The Exposure Draft of the Policy Document on Electronic Money (e-Money) (‘Draft’) is a solid 81 pages of document that seeks to replace and supersede the current Bank Negara of Malaysia (‘BNM’)’s Guideline on Electronic Money (2008 Guidelines) which is currently used as the primary guidelines applicable for e-money business in Malaysia. The full Draft can be obtained on BNM’s website here. Introduction The Draft sets out a list of comprehensive requirements reflecting the regulator’s expectations to be satisfied by the existing e-money issuers including future applicants seeking to be approved as an e-money issuer. The Draft consists of 5…