Tokenization and Security Token Offerings: Hong Kong's Regulatory Approach to Cryptocurrency and Fintech

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Introduction

Bitcoin and Ethereum remain the two highest-market-cap cryptocurrencies to date. Other popular cryptocurrencies with significant trading volume include:

Major cryptocurrency exchanges operating globally include Binance, Coinbase, Kraken, Bybit, and OKX. As these platforms expand into Hong Kong and Asian markets, understanding the regulatory framework becomes crucial.

Licensing for Cryptocurrency and Fintech Platforms

Current License Holders

Only two virtual asset trading platforms (VATPs) have received licensing from Hong Kong's Securities and Futures Commission (SFC) to date:

  1. OSL
  2. HashKey

Pending Applications

Seven platforms are currently undergoing the licensing process:

New Market Entrants

Zodia Custody (a Standard Chartered subsidiary) announced plans in late 2023 to provide cryptocurrency custody services in Hong Kong.

VATP Licensing Requirements

Applicants must submit an external evaluation report covering eight critical areas:

Evaluation AreaKey Focus Points
Governance & StaffingLeadership structure, qualifications
Token InclusionListing criteria, due diligence
Virtual Asset CustodyStorage solutions, security protocols
KYC ProceduresIdentity verification processes
AML/CFT MeasuresTransaction monitoring, reporting
Market SurveillanceManipulation detection systems
Risk ManagementOperational risk frameworks
CybersecurityThreat prevention, response plans

Payment Licensing in Hong Kong (MSO License)

The Hong Kong Customs and Excise Department regulates Money Service Operator (MSO) licenses for:

Notable MSO License Holders:

👉 Learn more about MSO compliance requirements

Important Clarification: While MSO licensing doesn't directly regulate cryptocurrencies, any business conducting money services (as defined by Customs) must obtain this license—regardless of cryptocurrency involvement.

Tokenization and Security Token Offerings (STOs)

Why STOs Are Gaining Popularity

Hong Kong's Landmark 2023 Initiative

The Hong Kong Monetary Authority (HKMA) issued HK$800 million in tokenized green bonds—the first government-issued tokenized green bonds. The entire process occurred digitally via blockchain, including:

  1. Primary issuance
  2. Coupon payments
  3. Secondary market trading
  4. Settlement
  5. Maturity redemption

Legal Considerations for STOs

Issuers must evaluate:

  1. Whether tokens qualify as "securities" under the Securities and Futures Ordinance
  2. Prospectus requirements applicability

Common Structuring Approaches:

SFC Guidelines on Tokenized Products

Key November 2023 reminders from the SFC:

  1. Pre-approval Requirement: All new tokenized investment products require SFC recognition and prior consultation
  2. Distribution Rules:

    • Distributors must be SFC-licensed
    • Must comply with:

      • Client onboarding regulations
      • Suitability assessments

For Intermediaries Handling Tokenized Securities:

Emerging Challenges: Crypto Scams and Asset Recovery

The SFC continues to:

  1. Introduce new virtual asset regulations
  2. Expose non-compliant platforms (e.g., JPEX case regarding false licensing claims)
  3. Address rising romance/Investment scams

👉 Essential guide to crypto asset protection

Legal Recourse Options:

FAQ Section

Q1: What's the difference between utility tokens and security tokens?

A: Utility tokens provide access to a product/service, while security tokens represent investment contracts and are subject to securities regulations.

Q2: How long does VATP licensing typically take?

A: The process generally takes 6-12 months, depending on application completeness and compliance readiness.

Q3: Can individuals participate in STOs?

A: It depends on the offering structure—some are restricted to professional investors, while others may be available to retail participants.

Q4: What happens if a platform operates without an MSO license?

A: The Hong Kong Customs Department may impose fines up to HK$100,000 and 6 months imprisonment for first offenses.

Q5: Are stablecoins regulated in Hong Kong?

A: Currently under review—the HKMA has proposed a regulatory framework expected to take effect by 2024-2025.

Q6: How does blockchain help in bond tokenization?

A: It enables faster settlement, 24/7 trading, fractional ownership, and automated compliance through smart contracts.

About the Author

David Cameron Law Office (DCLO)
John Smith (pseudonym) is a qualified lawyer in Hong Kong, England & Wales, and New York with over 15 years of financial markets experience. His practice focuses on:

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