The Record

Twelve months of SFC circulars, on one page.

All 59 circulars the SFC issued from July 2025 to September 2026 — each one summarized, tagged, and given the small-firm “so what”. Every entry links to the official text on sfc.hk. Read the original before you act; this page is the map, not the territory.

Complete to 30 September 2026 — the SFC’s most recent circular

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Technology Products Conduct VA AML OTC derivatives Type 1 All licences Licensing Type 9 Client assets FRR Type 4

59 of 59 shown

SEPTEMBER 2026

5 circulars

30 Sept

26EC59

FYI

Securities and Futures Commission & Securities Commission Malaysia Memorandum of Understanding on Simplified Dual IPO Listing Framework Circular on the Single Submission Arrangement for Dual Listings in Hong Kong

The SFC and Securities Commission Malaysia set out a single submission arrangement for companies seeking a simultaneous primary listing in one market and a secondary listing in the other. All application materials go to the primary-listing regulator, with one channel for regulatory comments and responses.

Only relevant if you sponsor a Hong Kong–Malaysia dual listing; if so, read the submission guidance for your primary and secondary scenario.

ProductsRead on sfc.hk ↗

30 Sept

26EC60

ACT

Circular to intermediaries Obtaining client consent under the Hong Kong Investor Identification Regime for the exchange-traded derivatives market (HKIDR-DM)

The SFC sets out how intermediaries must obtain express consent from individual clients to collect and transfer their personal data to the SFC and HKEX under the derivatives investor identification regime. Consent must be explicit, explained, authenticated and recorded; without it, a client may only close existing open positions.

Draft or adapt a consent form covering all the specified purposes, and check any existing client consents against that list before relying on them.

ConductRead on sfc.hk ↗

30 Sept

26EC61

ACT

Circular to Intermediaries Roadmap for Implementing the Hong Kong Investor Identification Regime for the Exchange-traded Derivatives Market

The SFC sets out the roadmap for the investor identification regime for the exchange-traded derivatives market (HKIDR-DM), scheduled for the second quarter of 2028. Relevant intermediaries must assign each relevant client a BCAN, submit client identification data to an HKEX repository and include the BCAN on every order.

If clients trade futures or options through you, start now: client consent and client identification data updates both run from Q3 2026 to Q4 2027.

ConductTechnologyRead on sfc.hk ↗

4 Sept

26EC54

FYI

Circular to Licensed Corporations, SFC-licensed Virtual Asset Service Providers and Associated Entities Brokers' Forum

The SFC will host a brokers' forum on 28 September 2026 at its Quarry Bay office, sharing supervisory observations and regulatory updates with a focus on cybersecurity and anti-scam measures. It is free, conducted in Cantonese, and offers 1.5 CPT hours.

Submit one enrolment form per firm, for up to two nominees, by 10 September; places are first-come, first-served.

Type 1TechnologyRead on sfc.hk ↗

3 Sept

26EC55

ACT

Circular on SFC-authorised funds with exposure to private market assets

The SFC gives guidance to managers of SFC-authorised funds with direct or indirect exposure to private credit and private equity. Enhanced disclosure of the extent, nature and key risks of that exposure is required in offering documents and key facts statements, and exposure of 50% or more of NAV makes a fund a complex product.

Review each authorised fund for private market exposure, including BDCs and CLOs, and update its offering document and KFS as soon as practicable.

ProductsType 9Read on sfc.hk ↗

AUGUST 2026

2 circulars

31 Aug

26EC52

NOTE

Circular to Licensed Corporations in relation to list of prescribed persons who have reached the clearing threshold under the clearing and record keeping rules for the OTC derivatives regime

An updated list of prescribed persons who have reached the clearing threshold under the OTC derivatives clearing and record keeping rules has been posted on the SFC website. It is compiled from information available to the HKMA and the SFC and may be updated from time to time.

Pull the updated list from the SFC website and re-check it against your OTC derivative counterparties.

OTC derivativesRead on sfc.hk ↗

20 Aug

26EC51

ACT

Circular to licensed corporations, SFC-licensed virtual asset service providers and associated entities Mitigating risks in receiving deposits through simplified eDDA arrangements

The SFC sets out the risks of simplified eDDA arrangements, where the licensed firm initiates the direct debit setup as payee on its client’s pre-authorisation: impersonation, unauthorised setup requests, and the indemnities firms give their banks. Firms should review these arrangements, assess the risks and implement mitigating measures.

