ASPIRATION: SFC's New Roadmap for Virtual Assets
Background
On 19 February 2025, the Securities and Futures Commission ("SFC") unveiled a regulatory roadmap for Hong Kong's virtual asset ("VA") market with new initiatives under five pillars, namely, Access, Safeguards, Products, Infrastructure, and Relationships ("A-S-P-I-Re Roadmap"), to embrace the remarkable opportunities and the considerable challenges in face of the rapid evolution in the global VA market.
This A-S-P-I-Re Roadmap was launched against the backdrop that the global virtual asset market had been valued at over US$3 trillion in 2024 and emerged as a transformative force in finance, with annual trading volumes exceeding US$70 trillion. Institutional dominance coexists with retail speculation, liquidity is fragmented across centralized (CEXs) and decentralized (DEXs) exchanges, and regulatory divergence across jurisdictions—from Hong Kong’s investor-centric framework and the EU’s harmonised MiCA rules to the U.S. fragmented oversight—fuelling compliance challenges and arbitrage risks.
This alert outlines the SFC’s new regulatory blueprint for regulating the VAs in Hong Kong.
The A-S-P-I-Re Roadmap
There are 12 initiatives under the five pillars of the A-S-P-Re Roadmap, engineered to operate collaboratively to bolster the security, innovation, and growth of Hong Kong’s VA market.
It is worth noting that the SFC has not provided a specific timeline for the implementation of each initiative. However, we anticipate that progress on the licensing regimes for OTC trading and custody services is likely to advance more quickly, as these initiatives have been previously signposted and are not entirely new concepts.
Conclusion
The A-S-P-I-Re Roadmap represents the SFC’s forward-looking commitment to addressing the most pressing challenges in Hong Kong’s VA market in a pragmatic manner. We believe these proactive initiatives will not only enhance Hong Kong's attractiveness but also align with the growing demand for diverse VA financial products and strategies among experienced VA market players, helping the growth of Hong Kong's VA ecosystem. A wealth of new opportunities awaits VA market players seeking innovative investment solutions.
How Howse Williams Regulatory Team Can Help
At Howse Williams, our dedicated Regulatory team specialises in providing comprehensive legal services related to VAs in Hong Kong. Our expertise includes a deep understanding of both current and developing regulatory frameworks and significant experience in both contentious and non-contentious matters. As Hong Kong's VA landscape evolves with the SFC's A-S-P-I-Re Roadmap, we are uniquely positioned to guide our clients through this dynamic environment with strategic guidance on compliance, licensing, and innovative investment options.
We invite you to connect with us to discuss how we can assist you in leveraging these developments to achieve your business goals in the VA space.
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