Jurisdictions/Hong Kong/Money Service Operator License
馃嚟馃嚢Hong KongSecurities and Futures Commission (SFC) / Hong Kong Monetary Authority (HKMA)

Money Service Operator License

License for crypto-to-fiat exchange services and OTC trading operations with AML compliance.

Money Service Operators Ordinance (Cap. 615)

Capital Required

No statutory minimum; professional indemnity insurance required

Timeline

4-6 months

Fees

HKD 50,000-100,000 application + HKD 40,000-80,000 annual

Regulatory Body

Securities and Futures Commission (SFC) / Hong Kong Monetary Authority (HKMA)

Legislative Framework

Securities and Futures Ordinance (SFO), Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), Stablecoins Ordinance 2025

Last updated: August 2025

Key Requirements

1

Professional indemnity insurance of minimum HKD 500,000-1,000,000 covering MSO operations

2

Comprehensive AML/CFT procedures compliant with AMLO including customer verification for transactions over HKD 8,000

3

Beneficial ownership and governance documentation with fit-and-proper declarations for persons >25%

4

Clear operating procedures for crypto-to-fiat exchanges and OTC trading with documented pricing

5

Segregated customer fund accounts with AMLO-regulated financial institution for collection and transfer

6

Compliance Officer appointment with AML/CFT experience for regulatory oversight of operations

7

Record-keeping policies for customer files and transaction documentation maintained 5 years minimum

8

Annual independent audit of financial statements and AML/CFT compliance procedures to AMLO

Application Process

1

Submit Money Service Operator License application to AMLO specifying exchange and OTC services

2

Provide beneficial ownership documentation and fit-and-proper declarations for board and key personnel

3

Include comprehensive AML/CFT procedures, customer agreements, and operating procedures for exchanges

4

Arrange MSO bank account with AMLO-regulated institution and provide documentation and arrangements

5

Submit professional indemnity insurance certificate and compliance officer appointment confirmation

6

AMLO review and approval following assessment of AML/CFT controls and operational procedures

Expected Total Timeline

4-6 months

Ongoing Obligations

After obtaining your Money Service Operator License, these are the continuing compliance requirements you must maintain.

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

Cost Summary

Capital Requirement

No statutory minimum; professional indemnity insurance required

Application & Licensing Fees

HKD 50,000-100,000 application + HKD 40,000-80,000 annual

Jurisdiction Setup Cost

$120,000-$350,000

Annual: $100,000-$300,000

Need help with Money Service Operator License?

Our team manages the full Hong Kong licensing process -from application preparation through post-approval implementation.

The information provided on this website is for general informational purposes only and does not constitute legal, financial, or tax advice. No attorney-client relationship is formed by use of this site. LegalWrapper.io is a product of Enterslice. Content on this site may not reflect the most current legal or regulatory developments. Consult with a qualified legal professional before making any structuring, licensing, or compliance decisions. Regulatory requirements and outcomes vary by jurisdiction and are subject to change. Prior engagements do not guarantee specific regulatory approvals or timelines.