Ask whether your payer banks confirm eDDA setups; where they do not, prove account ownership with a one-off small-value transfer before accepting deposits.

AMLConductVARead on sfc.hk ↗

JULY 2026

9 circulars

29 Jul

26EC45

NOTE

Joint Circular on the Cross-Sectoral Cyber Mapping Exercise

The HKMA, SFC, IA and MPFA report the outcomes of the first production run of their cross-sectoral Cyber Mapping exercise, completed in March 2026, which mapped how over 50 participating financial institutions interconnect. It found no new major sources of systemic cyber risk, but flagged recurring reliance on certain specialist third-party providers.

No filing required, but map your own critical technology vendors — the Authorities will use this lens for third-party risk supervision.

TechnologyAll licencesRead on sfc.hk ↗

24 Jul

26EC43

NOTE

Circular on listed structured funds

The SFC sets out an updated framework and additional requirements for authorising listed structured funds — including leveraged and inverse (L&I) products and new Defined Outcome Listed Structured Funds — for public offering in Hong Kong. It incorporates and supersedes the SFC’s May 2020 L&I product circulars.

If you manage or plan to offer listed structured funds, review the new authorisation requirements before submitting products for SFC approval.

ProductsRead on sfc.hk ↗

23 Jul

26EC37

NOTE

Mutual Recognition of Funds (MRF) between Malaysia and Hong Kong

Under a new MoU with the Securities Commission Malaysia dated 23 July 2026, the SFC expands the mutual recognition of funds framework to Malaysian-domiciled funds, superseding the 2009 Islamic CIS arrangement. It sets out eligibility and compliance requirements for offering Malaysian Funds to Hong Kong retail investors.

Fund distributors should note that a broader range of Malaysian funds can now be authorised for public offering in Hong Kong under MRF.

ProductsRead on sfc.hk ↗

23 Jul

26EC38

NOTE

Cross-listings of Malaysian Real Estate Investment Trusts in Hong Kong

The SFC and the Securities Commission Malaysia signed an MoU dated 23 July 2026 expanding the mutual recognition of funds (MRF) framework to cover Malaysian REITs. The circular sets out the eligibility and ongoing requirements for authorising a Malaysian REIT for public offering in Hong Kong.

If you distribute or advise on REITs, note that eligible Malaysian REITs may now seek SFC authorisation for Hong Kong retail offering.

ProductsRead on sfc.hk ↗

21 Jul

26EC44

ACT

Circular to intermediaries Updates on HKEX’s post release tests for the launch of its backbone network upgrade for securities market systems

The SFC informs intermediaries of HKEX’s Post Release Tests for its securities-market backbone network upgrade. PRT 1 (8 August) and PRT 2 (22 August) are mandatory for Exchange Participants and China Connect Exchange Participants; PRT 3 (5 September) is optional. Other SFTP-using RRIs may participate voluntarily.

Exchange Participants must schedule staff and systems for the mandatory 8 and 22 August tests; other SFTP-connected firms should join to verify connectivity.

TechnologyConductRead on sfc.hk ↗

14 Jul

26EC39

FYI

Circular to Licensed Corporations, SFC-licensed Virtual Asset Service Providers and Associated Entities - Anti-Money Laundering / Counter-Financing of Terrorism (1) FATF Statement on High-Risk Jurisdictions subject to a Call for Action (2) FATF Statement on Jurisdictions under Increased Monitoring (3) Outcomes from the FATF Plenary, 17-19 June 2026

The SFC relays FATF's June 2026 statements on high-risk and increased-monitoring jurisdictions. FATF calls for countermeasures against the DPRK and Iran, and enhanced due diligence proportionate to risk for jurisdictions such as Myanmar.

Check client and transaction exposure to listed jurisdictions and apply enhanced due diligence or countermeasures as required.

AMLRead on sfc.hk ↗

13 Jul

26EC41

FYI

Circular to Intermediaries ─ Over-the-counter Derivatives Regulatory Regime – Industry Webinar

The SFC will host a Zoom industry webinar on 14 August 2026 on the upcoming OTC derivatives licensing regime, covering new and expanded regulated activities, planned legislative amendments, transitional licensing and FRR arrangements, other impacts and next steps. English, free, one CPT hour.

If you engage or plan to engage in OTCD activities, enrol staff by 27 July 2026 to understand the new regime.

