Hong Kong

Key Requirements

• Minimum HKD 5,000,000 paid-up share capital and HKD 3,000,000 liquid capital continuously per SFO
• External assessor certification confirming SFO operational standards and cybersecurity in two phases
• Real-time order matching infrastructure with guaranteed settlement within 24 hours per standards
• Comprehensive market surveillance system detecting abuse, manipulation, and suspicious patterns
• Dual governance structure with SFC Responsible Officers and AMLO-appointed Money Services Officers
• Professional indemnity insurance of minimum HKD 2,000,000 covering trading platform liabilities
• Segregated customer fund accounts with independent custodian or internal custody license
• Clear fee schedules and service terms with mandatory dispute resolution through ombudsman

Application Process

1. 1.Prepare comprehensive VATP license application to SFC specifying trading platform architecture
2. 2.Submit organizational structure with Responsible Officers CVs and AMLO fit-and-proper assessments
3. 3.Arrange external assessor engagement for pre-authorization phase assessment of operational standards
4. 4.Submit compliance manual, market surveillance procedures, and AML/CFT controls per standards
5. 5.SFC preliminary review and in-principle approval upon assessment of compliance framework
6. 6.Complete external assessor post-authorization verification following operational commencement

Ongoing Obligations

• Quarterly capital adequacy reports and annual independent audit by SFC-approved auditors
• Monthly market surveillance reports identifying suspicious activity and regulatory referrals
• Daily trading activity monitoring and quarterly metrics including volumes, settlement, and uptime
• Mandatory notifications to SFC of material changes to systems, governance, or risk management
• Annual fit-and-proper assessments for all Responsible Officers and Management Team with updates
• Maintain external assessor engagement for periodic compliance audits and cybersecurity assessments

Key Requirements

• Minimum HKD 25,000,000 paid-up share capital and HKD 3,000,000 liquid capital continuously
• 100% reserve backing in corresponding fiat currency held in segregated accounts with HKMA-approved banks
• One-business-day redemption guarantee at par-value (1:1 ratio) with documented procedures
• Board composition with at least one-third independent non-executive directors per governance
• Weekly independent audits of stablecoin reserves with certification by HKMA-approved auditors
• Restricted business model prohibited from investing reserves or providing credit using reserves
• Smart contract code audits by independent security firms with documented remediation
• Clear disclosure documentation specifying reserve composition, redemption terms, and regulatory status

Application Process

1. 1.Prepare comprehensive stablecoin issuer application to HKMA with detailed design and reserve policy
2. 2.Submit organizational structure with independent director CVs and board composition documentation
3. 3.Establish reserve account with HKMA-approved custodian bank and obtain custody agreement
4. 4.Provide detailed reserve management procedures, weekly audit protocols, and auditor letters
5. 5.Submit smart contract documentation with audit reports and remediation evidence
6. 6.HKMA review and approval following assessment of reserve adequacy and governance framework

Ongoing Obligations

• Weekly independent audits of stablecoin reserves with reports to HKMA monthly and public disclosure
• Quarterly reporting of stablecoin circulation, redemption activity, and reserve composition
• Maintain 100% segregated reserves in HKMA-approved banks with monthly custodian verification
• Immediate notification to HKMA within 24 hours of reserve shortfalls, failures, or incidents
• Annual fit-and-proper assessments for board directors and senior management with updates
• Annual smart contract security audits with documented remediation submitted to HKMA

Key Requirements

• Minimum HKD 5,000,000 paid-up share capital and HKD 3,000,000 liquid capital continuously per SFO Type 9
• Two Responsible Officers (RO) with Type 9 competency certifications and fund management experience
• Detailed fund management policies specifying crypto exposure limits (>10% triggers Type 9), leverage, and valuation
• Qualified custodian with SFC license for asset safekeeping and segregation of holdings
• Annual independent audits of fund accounts and quarterly investor reporting with NAV valuations
• Professional indemnity insurance of minimum HKD 1,000,000-2,000,000 covering fund liabilities
• Clear fund prospectus with transparent fee structures, risk disclosures, and performance fee methodologies
• Cybersecurity framework meeting SFC Technology Risk Management Guidelines with annual assessments

