Virtual asset trading platform operators

Under the Securities and Futures Ordinance (Cap. 571) (SFO) and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (AMLO), centralised virtual asset trading platforms carrying on their businesses in Hong Kong, or actively marketing their services to Hong Kong investors, are required to be licensed and regulated by the SFC.

	SFO regime	AMLO regime
Type of licence	Type 1 regulated activity (dealing in securities) & Type 7 regulated activity (providing automated trading services)	Providing a virtual asset service (operating a virtual asset exchange)
Licensing scope	Centralised platforms providing trading services in security tokens* using an automated trading engine which matches client orders and also providing custody services as an ancillary service to their trading services	Centralised platforms providing trading services in non-security tokens* using an automated trading engine which matches client orders and also providing custody services as an ancillary service to their trading services
Persons to be licensed	Licensed corporations (LCs) Licensed representatives of LCs (including responsible officers)	Licensed providers (LPs) Licensed representatives of LPs (including responsible officers)

* Given that the terms and features of a virtual asset may evolve over time, a virtual asset's classification may change from a non-security token to a security token (or vice versa). To avoid contravention of the licensing regimes and to ensure business continuity, it would be appropriate for virtual asset trading platforms to apply for licences under both the SFO and AMLO regimes.

How to apply

Please submit the licensing application to the SFC through WINGS. Please refer to the user guides and online demo of WINGS on the SFC's website on how to open a WINGS account and how to prepare an application on WINGS.

To streamline the application process, applicants for licences under both the SFO and AMLO regimes can submit a single consolidated application online and indicate that they are applying for both licences simultaneously.

Application documents

Please submit to the SFC:

Fees

The application fees are as follows:

Type of application	Type of licence	Application fee amount
Licensed corporation (under SFO)	Types 1 & 7 regulated activities	$4,740 per regulated activity
Licensed virtual asset service provider (under AMLO)	Providing a VA service	$4,740 for a VA service
Licensed representative (under SFO)	Types 1 & 7 regulated activities	$1,790 per regulated activity
Licensed representative (under AMLO)	Providing a VA service	$1,790 for a VA service
Approval to become responsible officer (SFO)	Types 1 & 7 regulated activities	$2,950 per regulated activity
Approval to become responsible officer (AMLO)	Providing a VA service	$2,950 for a VA service

Licensing Handbook for Virtual Asset Trading Platform Operators (VATP Licensing Handbook)

The VATP Licensing Handbook provides a handy licensing guide for virtual asset trading platform operators. It sets out detailed procedures to guide them on how to apply for a licence as well as the relevant ongoing notifications and other applications required of them after obtaining a licence.

Please refer to the VATP Licensing Handbook for more information on the application procedures and process.

Other relevant documents

The SFC has also issued a circular on the implementation of the licensing regimes under the SFO and the AMLO and a circular on the transitional arrangements under the AMLO.

Last update: 1 Jun 2023