OTC derivativesLicensingRead on sfc.hk ↗

10 Jul

26EC40

FYI

Circular to Licensed Corporations, SFC-licensed Virtual Asset Service Providers and Associated Entities - Cybersecurity Webinar

The SFC will host two Zoom cybersecurity webinar sessions on 30 July 2026 to raise awareness of AI-enabled cyberattacks and share its expectations, guidance and practical mitigation measures for licensed firms. Free, up to three representatives per firm.

Optional; enrol relevant management, compliance or IT staff (and vendors) by 24 July 2026.

TechnologyRead on sfc.hk ↗

9 Jul

26EC35

ACT

Circular to licensed corporations and SFC-licensed virtual asset service providers Implementing (i) robust authentication methods to reduce and mitigate hacking risks from phishing attacks and (ii) adequate monitoring and surveillance measures to identify suspicious activities

Following large-scale SMS phishing and man-in-the-middle attacks in 2025, the SFC expects internet brokers and VASPs to adopt phishing-resistant authentication and device binding, effective transaction monitoring and client notifications, prompt incident response and reporting, and enhanced client awareness of phishing risks.

If you offer internet trading, upgrade to phishing-resistant login and device binding and strengthen account surveillance and incident procedures.

TechnologyConductRead on sfc.hk ↗

JUNE 2026

3 circulars

23 Jun

26EC34

NOTE

Circular to intermediaries Updates on HKEX’s third optional market rehearsal for its backbone network upgrade for securities market systems

A third, optional HKEX market rehearsal will be held on 11 July 2026 to verify the system failover process over the enhanced backbone network. Relevant Regulated Intermediaries using the SFTP channel are strongly encouraged to participate.

Optional; if you are an Exchange Participant wanting the failover test, register via HKEX by 7 July 2026.

TechnologyRead on sfc.hk ↗

5 Jun

26EC33

NOTE

Circular on listed structured funds

The SFC sets additional requirements for authorising listed structured funds, notably Leveraged and Inverse Products and Defined Outcome Listed Structured Funds, supplementing UT Code 8.8. It incorporates and supersedes the SFC's 2020 L&I Products circulars, applying general requirements plus product-specific safeguards.

If you issue or advise on listed structured funds, review the new authorisation framework replacing the 2020 L&I circulars.

ProductsRead on sfc.hk ↗

2 Jun

26EC32

ACT

Circular to licensed corporations, SFC-licensed virtual asset service providers and associated entities Enhanced cybersecurity measures to address evolving risks arising from artificial intelligence-enabled cyberattacks

The SFC reminds licensed firms to review and enhance cybersecurity measures against AI-enabled cyberattacks, which can autonomously find and chain vulnerabilities and lower the barrier for threat actors. Senior management, including the MIC-IT, is ultimately responsible for reviewing and approving framework changes.

Have your MIC-IT assess preparedness for AI-enabled attacks, remediate vulnerabilities and document approval of cybersecurity enhancements.

TechnologyConductRead on sfc.hk ↗

MAY 2026

4 circulars

27 May

26EC26

NOTE

Circular on provision of Relevant Stablecoin service by virtual asset trading platforms and licensed corporations

The SFC sets expected standards for VATPs and LCs dealing in Relevant Stablecoins (specified stablecoins issued under an HKMA licence). Given HKMA oversight, the VATP Guidelines' liquidity and index requirements need not apply, but firms must disclose stabilisation and redemption mechanisms and assess client VA knowledge.

If you deal in HKMA-licensed stablecoins, note the relaxed liquidity/index treatment but maintain disclosure and client-knowledge assessments.

VAProductsRead on sfc.hk ↗

27 May

26EC31

NOTE

Circular on SFC-authorised funds with exposure to virtual assets

This revised circular sets requirements for authorising funds with over 10% NAV exposure to virtual assets, covering direct investment in spot VA tradable on licensed VATPs and indirect exposure via futures and exchange-traded products. It supersedes the 7 April 2025 circular and excludes Relevant Stablecoins and tokenised deposits.

If you manage SFC-authorised VA funds, review the revised requirements replacing the April 2025 circular.

VAProductsRead on sfc.hk ↗

22 May

26EC29

ACT

Circular to licensed corporations Expected controls for account opening and maintaining relationships with clients

A review of 12 securities brokers found significant deficiencies in account-opening due diligence and cross-border correspondent relationships, including acceptance of questionable or forged documents and missed red flags. The SFC sets expected standards and additional measures, with zero tolerance for forged documents and warnings of supervisory and enforcement action.

