/ DIGITAL ASSETS & WEB3

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 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.

/ 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.

→ Read our guide: VASP Licensing in Hong Kong 2026

02 — RWA Tokenisation

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.

→ Read our article: RWA Tokenisation — Hong Kong Legal Framework

03 — Digital Asset Funds

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.

→ Read our guide: VASP Licensing in Hong Kong 2026

02

RWA Tokenisation

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.

→ Read our article: RWA Tokenisation — Hong Kong Legal Framework

03

Digital Asset Funds

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.

/ 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.

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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.

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.

→ Read our guide: VASP Licensing in Hong Kong 2026

Real-World Asset (RWA) Tokenisation

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.

→ Read our article: RWA Tokenisation — Hong Kong Legal Framework

Digital Asset Investment Funds

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.

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