Exploring HK's Crypto Regulatory Ecosystem


In October 2022, the Hong Kong government announced its plan to promote the city as an international blockchain hub, stating that it will establish favorable policies for companies to set up businesses in the region.

At the same time, Hong Kong’s Securities and Futures Commission (SFC) announced a regime for crypto futures ETFs, giving retail investors indirect access to digital assets trading.1

Re-emphasizing the city’s desire to set their mark as a premier digital assets destination, the SFC announced proposed legislation requiring all centralized digital assets trading platforms to be licensed with a regulatory body, which would allow all types of investors, including retail investors, to participate.2

These announcements have started a ripple effect in the industry, causing both incumbents and newcomers to take advantage of these new opportunities.

Shortly after the proposed regulation was announced, OKX quickly announced that it has set up an HK entity and will apply for an HK Virtual Assets Service Provider (VASP license).3

The top-ranking exchange reaffirmed their desire to establish a strong local presence by sponsoring two industry-related conferences - Web3 Festival and WOW Summit - in the city earlier this year.

The new VASP licensing regime took place on June 1st.

While some have been eagerly awaiting to explore the opportunities that come with the new regulation, others have been skeptical, opting to take a ‘wait-and-see’ approach before planning their next steps.

Local Institutional Support

Hong Kong established the Web3 Institute last month to supplement its regulatory efforts in the space.

It aims to:

  • Gather Web3.0-related companies and professionals

  • Improve Web3.0 technology and applications

  • Provide strong support for the construction of digital ecosystems in Hong Kong, the Greater Bay Area, and the world.4

The Institute is led by Norman Chan, who previously served as the Head of the Hong Kong Monetary Authority (HKMA), who brings experience from the traditional finance sector.

He will translate this knowledge into guiding the institute towards robust standards and frameworks for the city’s seamless transition into adopting digital assets.

Perhaps most importantly, the launch of the Web3 Institute has been met with full support from the Chinese government.5 

Although China had previously imposed a stringent ban on digital currencies in 2021, it has appointed Li Feng, the CEO of China Mobile International, as the Institute’s honorary chairperson.

This is seen as a positive sign towards China’s view on Hong Kong’s positioning as Asia’s digital assets hub, and is definitely a first step for China to re-open the door to the industry.

Given our strong history and network in Hong Kong, Cadenza has reached out to the Web3 Institute and are actively exploring potential avenues for collaboration.

Additionally, the Hong Kong government has also allocated approximately $6.4MM USD to develop its Web3 ecosystem.6  

Detailed in the annual 2023-2024 budget, the funds will go towards:

  • Organize major international seminars

  • Cross-sectoral business co-operation

  • Workshops for young people

Hong Kong Cyberport, a startup incubator and ecosystem wholly owned by the HKSAR government, has also been a strong supporter of fostering blockchain technology in the region for years.

Although they seek to invest in many different technology verticals, they have identified blockchain as ‘one of [their] key technology clusters.7

Animoca Brands, a leading Web3 gaming company advancing digital property rights for the open metaverse, is perhaps one of the biggest success stories to come out of the Cyberport’s community.

Founded in 2014, Animoca had reached Unicorn status in 2021 after a $88MM USD capital raise.

Animoca’s co-founder and chairman Yat Siu commented, [Cyberport] is our home.

Cyberport actively promotes digital entertainment ventures, attracting potential startups in the industry to join the community, which creates synergy for all the companies here.8  

For companies that plan to set up or relocate to Hong Kong after this regulatory change, Cyberport presents an attractive ecosystem for development and growth.

One of the big motivations behind Hong Kong’s aggressive regulatory push is to regain its position as Asia’s premier financial hub.

In recent years, amidst China’s digital assets clampdown and rigorous COVID policies, many founders had relocated and fled to Singapore to set up their businesses.

Looking from a wider macro perspective, Singapore’s assets under management ‘grew 16% to $4tn, while Hong Kong’s grew by only 2% to $4.6tn.9

Post-FTX, however, Singaporean regulators have become increasingly cautious, placing blanket bans across many different areas of the industry.

Therefore, the establishment of institutions to support the industry’s development could serve as a dealbreaker for many Singaporean-based companies to consider relocating to Hong Kong.

Additionally, the Hong Kong Monetary Authority announced in mid-May that a trial run for a digital Hong Kong Dollar (e-HKD) is in the works.

This move is timely and is reflective of recent trends. According to the 2022 Global Payments Report published by the FIS, ‘digital wallets will account for 40% of the city’s online transaction value by 2025, overtaking credit cards.10

Alongside other institutions that are playing a role in fostering Web3 adoption in the region, the e-HKD trial run will involve ‘around 16 handpicked banks and payment companies, including industry heavyweights HSBC and Standard Chartered, [whom] will undertake tests involving six potential use cases for the digital asset.11

Startup Opportunities

The regime is set to bring forth a whole new wave of companies that specifically operate within one set of regulations.

