On-shore VASP in Hong Kong

SFC — licenses VA trading platforms under AMLO Part 5B (13 licensed as of 12 October 2026) and SFO Types 1/7 for security tokens; supervision and enforcement

HKMA — licenses fiat-referenced stablecoin issuers under the Stablecoins Ordinance (Cap. 656, in effect 1 August 2025; first two licences 10 April 2026), supervises banks, runs the Fintech Supervisory Sandbox

FSTB — virtual asset policy (policy statements of October 2022 and 26 June 2025) and legislative proposals, including the VA dealer, custodian, advisory and management licensing bill targeted for 2026

JFIU — Joint Financial Intelligence Unit — suspicious transaction reports

AMLO (Cap. 615) Part 5B, inserted by the AMLO (Amendment) Ordinance 2022 (Ord. No. 15 of 2022, gazetted 16 December 2022), introduced mandatory SFC licensing of centralised virtual asset trading platforms from 1 June 2023; licensed platforms may serve both professional and retail investors, subject to SFC token-admission and investor-protection requirements.

Securities and Futures Ordinance (Cap. 571), in force since 1 April 2003: a virtual asset trading platform offering trading in security tokens needs SFC licences for Type 1 (dealing in securities) and Type 7 (providing automated trading services) regulated activities.

A VATP licence from the SFC under AMLO Part 5B has been mandatory since 1 June 2023. The SFC VATP Guidelines require paid-up share capital of at least HK$5,000,000 and liquid capital of at least the higher of HK$3,000,000 and the Financial Resources Rules basic amount (paras 6.2-6.3), storage of 98% of client virtual assets in cold storage (para 10.6(c)), and large-cap index tests for retail-tradable tokens (para 7.8). The SFC list shows OSL Exchange (licensed 15/12/2020) and HashKey Exchange (09/11/2022) as the earliest licensed platforms; 13 were licensed on 12 Oct 2026.

Under the SFC Guidelines for Virtual Asset Trading Platform Operators (June 2023), a licensed platform operator must hold client assets on trust through a wholly owned Associated Entity (para 10.1), store 98% of client virtual assets in cold storage (para 10.6(c)), and keep an SFC-approved compensation arrangement covering 50% of client VAs in cold storage and 100% in hot and other storage (para 10.22). A separate licensing regime for VA custodians outside trading platforms is a proposal (FSTB/SFC conclusions of 24 Dec 2025), not yet law.

An SFC licence under AMLO Part 5B has been required since 1 June 2023 for any centralised virtual asset exchange carrying on business in Hong Kong or actively marketing to Hong Kong investors. OTC virtual asset dealing has no dedicated licensing regime yet: the FSTB and SFC concluded their VA dealer and custodian consultation on 24 Dec 2025 and target a bill in 2026.

Hong Kong's travel rule for SFC-licensed VASPs applies from 1 June 2023 under AMLO Sch. 2 s.13A; transfers of HK$8,000 or more need fuller originator data and verification, and smaller transfers still need names and account numbers (SFC AML/CFT Guideline paras 12.11.5–12.11.6).

The HKMA FATF travel‑rule updates linked on https://www.hkma.gov.hk/eng/key-functions/banking/anti-money-laundering-and-counter-financing-of-terrorism/fatf-related-statments-update/ no longer reflect the most recent Hong Kong SAR China regulatory stance as of November 2023.

Evidence fact hk.tax not found (may have been renamed).