Hong Kong has emerged as Asia's leading digital asset hub, with a comprehensive regulatory framework overseen by the Securities and Futures Commission (SFC). Alan Wong LLP advises asset managers, financial institutions, fintech companies, and businesses engaging with Hong Kong's digital asset ecosystem on the full range of digital asset regulatory and transactional matters.
Our practice spans VASP licensing under Hong Kong's anti-money laundering regime, tokenisation of real-world assets (RWAs), SFC-regulated digital asset funds, and the structuring of digital asset investment products. We combine deep knowledge of Hong Kong's evolving regulatory landscape with practical transaction experience to provide commercially focused advice to clients operating in this space.
Digital Assets Legal Services in Hong Kong
Hong Kong has emerged as Asia's leading digital asset hub, with a comprehensive regulatory framework overseen by the Securities and Futures Commission (SFC). Alan Wong LLP advises cryptocurrency exchanges, virtual asset service providers (VASPs), asset managers, and investors on the full range of digital asset regulatory and transactional matters.
Our practice spans VASP licensing under Hong Kong's anti-money laundering regime, tokenisation of real-world assets (RWAs), SFC-regulated digital asset funds, and the structuring of digital asset investment products. We combine deep knowledge of Hong Kong's evolving regulatory landscape with practical transaction experience to provide commercially focused advice to clients operating in this space.
/ WHO WE ADVISE
Who this is for
Crypto exchanges
VASP licence applications; SFC compliance and AML/CFT programme design.
Token issuers
Token offerings, legal opinions, and Hong Kong securities law navigation.
RWA tokenisation
Tokenising real estate, funds, bonds, or commodities under Hong Kong law.
Digital asset funds
OFCs or LPFs with digital asset strategies; SFC Type 9 licensing.
Web3 startups
Legal structuring, token design, and regulatory strategy for DeFi and Web3.
Institutional investors
Digital assets, tokenised securities, or funds with digital asset exposure.
/ PRACTICE AREAS
01 — VASP Licensing
Under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), any operator of a centralised virtual asset exchange conducting business in or targeting clients in Hong Kong must be licensed by the SFC. Alan Wong LLP advises clients on the VASP licensing framework - including businesses that interact with licensed platforms, broker-dealers assessing their regulatory obligations, and entities evaluating whether their operations trigger licensing requirements. We advise on AML/CFT programme requirements, governance frameworks, risk management policies, and the compliance obligations applicable to businesses operating in Hong Kong's virtual asset regulatory environment.
Tokenisation of real-world assets - including real estate, private equity interests, bonds, and commodities - is one of the fastest-growing areas of financial innovation in Hong Kong. Alan Wong LLP advises issuers, platforms, and investors on the legal framework applicable to RWA tokenisation, covering classification of tokenised instruments under Hong Kong securities law, SFC authorisation requirements, token issuance structure, smart contract legal considerations, custody and transfer of digital securities, and cross-border distribution of tokenised products.
Hong Kong now permits SFC-authorised funds to invest in digital assets, and both the open-ended fund company (OFC) and limited partnership fund (LPF) structures have been used for digital asset strategies. Alan Wong LLP advises fund managers and sponsors on establishing digital asset funds in Hong Kong, including SFC Type 9 licensing for discretionary asset management of virtual assets. We advise on portfolio manager qualification requirements, risk management frameworks, fund constitutional documents, investor disclosure requirements, and the intersection of fund law and digital asset regulation.
Alan Wong LLP is at the forefront of digital asset legal practice in Hong Kong. Contact us to discuss your regulatory or transactional requirements.
/ PRACTICE AREAS
01
VASP Licensing
Under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), any operator of a centralised virtual asset exchange conducting business in or targeting clients in Hong Kong must be licensed by the SFC. Alan Wong LLP advises clients on the VASP licensing framework — including businesses that interact with licensed platforms, broker-dealers assessing their regulatory obligations, and entities evaluating whether their operations trigger licensing requirements. We advise on AML/CFT programme requirements, governance frameworks, risk management policies, and the compliance obligations applicable to businesses operating in Hong Kong's virtual asset regulatory environment.
Tokenisation of real-world assets — including real estate, private equity interests, bonds, and commodities — is one of the fastest-growing areas of financial innovation in Hong Kong. Alan Wong LLP advises issuers, platforms, and investors on the legal framework applicable to RWA tokenisation, covering classification of tokenised instruments under Hong Kong securities law, SFC authorisation requirements, token issuance structure, smart contract legal considerations, custody and transfer of digital securities, and cross-border distribution of tokenised products.
Hong Kong now permits SFC-authorised funds to invest in digital assets, and both the open-ended fund company (OFC) and limited partnership fund (LPF) structures have been used for digital asset strategies. Alan Wong LLP advises fund managers and sponsors on establishing digital asset funds in Hong Kong, including SFC Type 9 licensing for discretionary asset management of virtual assets. We advise on portfolio manager qualification requirements, risk management frameworks, fund constitutional documents, investor disclosure requirements, and the intersection of fund law and digital asset regulation.
Alan Wong LLP is at the forefront of digital asset legal practice in Hong Kong. Contact us to discuss your regulatory or transactional requirements.