Specifically, the aforementioned regime plans to ‘supervise the governance, issuance and stabilization of stablecoins’, starting with fiat-backed ones.

With a clearer set of regulations, CNHC, an offshore Chinese-yuan pegged stablecoin project, raised $10M of funding from KuCoin Ventures, Circle Ventures and IDG Capital in 2022.12

Founded in 2021, CNHC is registered in the Cayman Islands as a cross-border payment service provider; with the latest announcement, they are now in the process of moving its headquarters to Hong Kong, which is also home to the largest offshore center historically.

Other established players are also looking to tap into the space.

In December of last year, the Tron blockchain launched TCNH.

A stablecoin pegged to Offshore Chinese Yuan.13

With both the Hong Kong and Chinese government looking for ways to push digital currency adoption in their jurisdictions, companies can benefit by building solutions that complement these political agendas with increasingly visible regulatory guidelines.

Currently, only two local exchanges - HashKey Group and OSL - have received authorization to operate in Hong Kong.

As mentioned above, other internationally-based exchanges such as OKX have expressed their desire to move into the region as well.

However, these transitions might prove more tedious than it seems.

Another digital assets exchange, Bitget, announced that Hong Kong users will be required to move to www.BitgetX.hk and ‘close any open perpetual contract or margin trading positions and withdraw their virtual assets from Savings products at Bitget.com.14

This presents an opportunity for new exchange players to enter the space and provide a product that is both compliant and user-friendly.

Innovative products are continuously being developed in line with the region’s shifting regulatory landscape.

Conflux Network, a Layer 1 protocol that claims to be the only regulatory compliant, public and permissionless blockchain in China, announced that it has partnered with China Telecom to build blockchain-based SIM cards.15

China Telecom is the second largest wireless carrier in China with an estimated 390MM subscribers.

These BSIM cards will allow users to ‘store digital assets safely, transfer their digital assets conveniently, and display their assets in a variety of applications’.

On May 18th, Conflux unveiled their BSIM card, as well as announcing that they will be piloting the product in Hong Kong before introducing it to Mainland China and overseas.

This shows that companies have identified an existing market large enough in Hong Kong to test their products, hinting at the potential of the startup ecosystem that is yet to be unlocked.

In recent years, Hong Kong has become home to a budding blockchain startup ecosystem.

In 2022, FinTech News identified approximately 400 FinTech-related startups in the city, and found that blockchain represents the largest FinTech segment (24%).16

Venture Ecosystem

According to Pitchbook, there are approximately 294 active blockchain-focused investment funds with at least one location based in Hong Kong, highlighting the appetite for investments in the region.

With the new regulations in store, we can expect that this number will continue to grow, as investors feel increasingly comfortable to deploy capital within the space.

Looking Ahead

On May 23rd, the Hong Kong SFC concluded its consultation on regulation of digital assets trading platforms.

Including these key points:

  • In order for a token to be eligible for retail investor trading, ‘tokens must [at the minimum] be eligible large-cap virtual assets included in at least two acceptable indices issued by two independent index providers’.

  • To provide clients with sufficient liquidity on trading platforms, the SFC will allow ‘market making activities to be conducted by third-party market makers’.

  • The aforementioned stablecoin regulations are still expected to be implemented later this year or next; currently, however, it is of the SFC’s view that ‘they should not be admitted for retail trading’.

  • Currently, trading platforms are not allowed to offer services such as ‘earning, deposit-taking, lending, and borrowing’.

Additionally, the SFC has said that they have not approved any virtual asset trading platforms to provide their services to retail investors.

However, there now exists a very concrete and actionable framework for companies to follow.

Applications for digital assets trading licenses will open on June 1st.

There have been mixed reactions from the community regarding these new rules.

Some think that they are too restrictive, and that they are not enough to enact any sort of significant change in the ecosystem.


Others welcome the change, stating that clear-cut boundaries are a positive sign showing the city is ready to properly embrace wider digital assets adoption.

Ultimately, the regulatory landscape for digital assets and Web3 is shifting every day, and there remains a lot to be seen on how Hong Kong’s Web3 ecosystem takes shape.

For now, the new regulatory frameworks supported by institutional involvement will definitely propel Hong Kong’s position as a digital assets destination.

At Cadenza, we plan to actively monitor deal flow for new and exciting investment opportunities, and build out a robust investor network in the region to stay updated with the latest activities.

1.The Government of the Hong Kong Special Administrative Region (2023) https://www.info.gov.hk/gia/general/202210/31/P2022103000454.htm

6The Government of the Hong Kong Special Administrative Region (2023) https://www.budget.gov.hk/2023/eng/budget10.html