The Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Ordinance 2022 is Hong Kong Ordinance No. 15 of 2022. As of 16 June 2026, the ordinance is treated in this profile as in force. It amended the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) to bring virtual asset exchange activity into a statutory licensing regime and to create a registration regime for dealers in precious metals and stones. Most provisions commenced on 1 April 2023, while the virtual asset service provider licensing provisions and related AML/CFT amendments commenced on 1 June 2023.
Purpose of the Hong Kong AMLO amendment
The amendment was designed to align Hong Kong’s AML/CFT framework with Financial Action Task Force expectations for virtual asset activity and designated non-financial businesses. It adds regulatory coverage for two sectors that the government identified as priority gaps: operators of virtual asset exchanges and dealers in precious metals and stones. The law is therefore both a crypto-market perimeter measure and a broader anti-money laundering statute.
Virtual asset service provider licensing
For crypto markets, the central feature is the Part 5B regime for virtual asset service providers. The enacted framework focuses on a “VA service” that consists of operating a virtual asset exchange. Under the SFC’s implementation materials, centralised virtual asset trading platforms carrying on business in Hong Kong, or actively marketing services to Hong Kong investors, must seek licensing under the AMLO and, where relevant, the Securities and Futures Ordinance. The SFC describes this as a dual-licence arrangement for platforms that may trade both security and non-security tokens.
- Applicants and their officers are subject to fit-and-proper assessment.
- Licensed platforms are subject to AML/CFT duties, including customer due diligence and record keeping.
- Regulatory requirements cover investor-protection controls, including custody of client assets, financial soundness, conflicts management, audits, inspections and investigations.
- Active marketing to Hong Kong investors can bring an offshore provider within the AMLO licensing perimeter if the marketed service would constitute a VA service in Hong Kong.
Transitional arrangements for virtual asset platforms
The AMLO amendment included transitional mechanics for pre-existing virtual asset trading platforms. The SFC’s circular described a non-contravention period from 1 June 2023 to 31 May 2024 for qualifying pre-existing platforms with meaningful and substantial presence in Hong Kong. Platforms that submitted complete applications by 29 February 2024 and met statutory conditions could be treated as deemed-to-be-licensed from 1 June 2024 while the SFC considered their applications. The SFC later reminded the market that the non-contravention period ended on 1 June 2024 and that platforms operating in Hong Kong must be licensed or deemed-to-be-licensed under the AMLO.
Precious metals and stones registration
Although not crypto-specific, the dealers in precious metals and stones regime is part of the same amendment. From 1 April 2023, persons carrying on a precious metals and stones business in Hong Kong and engaging in transactions at or above HK$120,000 may need to register with the Customs and Excise Department. Category A registration covers non-cash transactions at or above the threshold, while Category B registration applies to cash transactions at or above the threshold and carries AML/CFT supervision. Non-Hong Kong dealers may be exempt from registration if they meet statutory conditions, but they must file cash transaction reports for qualifying Hong Kong cash transactions.
Status and editorial treatment
CryptoSlate should classify the measure as an in-force Hong Kong act with a primary effective date of 1 April 2023 and a phase-in date of 1 June 2023 for the virtual asset licensing provisions. The profile should be read as a legal-reference summary, not as compliance advice. Related coverage should point readers to Hong Kong’s broader virtual asset regulatory framework, including SFC materials for virtual asset trading platform operators and later consultations on dealing, custody, advisory and management services.