HKSI Paper 1 Regulatory overview of the Hong Kong financial industry question: Licence for a virtual asset trading platform

HKSI Paper 1Regulatory overview of the Hong Kong financial industry

Tsim Sha Tsui Digital Exchange Ltd plans to run a centralised platform in Hong Kong on which clients trade non-security virtual assets such as bitcoin. What licence does the platform operator need?

A A virtual asset trading platform licence from the SFC under Part 5B of the AMLO (Cap. 615)
B A Type 7 licence from the SFC under the SFO, which already covers trading in all virtual assets
C A stablecoin issuer licence from the HKMA under the Stablecoins Ordinance
D A money service operator licence from the Commissioner of Customs and Excise

Show the answer and explanation

Answer: A. A virtual asset trading platform licence from the SFC under Part 5B of the AMLO (Cap. 615)

Since 1 June 2023 a centralised virtual asset trading platform carrying on business in Hong Kong, or actively marketing to Hong Kong investors, must be licensed by the SFC under Part 5B of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). If security tokens are also traded, SFO Type 1 and Type 7 licences are needed too, but Type 7 on its own does not reach non-security virtual assets. A stablecoin issuer licence covers issuing fiat-referenced stablecoins, not running a platform. A money service operator licence covers remittance and money changing. Source: AMLO (Cap. 615) Part 5B; SFC 'Virtual asset trading platform operators' (sfc.hk) (as at October 2026).

Common mistake

Assuming everything 'crypto' falls under the SFO. Non-security virtual asset platforms are licensed by the SFC under the AMLO, not under Type 7.

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Original study material mapped to the public HKSI Paper 1 syllabus. Unofficial, not endorsed by HKSI Institute or the SFC. Verify figures and rules against current guidance before relying on them.