The Briefing.
HKIDR-DM client consent — Q3 2026 to Q4 2027 (26EC61)HKIDR-DM launch — Q2 2028 (26EC61)Phishing-resistant login — by 8 Jul 2027 (26EC35)FRR — monthly return due 21st, WINGS onlyCPT — ROs 12 hrs by 31 Dec, incl. 2 hrs ethicsAnnual return — within 1 month of licensing anniversaryMIC changes — notify within 7 business daysNext briefing — Monday 7:30am HKT

SFC and HKMA, Hong Kong · Free every Monday

The 5-minute Monday briefing for Hong Kong’s small licensed firms.

Every SFC and HKMA development from last week, summarized in plain English, with the “so what” for a firm that runs compliance on a small team.

Written by a practitioner with 20 years in Hong Kong compliance. No spam, unsubscribe anytime.

Engraving of a lighthouse sweeping a yellow beam across Victoria Harbour, lighting up small junk boats against the Hong Kong skylineEngraving of a lighthouse sweeping a yellow beam across Victoria Harbour, lighting up small junk boats against the Hong Kong skyline

One beam over the harbour, every Monday

Inside every issue

Everything published Monday to Friday is filtered once into three fixed sections, read in five minutes.
01Engraving of a magnifying glass highlighting one document in yellowEngraving of a magnifying glass highlighting one document in yellow

This Week's One Thing

The single development you can't ignore: who's in scope, what to actually do, and by when. Never more than one.

02Engraving of a broom sweeping scattered papers into one tidy stackEngraving of a broom sweeping scattered papers into one tidy stack

The Sweep

Everything else from the week, one line each, tagged by licence type, so you skip what doesn't apply in seconds.

03Engraving of a balance scale weighed down by a stack of gold coinsEngraving of a balance scale weighed down by a stack of gold coins

Enforcement Corner

What a real firm did, what it cost, and the control that would have caught it. The section people forward.

From the latest issue

Nº 009 · 12 October 2026
01This Week's One Thing

Design as if one account is already compromised

On 2 June 2026 the SFC issued Circular 26EC32 to licensed corporations, SFC-licensed virtual asset service providers and their associated entities, asking them to review and enhance their cybersecurity measures against attacks assisted or accelerated by frontier AI tools. Earlier issues here covered the patching and asset-inventory half. Two other sections are just as specific and get less airtime: access and privilege controls, and incident response and recovery.

On access, the circular says firms should design system controls on the assumption that any user, device, privileged account or network component may be compromised. It lists what that means in practice:

  • enforce least-privilege access to all business critical components, including limiting connectors and tool permissions to what the use case needs, and safeguard privileged accounts;
  • enhance firewalls and network segmentation, with micro network segmentation where feasible to limit lateral movement;
  • treat external and untrusted inputs — content from apps, emails, documents and webpages — as potentially adversarial, so they cannot directly alter system instructions or trigger privileged actions;
  • apply maker-checker controls for high-impact actions.

On response, it warns that AI-enabled attacks may unfold faster than traditional detection and response can handle, and that relying on post-incident investigation or normal escalation channels may let the attack continue or worsen. Firms should have escalation and reporting mechanisms and consider pre-planned containment strategies, including the ability to block malicious activity, isolate affected systems and restrict access rapidly. They should test the plans through tabletop exercises, simulated attacks or other appropriate means, back up business records, client and transaction databases and supporting documentation regularly, and promptly notify the SFC of material cybersecurity incidents.

  • Who’s in scope: licensed corporations, SFC-licensed VASPs and their associated entities. The circular puts ultimate responsibility on senior management, including the Manager-in-Charge of Information Technology (MIC-IT).
  • What to do: review your access, privilege, containment and recovery arrangements against the circular’s sections, using the examples in its Appendix.
  • By when: no date is given. The SFC says it may issue further guidance, conduct reviews of preparedness, or take supervisory action where appropriate.
TechnologyAll licences
Read the full issue →

59 SFC circulars, each one summarized and tagged.

Open the Record →

The 2026 Hong Kong Compliance Calendar: every FRR, BRMQ, CPT and annual-return deadline on one page, free with your subscription.

Get the calendar →
Engraving of three different professional hats on a wall rack, one with a yellow bandEngraving of three different professional hats on a wall rack, one with a yellow band

Built for the RO wearing three MIC hats: boutique asset managers, hedge funds, family offices and brokers, plus the consultants who serve them.

One email a week.

Written for the person who owns the risk, not the person selling the software.