Run an internal look-back for forged documents, close affected accounts, and tighten CBCR and Mainland-client due diligence per Appendix A.

AMLConductRead on sfc.hk ↗

19 May

26EC28

ACT

Circular to intermediaries Updates on HKEX second market rehearsal for its backbone network upgrade for securities market systems

HKEX's second market rehearsal for its securities-systems backbone network upgrade will run on 30 May 2026 to validate connectivity by simulating daily operations. Participation is mandatory for Exchange Participants and China Connect EPs; other SFTP-channel intermediaries are strongly encouraged to take part.

Exchange Participants must join the mandatory second rehearsal on 30 May 2026; refer to HKEX's 19 May circular for logistics.

TechnologyRead on sfc.hk ↗

APRIL 2026

4 circulars

20 Apr

26EC22

NOTE

Circular on tokenisation of SFC-authorised investment products

The SFC sets out requirements allowing tokenisation of SFC-authorised investment products for public offering, adopting a see-through approach: primary dealing of tokenised products is permitted where the underlying product meets all authorisation requirements plus additional safeguards for tokenisation risks.

Relevant only if you provide or distribute tokenised authorised products; check the tokenisation safeguards before offering them.

VAProductsRead on sfc.hk ↗

20 Apr

26EC23

NOTE

Circular on secondary trading of tokenised SFC-authorised investment products

The SFC now permits secondary trading of tokenised SFC-authorised products (principally open-ended funds) via on-platform trading on licensed VATPs, setting requirements covering the trading channel, fair pricing, liquidity provision, disclosure and client onboarding. Read with the other Tokenisation Circulars.

Only relevant if you operate or distribute via a VATP; review the trading, pricing and disclosure conditions.

VAProductsRead on sfc.hk ↗

15 Apr

26EC19

FYI

No change to the financial services providers list – the clearing and record keeping rules under the OTC derivatives regulatory regime

The SFC and HKMA completed their joint annual review of the financial services providers (FSP) list under the OTC derivatives clearing rules and propose no changes. The current FSP List effective 1 January 2026 remains in force until further notice.

No action; the FSP List is unchanged for OTC derivatives clearing obligations.

OTC derivativesRead on sfc.hk ↗

9 Apr

26EC18

NOTE

Circular to Licensed Corporations which are Participants of The Stock Exchange of Hong Kong Limited or Hong Kong Futures Exchange Limited - Licence Holders Insurance Scheme for Exchange Participants

The SFC sets out the licence holders insurance scheme for SEHK and HKFE Exchange Participants for the 2026/2027 scheme year. Marsh is reappointed as broker and administrator; master policies covering fidelity risks carry a $15 million indemnity limit per activity and $3 million deductible per claim.

If you are an Exchange Participant, review the insurance documents Marsh distributes separately to confirm your cover.

Type 1Read on sfc.hk ↗

MARCH 2026

4 circulars

23 Mar

26EC15

ACT

Circular to intermediaries Updates on HKEX market rehearsals for its backbone network upgrade for securities market systems

HKEX will run two mandatory market rehearsals in Q2 2026 for its securities-systems backbone network upgrade, with further rehearsals to follow. Relevant Regulated Intermediaries using the SFTP channel for BCAN-CID and reporting submissions are invited to participate; the rehearsals are mandatory for Exchange Participants and China Connect EPs.

Exchange Participants must submit the Notification Form by 27 March 2026; non-EPs are encouraged to join for readiness.

TechnologyRead on sfc.hk ↗

16 Mar

26EC14

NOTE

Circular to Licensed Corporations - Documentation Updates for OTC Derivatives Trade Reporting

The SFC reminds LCs of HKMA updates to the HKTR trade repository Reference Manual, covering ISO 20022 data archiving and a revised Sunday maintenance/outage window (12:00pm Sunday to 00:30am Monday) effective 16 March 2026. Weekday and Saturday hours are unchanged.

If subject to OTC derivatives mandatory reporting, note the revised Sunday outage window and review the updated Reference Manual.

OTC derivativesTechnologyRead on sfc.hk ↗

13 Mar

26EC13

FYI

Circular to Licensed Corporations, SFC-licensed Virtual Asset Service Providers and Associated Entities - Anti-Money Laundering / Counter-Financing of Terrorism (1) FATF Statement on High-Risk Jurisdictions subject to a Call for Action (2) FATF Statement on Jurisdictions under Increased Monitoring (3) Outcomes from the FATF Plenary, 11-13 February 2026

The SFC relays FATF's February 2026 statements on high-risk and increased-monitoring jurisdictions. FATF calls for countermeasures against the DPRK and Iran, and enhanced due diligence proportionate to risk for jurisdictions such as Myanmar.

