Hong Kong runs a two-track licensing model for virtual assets: the Securities and Futures Ordinance (SFO) for tokens that are "securities", and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) Schedule 3B for non-security VAs. Stablecoin issuers sit in their own statute under the HKMA. This site walks through what needs a licence, what doesn't, and what an STO actually is.
The two-track model (SFO + AMLO), plus the HKMA stablecoin regime. Who regulates what, and how the pieces fit together.
Read framework ->Ten concrete examples that need a licence and ten that generally do not - exchanges, OTC desks, miners, merchants, developers, gamers, and more.
See examples ->A decision tree: security tokens vs. non-security tokens, agent vs. principal, referral vs. full intermediation, retail vs. PI-only.
Walk the decision tree ->What an STO is under HK law, what is and isn't a security token, and the SFC's "substance over form" test - with worked examples.
Read about STOs ->VATP, SFO Type 1 / 4 / 7 / 9, HKMA Stablecoin Issuer, the proposed VA dealer / custodian / adviser regimes, fees, capital, timelines.
See requirements ->Up to HK$5,000,000 fine and 7 years' imprisonment for unlicensed dealing in securities or unlicensed VA service. Personal liability extends to ROs and directors.
See penalties ->If a token is a "security" (e.g. tokenised bond, fund unit, profit-sharing instrument), the SFO regime applies in full - prospectus rules, Type 1 dealing, Type 7 ATS, Type 9 fund management. If a token is a non-security VA (BTC, ETH, most major L1/L2 tokens), AMLO Schedule 3B applies and only an SFC-licensed VATP may operate as a HK exchange. Fiat-referenced stablecoins are a third regime, licensed by the HKMA under the Stablecoins Ordinance (Cap. 656). New regimes for OTC dealers, custodians, advisers and asset managers of non-security VAs are scheduled for 2026.