Application Process

1. 1.Submit SFC Type 9 Asset Management License application specifying fund strategies and crypto exposure
2. 2.Provide fund documentation including prospectus, investment policy, and custody/administration agreements
3. 3.Submit CVs for two Responsible Officers with Type 9 competency certifications and fit-and-proper declarations
4. 4.Arrange custodian appointment with SFC-licensed institution and submit agreement documentation
5. 5.Provide detailed fund valuation methodology and crypto asset pricing sources with verification procedures
6. 6.SFC review and approval following assessment of fund management framework and investor protections

Ongoing Obligations

• Quarterly fund valuations with investor reporting including asset composition, performance, and fees
• Annual independent audit of fund accounts by SFC-approved auditors within 4 months of year-end
• Monthly custodian reconciliation statements and quarterly verification of segregation and NAV accuracy
• Annual fit-and-proper assessments for both Responsible Officers with mandatory SFC notification
• Quarterly compliance certifications regarding investment policy adherence and crypto exposure limits
• Annual cybersecurity assessments and documented testing results submitted to SFC per guidelines

Key Requirements

• Minimum HKD 5,000,000 paid-up share capital and HKD 3,000,000 liquid capital continuously per SFO Type 1
• Registered representatives with Type 1 certification approved by SFC for all securities activities
• Comprehensive securities dealing procedures covering order execution, best execution, and market conduct
• Compliance Officer appointed with securities dealing experience and SFC fit-and-proper approval
• Clear client agreements specifying dealing services, fee arrangements, conflicts, and complaints per SFO
• Professional indemnity insurance of minimum HKD 500,000-1,000,000 covering dealing liabilities
• Market conduct systems including internal compliance monitoring, audit trails, and suspicious detection
• Segregated client account structures for securities holdings with qualified custodian arrangements

Application Process

1. 1.Submit SFC Type 1 Dealing in Securities License application specifying tokenized securities trading
2. 2.Provide organizational structure with CVs for Compliance Officer and registered representatives with certifications
3. 3.Include comprehensive compliance manual with securities dealing procedures and market conduct obligations
4. 4.Submit client agreements, fee schedules, and execution procedures aligned with SFO requirements
5. 5.Arrange custodian appointment with SFC-licensed institution and provide custody documentation
6. 6.SFC review and approval following assessment of compliance framework and registered representatives

Ongoing Obligations

• Quarterly capital adequacy reports and annual independent audit by SFC-approved auditors
• Quarterly execution quality reports analyzing pricing, spreads, and slippage versus benchmarks
• Monthly client complaints and dispute resolution tracking with quarterly SFC escalation reporting
• Annual fit-and-proper assessments for all registered representatives with mandatory certification renewal
• Quarterly compliance certifications regarding market conduct obligations and conflicts management
• Annual review of client agreements and execution procedures with SFO compliance certification

Key Requirements

• Professional indemnity insurance of minimum HKD 500,000-1,000,000 covering MSO operations
• Comprehensive AML/CFT procedures compliant with AMLO including customer verification for transactions over HKD 8,000
• Beneficial ownership and governance documentation with fit-and-proper declarations for persons >25%
• Clear operating procedures for crypto-to-fiat exchanges and OTC trading with documented pricing
• Segregated customer fund accounts with AMLO-regulated financial institution for collection and transfer
• Compliance Officer appointment with AML/CFT experience for regulatory oversight of operations
• Record-keeping policies for customer files and transaction documentation maintained 5 years minimum
• Annual independent audit of financial statements and AML/CFT compliance procedures to AMLO

Application Process

1. 1.Submit Money Service Operator License application to AMLO specifying exchange and OTC services
2. 2.Provide beneficial ownership documentation and fit-and-proper declarations for board and key personnel
3. 3.Include comprehensive AML/CFT procedures, customer agreements, and operating procedures for exchanges
4. 4.Arrange MSO bank account with AMLO-regulated institution and provide documentation and arrangements
5. 5.Submit professional indemnity insurance certificate and compliance officer appointment confirmation
6. 6.AMLO review and approval following assessment of AML/CFT controls and operational procedures

Ongoing Obligations

• Quarterly transaction volume reports and annual independent audit by AMLO-approved auditors
• Monthly AML suspicious activity reporting and quarterly AML/CFT compliance certifications to AMLO
• Annual fit-and-proper assessments for board members and compliance officer with updates to AMLO
• Maintenance of customer files and transaction records 5 years minimum with AMLO audit access
• Immediate notification to AMLO within 5 days of material breaches or significant customer complaints
• Annual review of MSO procedures with certification to AMLO of continued AML/CFT compliance