Check client and transaction exposure to listed jurisdictions and apply enhanced due diligence or countermeasures as required.

AMLRead on sfc.hk ↗

5 Mar

26EC11

FYI

Joint Circular on the Expansion of Generative Artificial Intelligence Sandbox

The HKMA, SFC, IA and MPFA jointly invite regulatees to apply for the expanded GenA.I. Sandbox++, extending the banking-sector sandbox to securities, asset and wealth management, insurance, MPF and stored value sectors. Participants get complimentary Cyberport GPU access and supervisory guidance.

Optional; apply through Cyberport if you want a supervised environment to test generative-AI solutions.

TechnologyRead on sfc.hk ↗

FEBRUARY 2026

4 circulars

26 Feb

26EC9

NOTE

Circular to intermediaries HKEX market rehearsals for its backbone network upgrade for securities market systems

The SFC informs intermediaries that HKEX will upgrade its securities-systems backbone network by Q3 2026 and run a series of market rehearsals between Q2 and early Q3 to validate connectivity, including the SFTP channel used for BCAN-CID and reporting submissions. Schedule details to follow.

Rehearsals are mandatory for Exchange Participants; watch for the schedule and prepare your file-submission processes.

TechnologyRead on sfc.hk ↗

11 Feb

26EC5

NOTE

Circular on licensed corporations providing virtual asset dealing services (1) to offer financing for virtual asset dealing and access to shared order book, and (2) to safeguard client virtual assets relating to withdrawals

The SFC sets a framework letting VA brokers under omnibus arrangements offer VA financing to their securities-margin clients, supported by sufficient securities and limited VA collateral. It also sets standards for shared order books and client VA safeguards where withdrawals are permitted.

If you are a VA broker, review the eligibility, collateral and client-asset safeguard conditions before offering VA financing.

VAClient assetsRead on sfc.hk ↗

11 Feb

26EC6

NOTE

Circular on permitting virtual asset trading platform operators to accept affiliated market makers

The SFC will allow licensed VATP operators to permit an affiliated company to conduct market making on their platform, subject to safeguards: functional independence, conflict-of-interest policies, a designated RO/MIC, information barriers, client-order priority and post-trade identification of affiliated trades.

If you operate a VATP, implement the conflict-of-interest controls before allowing an affiliated market maker.

VAConductRead on sfc.hk ↗

11 Feb

26EC7

ACT

Circular to Licensed Corporations Engaged in Asset and Wealth Management Activities - Asset and Wealth Management Activities Survey 2025

The SFC has launched its annual Asset and Wealth Management Activities Survey 2025. LCs with gross operating income from asset management, fund/portfolio advice or private wealth management must complete the full online questionnaire; firms with no such activity complete only the General Information section.

Complete the AWMAS questionnaire online by 22 April 2026; file the General Information section if you had no in-scope activity.

Type 9Read on sfc.hk ↗

JANUARY 2026

4 circulars

30 Jan

26EC4

NOTE

Circular to licensed corporations carrying out sponsor work

Amid a surge in listing applications, the SFC and SEHK flag declining quality of draft listing documents and substandard sponsor conduct, including over-reliance on experts, inadequate Principal supervision and insufficiently experienced staff. Sponsors are reminded of their gatekeeping obligations and will be held accountable.

If you carry out sponsor work, critically assess applicant readiness and your own resources before accepting new mandates.

ConductRead on sfc.hk ↗

29 Jan

26EC3

NOTE

Circular to licensed corporations Reminder of statutory obligations during SFC inspections to comply with section 180 of the Securities and Futures Ordinance (SFO)

The SFC reminds LCs to fully cooperate with inspections under section 180 of the SFO, having observed unsatisfactory practices that obstructed supervision. Obligations include giving access to records, maintaining and promptly retrieving records, ensuring RO availability, remaining fit and proper, and accountability for external representatives. Breaches risk supervisory and enforcement action.

Ensure records are readily retrievable and ROs available for inspection; cooperation failures can trigger licence conditions or enforcement.

