The regulatory architecture

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Hong Kong has no single integrated financial regulator. The Securities and Futures Commission (SFC) regulates securities and futures under the Securities and Futures Ordinance (Cap. 571) and, since 2023, virtual asset trading platforms under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). The Hong Kong Monetary Authority (HKMA) regulates banks and, since August 2025, stablecoin issuers. The FSTB sets policy and drafts legislation. The Insurance Authority and the Mandatory Provident Fund Schemes Authority have marginal roles. The division matters in practice because a token business often needs to speak to two regulators whose approaches differ: the SFC is a conduct regulator with a securities mindset, the HKMA a prudential regulator with a banking mindset.¹

The SFC's stated principle is "same business, same risks, same rules", which echoes the FSB's "same activity, same risk, same regulation" and MAS's "same risk, same regulation". The content differs. The SFC applies it by extending its securities rulebook to virtual assets through conditions on licences. That makes Hong Kong's regime more detailed than Singapore's in matters such as token admission and insurance, but narrower in scope, because activities outside a licensed platform or intermediary were for a long time unregulated.²

Notes

Securities and Futures Ordinance (Cap. 571). Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), Part 5B, as inserted by the Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Ordinance 2022. Stablecoins Ordinance (Cap. 656). ↩
SFC, Virtual Assets regulatory framework overview, stating the "same business, same risks, same rules" principle and listing the four categories of SFC-licensed or registered intermediaries: virtual asset trading platform operators, virtual asset fund managers, intermediaries dealing in or advising on virtual assets, and intermediaries distributing virtual asset-related products. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

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