/ FAQ
Frequently asked questions
Under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), any person operating a centralised virtual asset exchange in Hong Kong — or actively marketing to Hong Kong investors — must hold a VASP licence issued by the Securities and Futures Commission (SFC). Requirements cover exchange operations, AML/CFT programme design, governance, and custody of client assets.
The SFC licensing process is rigorous and typically takes 6 to 18 months from submission, depending on the completeness of your application and the complexity of your operations. Early legal preparation — including your AML/CFT programme, internal compliance framework, and governance documentation — is critical to avoiding delays and queries from the regulator.
It depends on the structure and rights attached to the token. Tokens that confer profit participation, governance rights, or economic interests may constitute "securities" under the Securities and Futures Ordinance (SFO), triggering prospectus, licensing, and disclosure obligations. A legal opinion on token classification is essential before any offering is launched, particularly where tokens are to be sold to Hong Kong investors.
RWA tokenisation involves representing ownership or economic rights in physical or financial assets — such as real estate, funds, bonds, or private credit — on a blockchain. In Hong Kong, these structures typically use special purpose vehicles (SPVs) or trust arrangements to hold the underlying asset, with the token representing a beneficial or contractual interest. Legal structuring must address securities laws, property law, and the rights of token holders.
A Hong Kong-based manager of a fund investing in virtual assets typically requires a Type 9 (Asset Management) licence from the SFC. If the fund's assets include tokens classified as securities, additional licensing conditions apply. The fund vehicle itself — commonly an Open-Ended Fund Company (OFC) or Limited Partnership Fund (LPF) — must also be properly established and registered in Hong Kong.
Not necessarily. The SFC applies a substance-over-form approach to determine whether activities constitute regulated activities under Hong Kong law. Projects offering trading, lending, yield products, or governance tokens to Hong Kong users may trigger licensing or disclosure obligations regardless of how decentralised the underlying infrastructure is. Early legal advice can prevent costly restructuring later.
/ GET IN TOUCH
Working with Digital Assets in Hong Kong?
Whether you are applying for a VASP licence, structuring an RWA tokenisation, or setting up a digital asset fund - we can help you navigate Hong Kong's regulatory framework.
Hong Kong has emerged as Asia's leading digital asset hub, with a comprehensive regulatory framework overseen by the Securities and Futures Commission (SFC). Alan Wong LLP advises cryptocurrency exchanges, virtual asset service providers (VASPs), asset managers, and investors on the full range of digital asset regulatory and transactional matters.
Our practice spans VASP licensing under Hong Kong's anti-money laundering regime, tokenisation of real-world assets (RWAs), SFC-regulated digital asset funds, and the structuring of digital asset investment products. We combine deep knowledge of Hong Kong's evolving regulatory landscape with practical transaction experience to provide commercially focused advice to clients operating in this space.
VASP Licensing in Hong Kong
Under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, all centralised virtual asset exchange operators conducting business in or targeting clients in Hong Kong must be licensed by the SFC. The licensing regime applies to platforms offering trading in virtual assets, including cryptocurrencies and tokenised securities.
Alan Wong LLP advises applicants on the full VASP licensing process - from initial regulatory readiness assessments and corporate structuring through to the preparation of licence applications and responses to SFC queries. We assist with the design and implementation of AML/CFT compliance programmes, governance frameworks, risk management policies, and the ongoing compliance obligations that licensed VASPs must maintain.
Tokenisation of real-world assets - including real estate, private equity interests, bonds, and commodities - is one of the fastest-growing areas of financial innovation in Hong Kong. Alan Wong LLP advises issuers, platforms, and investors on the legal and regulatory framework applicable to RWA tokenisation.
Our advice covers the classification of tokenised instruments under Hong Kong securities law, the applicable SFC authorisation requirements, the structuring of token issuance arrangements, smart contract legal considerations, and the custody and transfer of digital securities. We also advise on cross-border distribution of tokenised products and the interaction between Hong Kong law and other offshore regimes including the Cayman Islands and BVI.
Hong Kong now permits SFC-authorised funds to invest in digital assets, and both the open-ended fund company (OFC) and limited partnership fund (LPF) structures have been used for digital asset strategies. Alan Wong LLP advises fund managers and sponsors on establishing digital asset funds in Hong Kong, including SFC Type 9 licensing for discretionary asset management of virtual assets.
We advise on portfolio manager qualification requirements, risk management frameworks applicable to digital asset funds, fund constitutional documents, and investor disclosure requirements. For managers seeking to offer tokenised fund interests or establish on-chain fund structures, we provide advice on the intersection of fund law and digital asset regulation.
Alan Wong LLP is at the forefront of digital asset legal practice in Hong Kong. Contact us to discuss your regulatory or transactional requirements.
Message Sent! 信息已發送！ 信息已发送！
Thank you for your enquiry. We will get back to you within 1-2 business days. 感謝您的查詢。我們會在1-2工作天內回覆您。 感谢您的查询。我们会在1-2工作天内回复您。
Sending the message is not currently possible. Instead, please contact us by email or phone. 暫時不能發送信息。請以電郵或電話聯繫我們。 暂时不能发送信息。请以电邮或电话联系我们。
