On 26 May 2026, Hong Kong's Financial Services and Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) jointly published consultation conclusions on proposed licensing regimes for virtual asset (VA) advisory and VA management service providers. On 27 May 2026, the SFC issued a circular on the provision of services involving Relevant Stablecoins by licensed virtual asset trading platforms (VATPs) and licensed corporations. The FSTB and SFC plan to introduce a legislative proposal to the Legislative Council in 2026 to amend the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).
The proposed regimes apply a same-activity, same-risk, same-regulation principle, aligning VA advisory and VA management licensing under the AMLO with the Type 4 (advising on securities) and Type 9 (asset management) regulated activities under the Securities and Futures Ordinance (SFO). Entities advising on virtual assets or managing portfolios with virtual asset allocations above applicable thresholds must obtain a specific VA licence under the amended AMLO. The SFC confirmed it will not offer grandfathering or a transitional window for existing providers operating without a licence when the amended AMLO takes effect.
Investment advisors including virtual assets in client recommendations, discretionary portfolio managers with material virtual asset allocations, and VATPs providing stablecoin-related services must assess their licensing position under the incoming regime now. The SFC circular specifies that Relevant Stablecoins issued by entities not licensed by the Hong Kong Monetary Authority (HKMA) may only be offered to professional investors by VATPs and licensed corporations, pending issuer licensing. Retail distribution of such stablecoins is restricted until the stablecoin issuer holds an HKMA licence.
As of 26 May 2026, the legislative proposal has not yet been introduced into the Legislative Council. The commencement date of the amended AMLO and the opening of the VA advisory and management licence application window remain unconfirmed. Firms that cannot complete licensing before the amended AMLO takes effect face an interruption to lawfully conducting VA advisory or management activities in Hong Kong.
We advise asset managers, VATPs, and investment advisors on Hong Kong SFC and AMLO licensing requirements, including readiness assessments for the VA advisory and management regimes. Our partner network includes licensed local counsel in Hong Kong. Work we undertake includes SFC licensing, AMLO compliance, virtual asset regulatory strategy, and stablecoin issuer and distributor structuring.