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Author	Ms Nur Husna Zakaria
Organisation/Institution	University of Malaya, Faculty of Law
Country	MALAYSIA
Panel	Banking and Finance
Title	Bridging Regulatory Expectations and Industry Practice in Initial Exchange Offerings: Insights from Malaysia
Abstract	This article critically examines Malaysia’s regulatory disclosure regime for Initial Exchange Offerings (IEOs), focusing on Paragraph 8.03 of the Securities Commission’s Digital Asset Guidelines 2020. It explores the extent to which the regime aligns with industry practices within the rapidly evolving crypto asset ecosystem. Drawing on the theories of negotiated governance and legal endogeneity, the study reconceptualizes traditional regulatory concepts such as the capital market, investor, and materiality to account for the decentralized and technology-driven nature of crypto markets. Through doctrinal analysis, the article interrogates whether the interpretation of investor and materiality under Paragraph 8.03 adequately reflects crypto-specific realities. Complementing this, a qualitative content analysis of selected global IEO whitepapers and a case study of Malaysia’s IEO market identify patterns of convergence and divergence between regulatory expectations and industry disclosure practices. While centered on Malaysia, the study offers insights valuable for understanding and improving disclosure regimes for crypto fundraising globally. The article concludes with regulatory recommendations to enhance the responsiveness of Malaysia’s IEO disclosure framework, offering implications for broader law reform in digital finance and investment law.
Biography	Nur Husna is currently working to complete her PhD at the Faculty of Law, Universiti Malaya, where her research focuses on the disclosure regimes in Initial Exchange Offerings. She is also currently involved as a researcher with a research project on decentralised governance at the Faculty of Law, Universiti Malaya. She previously served as a lecturer at the same faculty, where she taught legal drafting, competition law and fintech law. Her academic and professional experience spans corporate law, competition law and the intersection of law and emerging technologies. Having recently migrated to Europe with her family, she continues to engage in research and contribute to discussions on crypto law, particularly within the Malaysian and broader Asian contexts, while exploring the evolving global legal landscape of digital assets.