Regulatory Framework Overview
Virtual Asset Trading Platform (VATP) operators conducting business in Hong Kong or actively marketing services to Hong Kong investors must be licensed and regulated by the Securities and Futures Commission (SFC) under:
- Securities and Futures Ordinance (SFO) (Cap. 571)
- Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) (Cap. 615)
Dual Licensing Requirements
| Aspect | SFO Regime | AMLO Regime |
|---|---|---|
| License Type | Type 1 (Securities Trading) & Type 7 (Automated Trading Services) | Virtual Asset Service Provider (VASP) License |
| Scope | Platforms offering security token* trading with custody services | Platforms offering non-security token* trading with custody services |
| Eligible Entities | Licensed corporations & representatives (including responsible officers) | Licensed providers & representatives (including responsible officers) |
Token classification may change over time. To ensure operational continuity, platforms are advised to apply for both licenses.
Application Process
Step-by-Step Guide
Submit via WINGS:
- Access the SFC’s WINGS portal and complete the integrated application form for dual licensing.
- Refer to the WINGS User Guide for account setup and form preparation.
Required Documents:
- Completed application form
- Written policies/procedures
- Proof of engagement with an external assessor
- Assessor’s competency statement
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Fees Structure
| Application Type | Fee (HKD) |
|---|---|
| SFO Licensed Corporation | $4,740/activity |
| AMLO Licensed VASP | $4,740 |
| SFO Licensed Representative | $1,790/activity |
| AMLO Licensed Representative | $1,790 |
Key Resources
- Licensing Handbook: Detailed procedures for license application and post-license compliance.
Circulars:
FAQs
Q1: Can a platform operate with just one license?
A1: No. If handling both security and non-security tokens, dual licensing is mandatory to avoid regulatory breaches.
Q2: How long does the application process take?
A2: Processing times vary based on documentation completeness. Expect 3–6 months for standard cases.
Q3: Are there ongoing compliance requirements post-licensing?
A3: Yes. Platforms must submit periodic reports, undergo audits, and notify the SFC of material changes.
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Additional Materials
Last Updated: January 16, 2025