Asia & Middle East · HK
Hong Kong
SFC licences cover securities businesses and virtual asset trading platforms; money service operators are licensed by the Customs and Excise Department.
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
- 3
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. We prepare SFC licence and money service operator applications and manage engagement with those authorities. 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
Money service operator licence
Licensing of remittance and money changing businesses.
Sectors: Payments
Our Regulatory & Licensing practice prepares the applications for these routes and manages them through to the regulator's decision.
Considerations
What to weigh up
- Licensing is activity-based; prepare for high expectations on governance, custody and conduct.
- Treat serving clients in mainland China as a separate set of 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. We deliver each to the requirements that apply locally, coordinating local specialists where local law, registration, representation or professional requirements require it.
- Privacy & Data ProtectionExternal DPO services and working privacy programmes: GDPR and global privacy laws, DPIAs, data mapping, transfers and ISO/IEC 27701.
- Information Security & CybersecurityFractional CISO support, ISMS and security programmes, certification and audit readiness, DORA, NIS2 and customer assurance for enterprise sales.
- AI GovernanceGovernance that lets AI adoption scale: EU AI Act readiness, ISO/IEC 42001 management systems, AI risk and impact assessments, and vendor risk.
- 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, copyright, domain disputes and enforcement that protect your brand, software and content across markets.
- Legal OpinionsRegulatory, business model, perimeter, payment, gaming, crypto-asset and cross-border opinions that answer what banks and investors ask.
- Bank Account OpeningHelp organising your banking with banks and EMIs that fit your model, from the onboarding file and account structure to periodic reviews.
- Merchant Account / Acquiring SetupMerchant applications, acquiring structure and negotiated terms for online and high-risk merchants that need stable card and local payment acceptance.
Support
Hong Kong: how we support your business
- Regulatory & LicensingStrategy, applications and regulator engagement for the payments, crypto and investment routes listed above.
- Corporate StructuringGroup architecture, incorporation, substance and governance built around your licences, banking and investors.
- Market Entry & Regulatory StrategyMarket prioritisation, regulatory roadmaps and launch readiness that let you expand into new jurisdictions in the right order.
Hong Kong: the right fit for your business?
We look at your product, target clients and banking needs to see whether this jurisdiction fits or another would serve you better, then send a written proposal with scope, timetable and fee.