Asia & Middle East · HK
Hong Kong
The SFC licenses securities businesses and virtual asset trading platforms; the HKMA licenses stored value facilities and, under the stablecoin regime, fiat-referenced stablecoin issuers.
At a glance
- Status
- Special Administrative Region of China
- Region
- Asia & Middle East
- Regulated sectors
- PaymentsCryptoInvestment
- Authorities
- SFC · HKMA · Customs and Excise Department
- Licensing routes
- 5
Overview
The framework
Hong Kong is a Special Administrative Region of China with its own legal system and financial regulators. The Securities and Futures Commission (SFC) licenses securities and futures businesses and, since 2023, virtual asset trading platforms.
The Hong Kong Monetary Authority (HKMA) licenses stored value facilities and, under the stablecoin regime, issuers of fiat-referenced stablecoins. Money service operators are licensed by the Customs and Excise Department. Gambling is tightly restricted, with authorised betting limited to a single operator.
Authorities
Who regulates what
- Securities and Futures Commission (SFC)
- Securities and futures licensing, and virtual asset trading platforms.
- Hong Kong Monetary Authority (HKMA)
- Banking, stored value facilities and stablecoin issuers.
- Customs and Excise Department
- Licensing of money service operators.
Regimes
Licensing routes
SFC licences for regulated activities
Licences for dealing in securities, advising, asset management and other regulated activities.
Sectors: Investment
Virtual asset trading platform licence
SFC licensing of centralised virtual asset trading platforms.
Sectors: Crypto
Stored value facility licence
HKMA licensing of stored value facilities, such as e-wallets.
Sectors: Payments
Stablecoin issuer licence
HKMA licensing of issuers of fiat-referenced stablecoins.
Sectors: Crypto · Payments
Money service operator licence
Licensing of remittance and money changing businesses.
Sectors: Payments
Applications and regulator engagement for these routes are handled by our Regulatory & Licensing practice.
Considerations
What to weigh up
- Licensing is activity-based, with high expectations on governance, custody and conduct.
- Serving clients in mainland China raises separate legal questions.
This overview is general information, summarised at a high level. Requirements change and depend on the specific activity; seek advice on your circumstances before acting.
Industries
Relevant industries
- Fintech & PaymentsPayment and e-money institutions, PSPs and acquirers, payment facilitators and embedded finance.
- Crypto & Digital AssetsCASPs and VASPs, exchanges, custodians, wallets, token projects and crypto payments.
- Forex & InvestmentsForex and CFD brokers, investment firms, trading and investment platforms.
Across jurisdictions
Cross-jurisdiction capabilities
Services we support across the jurisdictions in our directory, described once on their own pages. How each is delivered depends on the local requirements that apply; where local qualification is required, we coordinate locally qualified counsel.
- Privacy & Data ProtectionPrivacy compliance and GDPR programmes, notices and DPAs, DPIAs, data mapping and ROPA, transfers, audits and breach response.
- AML & Financial Crime ComplianceAML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.
- IP Registration & ProtectionTrademark and patent registration and protection, copyright protection, domain name disputes, portfolio support and IP agreements.
- Legal OpinionsRegulatory, business model, perimeter, payment, gaming, crypto-asset and cross-border opinions for banks, partners and investors.
- Bank Account OpeningSupport with corporate and operational accounts at banks and EMIs, prepared for how their compliance teams assess high-risk businesses.
- Merchant Account / Acquiring SetupSupport with merchant account applications and acquiring setup at acquirers and PSPs, including for high-risk merchant categories.
Support
How we support businesses in Hong Kong
- Regulatory & Licensing01Strategy, applications and regulator engagement for the payments, crypto and investment routes listed above.
- Corporate Structuring02Group architecture, incorporation, substance and governance built around your licences, banking and investors.
- Market Entry & Regulatory Strategy10Market prioritisation, regulatory roadmaps and launch readiness for businesses expanding into new jurisdictions.
Discuss your matter with a senior advisor.
Share a few details about your business and plans. We will come back to arrange a confidential initial conversation.