The Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Stablecoin Issuers) is the Hong Kong Monetary Authority’s statutory AML/CFT guidance for licensed stablecoin issuers in Hong Kong. It is in force from 1 August 2025, alongside the Stablecoins Ordinance framework for fiat-referenced stablecoin issuers. The HKMA states that the guideline should be read with the Stablecoins Ordinance, the Anti-Money Laundering and Counter-Terrorist Financing Ordinance and other HKMA requirements relevant to a licensee’s operations.
The guideline is designed for stablecoin issuer licensees, their officers and staff. It addresses money laundering and terrorist financing risks linked to regulated stablecoin activities, including issuance, redemption, wallet use, circulation of issued tokens and stablecoin transfers. It is not framed as a single universal implementation manual; instead, it uses a risk-based approach that varies with each licensee’s structure, business model and risk profile.
Scope of the Hong Kong Stablecoin AML/CFT Guideline
The guideline was issued under section 171 of the Stablecoins Ordinance, Cap. 656, and section 7 of the AMLO, Cap. 615. A licensed stablecoin issuer is treated as a financial institution for the purposes described in the guideline. Compliance is enforced through the Stablecoins Ordinance and, where applicable, the AMLO, and non-compliance may affect whether a licensee continues to satisfy the minimum licensing criteria.
Its status is tied to the broader Hong Kong stablecoin regime. The HKMA’s stablecoin regime page states that, after implementation on 1 August 2025, issuance of fiat-referenced stablecoins became a regulated activity in Hong Kong and a licence is required. The HKMA also published this AML/CFT guideline and a separate supervision guideline to set regulatory expectations for licensed issuers.
Key AML/CFT Requirements for Licensed Stablecoin Issuers
- Risk assessment: Licensees are expected to identify, assess and understand ML/TF risks across customer, country, product, service, transaction and delivery-channel factors.
- Governance and systems: AML/CFT systems should be approved by senior management, monitored and enhanced where necessary. The guideline also covers compliance management, an independent audit function, employee screening and staff training.
- Customer due diligence: Licensees must identify and verify customers, beneficial owners and persons acting on behalf of customers, and obtain information on the purpose and intended nature of the relationship where required.
- Wallet controls: Licensees should identify customer wallet addresses, confirm ownership or control, assess custodial wallet providers or relevant FI/VASP counterparties, and screen unhosted wallets for illicit, suspicious or sanctioned associations.
- Monitoring and reporting: The guideline covers ongoing CDD, transaction monitoring, blockchain analytics or other screening tools, suspicious transaction reporting to the Joint Financial Intelligence Unit and record-keeping.
Stablecoin Transfers and Travel Rule Treatment
The guideline applies the AMLO’s special requirements for stablecoin transfers. Depending on its role in a transaction, a licensee may act as an ordering, intermediary or beneficiary institution. The stablecoin-transfer provisions are intended to support sanctions screening, transaction monitoring and risk mitigation across relevant parties in a transfer.
For stablecoin transfers of at least HK$8,000, an ordering institution must obtain and record originator and recipient information, including identifying information for the originator and account or unique reference details for both sides of the transfer. Transfers below HK$8,000 require a narrower set of originator and recipient information. Required information must be submitted securely and immediately, meaning before, simultaneously with or concurrently with the stablecoin transfer.
Status, Consultation History and Editorial Context
Before finalisation, the HKMA consulted on proposed AML/CFT requirements for regulated stablecoin activities. The consultation opened on 26 May 2025, closed on 30 June 2025 and received 38 responses. In its July 2025 conclusions, the HKMA said it would implement the AML/CFT guideline with modifications and clarifications, and that the guideline would be published in the Gazette and take effect on 1 August 2025.
The guideline should be treated as an operative Hong Kong agency guidance instrument for CryptoSlate taxonomy purposes. Related reference pages should include the Stablecoins Ordinance, the HKMA supervision guideline for licensed stablecoin issuers and broader Hong Kong virtual-asset regulatory coverage.