Hong Kong is moving towards a new licensing / registration regime for virtual asset (VA) custodian service providers under the Anti Money Laundering and Counter Terrorist Financing Ordinance (Cap. 615) (AMLO), with a Bill expected to be introduced into the legislature in 2026.
For firms that may be in scope, the direction of travel is clear: stronger expectations around governance, financial resources, safeguarding controls and independent assurance.
Applicants are expected to obtain an independent external assessment covering areas such as wallet structure, private key governance, withdrawals, reconciliation and monitoring.
Read our flyer for a summary and practical readiness considerations.
