Iconomy Completes Due Diligence on Proposed Digital-Banking Acquisition

Singapore, 2 October 2026 — Iconomy Consulting Group has completed a cross-border corporate due diligence exercise for a prospective investor evaluating an acquisition involving a proposed Malaysian digital-banking and digital-assets business.

The exercise involved the review of corporate and transaction documentation, ownership and authority matters, regulatory representations, and other material information relevant to the proposed acquisition.

Given the regulated nature of the proposed business, a significant part of the exercise involved determining whether material regulatory representations made in connection with the proposed transaction could be independently verified with the relevant authorities.

Independent verification of regulatory documentation

Among the documents examined was a letter dated 6 January 2022 bearing the title “Blockchain Digital Banking & Assets Exchange License Application Joint Venture Investment Offer for Malaysia”, which appeared to concern an application and investment proposal relating to digital banking and digital assets in Malaysia.

Rather than relying solely upon the documents and representations made available in connection with the transaction, Iconomy sought independent verification through the relevant Malaysian governmental and regulatory channels.

Following enquiries made during the due diligence exercise, the Ministry of Finance Malaysia confirmed in writing on 2 October 2026 that the 6 January 2022 letter submitted for verification had not been issued by the Government Procurement Division of the Ministry of Finance.

The Ministry further clarified that approvals relating to digital banking and digital-asset activities fall within the jurisdiction of Bank Negara Malaysia rather than the Ministry of Finance.

The written response enabled Iconomy to conclude a material aspect of its verification exercise and provide the prospective investor with independent primary-source information against which the regulatory representations underlying the proposed transaction could be assessed.

Due diligence as an exercise in verification

Boo Kok Chuon, Group CEO of Iconomy Consulting Group, said:

“Due diligence should not begin with a predetermined conclusion about whether a transaction is good or bad. Our role is to identify the material propositions upon which the investment decision depends and determine whether those propositions can withstand independent verification.

This becomes especially important where an investment involves emerging financial technologies, cross-border transactions or regulatory representations. Where information can be verified directly with the relevant institution or authority, we believe that verification should be pursued before substantial capital is committed.”

Iconomy emphasised that its findings concerning the 6 January 2022 letter are confined to what was independently established through the due diligence process.

The exercise did not determine the authorship or provenance of the document, nor does the Ministry’s response, without further evidence, establish the knowledge, intention or conduct of any particular individual or organisation. Iconomy therefore does not draw conclusions beyond the matters capable of independent verification.

The identity of Iconomy’s client, the proposed transaction value, acquisition target and other commercially sensitive aspects of the engagement remain confidential.

A multidisciplinary approach to transaction due diligence

The engagement drew upon Iconomy’s multidisciplinary capabilities across corporate strategy, governance, finance, valuation and legal-commercial analysis.

For transactions involving regulated or emerging industries, Iconomy’s approach is to identify the assumptions material to the investment proposition, distinguish independently established facts from representations requiring further verification, and progressively test those representations against primary-source evidence wherever practicable.

The Group believes that rigorous verification is particularly important where investors encounter unfamiliar regulatory instruments, novel licensing terminology or representations involving governmental authorities.

Prospective investors considering transactions involving regulated financial activities should obtain appropriate professional advice and, where material regulatory approvals form part of the investment proposition, independently verify their status with the relevant regulatory or governmental authority before committing capital.

About Iconomy Consulting Group

Iconomy Consulting Group provides multidisciplinary corporate advisory services spanning governance, corporate strategy, business structuring, transaction support and related professional services. Its advisory approach integrates commercial, financial, legal and governance perspectives to support businesses and investors navigating complex transactions and strategic decisions.