ConductAll licencesRead on sfc.hk ↗

26 Jan

26EC2

ACT

Circular to Licensed Corporations, SFC-licensed Virtual Asset Service Providers and Associated Entities - Anti-Money Laundering / Counter-Financing of Terrorism Transition to the new suspicious transaction reporting platform

The JFIU's new STREAMS 2 platform replaces STREAMS as the only channel for filing suspicious transaction reports from 2 February 2026. Firms must register STREAMS 2 accounts and can file via XML, PDF upload or web form. A STREAMS blackout runs from 28 January to 2 February 2026.

AMLTechnologyRead on sfc.hk ↗

9 Jan

26EC1

FYI

Circular to Licensed Corporations Broker Forum

The SFC will host a broker forum on 2 February 2026 to share supervisory observations and regulatory updates for the securities industry. Conducted in Cantonese, free of charge, with 1.5 CPT hours; each LC may nominate one representative, allocated first-come, first-served.

Optional; enrol one representative by 16 January 2026 if you want the update and 1.5 CPT hours.

Type 1Read on sfc.hk ↗

DECEMBER 2025

3 circulars

22 Dec

25EC71

NOTE

Circular to licensed corporations - Exemption for non-centrally cleared equity options from margin requirements

The SFC will exempt non-centrally cleared single-stock, equity basket and equity index options from its margin requirements from 4 January 2026 until further notice, aligning with EU and UK approaches. The margin rules were originally scheduled to take effect that date.

If you trade equity options, no margin action needed from 4 January 2026; watch for the Code of Conduct amendment to be gazetted.

OTC derivativesRead on sfc.hk ↗

12 Dec

25EC70

NOTE

Circular in relation to the clearing and record keeping rules for the OTC derivatives regime – changes to the list of persons designated as financial services providers

The revised list of persons designated as financial services providers under the OTC derivatives Clearing Rules is gazetted today and takes effect on 1 January 2026. Licensed persons whose average OTC derivatives position reaches the USD 20 billion clearing threshold must centrally clear relevant transactions, including those with FSPs.

Only relevant if your OTC derivatives book approaches USD 20 billion; most small firms are below the clearing threshold and need no action.

OTC derivativesRead on sfc.hk ↗

5 Dec

25EC68

ACT

Circular to intermediaries SFC and HKMA joint product survey 2025

The SFC and HKMA are launching the 2025 joint survey on sales of non-exchange-traded investment products by Type 1 and Type 4 intermediaries, covering 2025. Submissions via WINGS are due 16 January 2026 (Part A), 27 February 2026 (Parts A-B) and 6 March 2026 (Parts A-C).

Diarise your WINGS submission date; all Type 1/Type 4 firms must at least file Part A by 16 January 2026.

ProductsType 1Type 4Read on sfc.hk ↗

NOVEMBER 2025

8 circulars

28 Nov

25EC66

NOTE

Circular to management companies of SFC-authorised unit trusts and mutual funds - Updated streamlined measures on post-authorisation matters for SFC-authorised UCITS funds

The SFC has further streamlined post-authorisation processing for SFC-authorised UCITS funds, effective 28 November 2025. It removes prior-approval requirements for changing depositaries and investment delegates and for material changes to investment objectives, policies and restrictions that comply with the home jurisdiction, and aligns notification requirements with home rules.

UCITS fund managers gain faster processing; the SFC still post-vets changes, so keep filings accurate and compliant with home-jurisdiction requirements.

ProductsRead on sfc.hk ↗

27 Nov

25EC67

FYI

Circular to Licensed Corporations, SFC-licensed Virtual Asset Service Providers and Associated Entities - Anti-Money Laundering / Counter-Financing of Terrorism Webinar Materials

Presentation materials from the SFC and Police Financial Intelligence and Investigation Bureau AML/CFT webinar held on 17-18 November 2025 are now available on the SFC website under training materials. Licensed firms and VASPs are encouraged to use them for internal training.

Download the materials for staff AML training; a useful resource, but no filing or action required.

AMLRead on sfc.hk ↗

17 Nov

25EC62

ACT

Circular to Licensed Corporations, SFC-licensed Virtual Asset Service Providers and Associated Entities - Anti-Money Laundering / Counter-Financing of Terrorism Detection and prevention of potential layering activities in money laundering

The SFC has observed illicit actors using licensed firms and virtual asset platforms for money-laundering layering, via frequent swift deposits and withdrawals not used for trading, including signs of smurfing. The circular sets out red flags and reiterates senior management's AML/CFT responsibilities to detect and prevent such activities.

