Hong Kong
Hong Kong runs one of Asia's most explicit dual-track regimes — SFC-licensed VASPs for trading platforms and HKMA-licensed issuers for fiat-referenced stablecoins. Retail access is deliberately narrow, wholesale rails are being built fast, and enforcement against unlicensed solicitation is now visible.
Comprehensive
Securities and Futures Commission (SFC) · HKMA
VASP licensing under AMLO (June 2023); Type 1 & 7 SFC uplifts for security tokens; stablecoin licensing under HKMA Stablecoin Ordinance (2025).
AMLO Schedule 2 obligations; Travel Rule since Jan 2024; annual AML/CFT return filed with SFC.
Implemented — HKD 8,000 threshold; sunrise gap addressed via SFC circular (Nov 2024) requiring risk-based mitigation.
IRD DIPN 39: profits tax on trading; no CGT; stablecoin issuers taxed on issuance revenue.
Retail access limited to SFC-approved large-cap tokens; suitability + knowledge test required.
Mandatory VASP licensing for centralised exchanges serving HK.
HKMA-issued licences for fiat-referenced stablecoin issuers; reserve and redemption standards.
HKD- and USD-referenced issuers approved after 18-month sandbox.
Unlicensed solicitation of HK retail; enforcement escalates.