Hong Kong VASP Licensing Regime

Hong Kong’s virtual asset service provider licensing regime is the Securities and Futures Commission framework for centralized virtual asset trading platform operators under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, Cap. 615. The regime was enacted through the Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Ordinance 2022, Ordinance No. 15 of 2022. Its VASP and VATP provisions took effect on June 1, 2023, and remain in force as of June 3, 2026.

The regime is most accurately described as a VATP licensing regime, even though it is often discussed as Hong Kong’s VASP regime. It focuses on businesses that operate a virtual asset exchange in Hong Kong, or that actively market that service to Hong Kong investors. The SFC states that centralized VATPs operating in Hong Kong need to apply for a licence under AMLO, the Securities and Futures Ordinance, or both, depending on their activities and token coverage.

Scope of the Hong Kong VASP regime

The statutory framework added a new regulatory regime to AMLO for virtual asset services. In practical terms, the SFC implementation materials focus on platform operators that provide centralized trading services for virtual assets. Platforms that deal in security tokens may also need licensing under Hong Kong securities law, which is why the SFC describes the process as a dual licence arrangement.

The transitional circular states that the arrangements for pre-existing platforms applied only to VATPs providing trading services in non-security tokens. VATPs that intended to provide trading services in security tokens were directed to obtain the relevant SFO licence before commencing that business. The SFC also advised pre-existing VATPs to apply under both the SFO and AMLO where token classification could change over time.

Key provisions for virtual asset trading platforms

• SFC licensing: VATPs carrying on a business of operating a virtual asset exchange in Hong Kong, or actively marketing that service to Hong Kong investors, are within the licensing perimeter.
• Fit and proper assessment: Applicants, licensed representatives and responsible officers are assessed against fitness, propriety, competence, experience and integrity requirements.
• Governance and responsible officers: Platform operators are expected to maintain responsible officer coverage, internal controls and systems adequate for the relevant activities.
• AML/CFT and KYC controls: The SFC’s framework references customer due diligence, record-keeping, anti-money laundering, counter-financing of terrorism, and know-your-client processes.
• Client asset and conduct standards: The guidelines address safe custody, segregation of client assets, conflicts of interest, token admission, market surveillance, risk management and cybersecurity.

Status and timeline

Jurisdictional impact

The regime applies within Hong Kong and to active marketing of covered services to Hong Kong investors. It primarily affects centralized virtual asset trading platforms, their licensed representatives, responsible officers, ultimate owners, and associated entities that hold client assets. It also affects retail and professional investors through the SFC’s public lists of licensed VATPs, applicants, removed applicants and closing-down platforms.

For readers tracking Hong Kong crypto regulation, this profile should be read alongside related SFC materials on stablecoins, custody, virtual asset dealing, advisory and asset management. Those later policy workstreams may expand Hong Kong’s virtual asset perimeter, but they are separate from the core VATP licensing regime covered here.

Regulator and official sources

The primary regulator is the Securities and Futures Commission of Hong Kong. The core official sources are the Amendment Ordinance, SFC implementation and transitional circulars, the SFC guidelines for VATP operators, consultation conclusions, and the SFC’s maintained VATP status lists.