Review your transaction monitoring for rapid in-out fund flows and smurfing; ensure ROs, MLRO and MICs can evidence these controls.

AMLVARead on sfc.hk ↗

13 Nov

25EC60

NOTE

Circular to licensed corporations Implementation Arrangements for Cross-Boundary Wealth Management Connect Pilot Scheme

The SFC introduces enhancements to the Cross-Boundary Wealth Management Connect Pilot Scheme. Participating LCs can obtain Southbound clients' one-off written consent, valid up to one year, to introduce and explain products, and Partner Brokers may set up three-party dialogues. Reciprocal arrangements apply to the Northbound Scheme.

Only affects LCs in the Cross-Boundary WMC; participants can rely on annual one-off client consent instead of per-transaction requests.

ConductProductsRead on sfc.hk ↗

12 Nov

25EC61

FYI

Circular to Licensed Corporations, SFC-licensed Virtual Asset Service Providers and Associated Entities - Anti-Money Laundering / Counter-Financing of Terrorism (1) FATF Statement on High-Risk Jurisdictions subject to a Call for Action (2) FATF Statement on Jurisdictions under Increased Monitoring (3) Outcomes from the FATF Plenary, 22-24 October 2025

The SFC relays the FATF's 24 October 2025 statements on high-risk jurisdictions subject to a call for action (countermeasures for DPRK and Iran, enhanced due diligence for Myanmar), jurisdictions under increased monitoring, and outcomes of the October 2025 FATF Plenary.

Update your high-risk jurisdiction lists and EDD/countermeasure triggers to reflect the latest FATF designations.

AMLRead on sfc.hk ↗

7 Nov

25EC58

NOTE

Circular to licensed corporations ─ SFC consultation on the Chinese version of the draft financial resources rule amendments

The SFC launched a public consultation on the Chinese version of the draft amendments to the Securities and Futures (Financial Resources) Rules. This corresponds to the English draft published on 14 July 2025. Written comments are due by 6 February 2026.

No action unless you want to comment; the Chinese draft mirrors the English FRR amendments, comments close 6 February 2026.

FRRRead on sfc.hk ↗

3 Nov

25EC56

NOTE

Circular on shared liquidity by virtual asset trading platforms

The SFC sets out its regulatory approach for SFC-licensed virtual asset trading platforms to integrate order books with global affiliate platforms into a shared liquidity pool. Eligible affiliates must be in FATF-aligned jurisdictions. The circular addresses new settlement and market-surveillance risks and requires operators to implement specified safeguards.

VATP-specific; operators wanting shared order books must manage cross-border settlement exposure and market-abuse surveillance under the stated requirements.

VARead on sfc.hk ↗

3 Nov

25EC57

NOTE

Circular on expansion of products and services of virtual asset trading platforms

The SFC broadens products and services SFC-licensed virtual asset trading platforms may offer. It removes the 12-month track record requirement for professional-investor offerings and for stablecoins issued by licensed issuers, clarifies distribution of tokenised securities and digital asset-related products, and updates client custody requirements. Retail track-record rules for other virtual assets remain.

Relevant to VATPs; platforms can expand offerings but must still perform due diligence and disclose short track records to professional investors.

VAProductsRead on sfc.hk ↗

OCTOBER 2025

2 circulars

17 Oct

25EC53

FYI

Circular to Licensed Corporations, SFC-licensed Virtual Asset Service Providers and Associated Entities - Anti-Money Laundering / Counter-Financing of Terrorism Anti-Money Laundering and Counter-Financing of Terrorism Webinar

The SFC will host two AML/CFT webinar sessions on 17 and 18 November 2025 via Zoom, covering the scam landscape, regulatory updates, supervisory observations, money-laundering typologies and the new STREAMS 2 reporting system. Enrolment is via the online form by 31 October 2025, maximum two representatives per firm.

Enrol one form per firm by 31 October 2025; three CPT hours offered for attending the full session.

AMLRead on sfc.hk ↗

13 Oct

25EC51

NOTE

Circular to Management Companies of SFC-authorised Real Estate Investment Trusts - Streamlined documentary requirements for secondary offerings

The SFC sets out streamlined content requirements for secondary offering documents by SFC-authorised REITs, effective immediately. REITs may adopt the same content requirements as listed companies under the Listing Rules, with modifications, while specified REIT Code disclosures still apply, to improve time-to-market for fund-raising.

