAX) features. In addition to that, we also clarified that BCMY Wallet is in partnership with BITGO (https://www.bitgo.com/info/) as the security, compliance, and custodial solutions for our blockchain-based currencies, where BCMY Wallet is 100% is a decentralized apps. Other than that, we clearly informed SC that we have successfully received the Stored Valued Facility (SVF) Notification status from Monetary Authority of Singapore (MAS) and attached the same for their reference.

On the same date at 7:01 PM (Singapore Time) SC RMO Team replied; “The Guidelines on Recognized Market (SC-GL/6-2015(R2-2019) apply to entities operating or intending to operate a Digital Asset Exchange in Malaysia. Do consult the relevant professional advice as needed”.

Thus, based on the series of communications with SC above and after seeking legal advice as well as our own study to the FAQ on SC documents posted –http://bit.ly/2HfWcbg,

we found out that: http://bit.ly/2XIGET2

1. PART F: ADDITIONAL REQUIREMENTS RELATING TO A RECOGNIZED MARKET THAT IS A CROWDFUNDING PLATFORM – CHAPTER 13 – Equity Crowdfunding (ECF) platform

Please note that BCMY Wallet is not an equity crowdfunding platform and BCMY Wallet is a decentralized apps for P2P asset storage.

2. PART F: ADDITIONAL REQUIREMENTS RELATING TO A RECOGNIZED MARKET THAT IS A CROWDFUNDING PLATFORM – CHAPTER 14 – Peer-To-Peer Financing

Please note that BCMY Wallet is not an electronic platform that facilitates directly or indirectly the issuance, execution or offering of an investment note or an Islamic investment note. BCMY Wallet is a decentralized apps for P2P asset storage.

3. PART G: ADDITIONAL REQUIREMENTS RELATING TO A DIGITAL ASSET EXCHANGE – CHAPTER 15 – Digital Asset Exchange

Please note that BCMY Wallet is not a Digital Asset Exchange (DAX) platform as BCMY Wallet is offering services of Stored Valued Facility (SVF) decentralized application which consist of NFC Card function to purchase asset (using digital fiat) which does not fall under the definition of electronic platform which facilitates the Trading of Digital Asset.

In addition, The SC also covered initial coin offerings (ICOs) in their earlier announcement; no one can conduct an ICO without authorisation from the SC first. The regulator also confirmed that guidelines for ICOs will be issued by the end of Q1 2019. To that end, the SC ordered ongoing ICOs to cease all activities and return all the money or assets collected from investors.

Please note that BCMY Wallet is not a platform offering on Initial Coin Offerings (ICOs) as BCMY Wallet is only a decentralized apps for P2P asset storage for the blockchain-based currencies.

On the other hand, with regards to SC on the List of Digital Asset Exchanges Permitted to Continue Operations Effective 1st March 2019 until further notice and List of Digital Asset Exchanges Not Permitted to Continue Operations Effective 1st March 2019 issued on the 7th March 2019, BCMY (M) Sdn. Bhd. Have been listed as one of the companies not permitted to continue operations.

We have received an e-mail from SC RMO Team, informing us that we are required to cease our business and return all clients assets and monies on or before 15th March 2019 and failure to do so will be deemed to be operating a market breach of securities laws and the SC reserves the right to take the relevant action.

The Senior Management of BCMY (M) Sdn. Bhd. have decided and agreed to follow the instructions from SC to cease operations, hence BCMY Wallet and the product features will be continuing our operations will remain at our located Main HQ-branch registered as below:

1. BCMY Pte Ltd (201717698K): 50 Raffles Place, #30-01, Singapore Land Tower, Singapore

2. BCMY Japan Ltd : 3-35-9 (4jai), HIgashiuen, Taitoku, Tokyo 110-0015, Japan

Any operations of BCMY (M) Sdn. Bhd. in Malaysia will be stopped in accordance to the SC instruction and the partnership with BCMY Pte. Ltd and BCMY Japan will be discontinued.

As we have never done any activities relating to crowdfunding or monies collections under BCMY (M) Sdn. Bhd., we firmly inform that BCMY Wallet features will remains and any marketing relating to this product features will be conducted outside Malaysia and there will be no return of clients’ assets and monies on or before 15th March 2019.

Here, we would like to reiterate to entire existing users, that BCMY Wallet provides Stored Value Facilities (blockchain-based currencies – BTC/ETH/DNC) and have been registered and established since 2017 in Singapore and Japan, which is why we have decided to continue our operations in Singapore and Japan.

We would like to express our appreciation towards the effort of SC in recognizing market operators in Malaysia. We hope that in the near future we will have opportunity from SC to be recognized as a market operator for digital currencies’ products and services that we have to offer. On this note, we would also like to express our appreciation towards the initiatives for Bank Negara Malaysia (BNM) in declaring BCMY (M) Sdn. Bhd. as one of the List of Reporting Institutions dealing with Digital Currencies since September 2018.

Thus, as for entire BCMY Users, we hope this clarifies your concerns and we thank you always for supporting us!