Relevant to REIT managers; secondary offering documents can be more succinct for rights issues and open offers. Updated REIT FAQs give guidance.

ProductsRead on sfc.hk ↗

SEPTEMBER 2025

3 circulars

30 Sept

25EC50

NOTE

Supplemental joint circular on intermediaries' virtual asset-related activities

Supplemental to the December 2023 joint SFC-HKMA circular on intermediaries' virtual asset-related activities, this circular refines and relaxes requirements and updates licensing conditions and terms and conditions. Notably, intermediaries may now provide staking services to clients through segregated accounts with an SFC-licensed platform or authorized financial institution.

If you deal in or advise on virtual assets, review the updated terms and conditions; staking to clients is now permitted subject to conditions.

VALicensingRead on sfc.hk ↗

29 Sept

25EC48

NOTE

Joint circular to intermediaries Concurrent SFC-HKMA thematic review of the distribution of non-exchange traded investment products

The SFC and HKMA will start a concurrent thematic review of intermediaries' distribution of non-exchange traded investment products, focusing on collective investment schemes after CIS sales rose 76% year-on-year. The review examines policies, systems, controls and management oversight, and compliance with the suitability requirement.

If you distribute CIS, expect scrutiny; check your product due diligence, suitability assessments and client disclosures are documented and defensible.

ProductsConductRead on sfc.hk ↗

18 Sept

25EC46

NOTE

Mutual Recognition of Funds (MRF) between the United Arab Emirates (UAE) and Hong Kong (Note: The Securities and Commodities Authority as referred to in this circular has been renamed as the Capital Market Authority)

The SFC and the UAE Securities and Commodities Authority (now the Capital Market Authority) signed a memorandum of understanding on 17 September 2025 establishing mutual recognition of funds. Eligible UAE-domiciled funds may seek SFC authorisation for public offering in Hong Kong, subject to the circular's eligibility and ongoing requirements.

Informational for most firms; opens a new channel for UAE funds to be authorised and distributed to Hong Kong retail investors.

ProductsRead on sfc.hk ↗

AUGUST 2025

2 circulars

15 Aug

25EC44

NOTE

Circular to licensed virtual asset trading platform operators on custody of virtual assets

The SFC elaborates its expected standards for safe custody of client virtual assets by SFC-licensed platform operators, following overseas platform cyber incidents involving wallet vulnerabilities. It sets minimum requirements and good-practice examples covering wallet infrastructure, access controls, transaction verification, third-party management and threat monitoring, taking a technology-neutral, outcome-based approach.

VATP-specific; platform operators must meet the minimum custody controls and can benchmark against the good practices for wallet and transaction security.

VAClient assetsRead on sfc.hk ↗

11 Aug

25EC43

ACT

Circular to Licensed Corporations - Updated Technical Specifications for OTC Derivatives Trade Reporting

The SFC reminds licensed corporations of the HKMA's 8 August notice on updated technical specifications for OTC derivatives trade reporting to the Hong Kong Trade Repository. The specifications take effect on 22 September 2025, ahead of the 29 September 2025 implementation of Unique Transaction Identifier, Unique Product Identifier and Critical Data Elements reporting.

If you report OTC derivatives to the HKTR, update systems to the new specifications by 22 September 2025 and test with the HKTR.

OTC derivativesRead on sfc.hk ↗

JULY 2025

2 circulars

15 Jul

25EC41

NOTE

Circular on enhanced facilitative measure for visiting professionals

The SFC enhances its facilitative measure for visiting professionals, extending the period itinerant professionals may conduct regulated activities or provide virtual asset services in Hong Kong from 30 to 45 days each calendar year. Other requirements are unchanged, and the new condition applies to existing licensed ITPs.

If you sponsor itinerant professionals from overseas group companies, they can now work up to 45 days per year; the SFC will update conditions.

LicensingRead on sfc.hk ↗

14 Jul

25EC40

NOTE

Circular to licensed corporations - SFC consultation on changes to financial resources rules and related guidelines to foster market developments for OTC derivatives and other products

The SFC published a consultation on draft amendments to the Securities and Futures (Financial Resources) Rules and related guidelines, implementing capital requirements for licensed corporations engaging in OTC derivative activities and other market-development changes, and concluding on certain 2017 FRR proposals. Written comments are due by 13 October 2025.

If you engage in OTC derivative activities, review the proposed capital rules and comment by 13 October 2025.

FRROTC derivativesRead on sfc.hk ↗

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