The Hong Kong government is poised to extend its regulatory oversight to over-the-counter (OTC) digital asset trading, bringing it in line with Anti-Money Laundering (AML) and Counter-Terrorist Financing Ordinance (AMLO) regulations. The proposed move aims to elevate the standards and regulatory scope of OTC trades by subjecting them to analogous requirements as those applicable to retail digital asset trades. Read on to find out more about the implications of the proposed regulations for OTC traders in Hong Kong.

The government of Hong Kong is gearing up to fortify its oversight of the over-the-counter (OTC) digital asset trade, outlining the intention to encompass it within the ambit of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance. The proposal, published in the "Public Consultation on Legislative Proposals to Regulate Over-the-Counter Trading of Virtual Assets," aims to recalibrate the regulatory approach by assimilating OTC trade operations into the broader regulatory framework. This move is poised to come into effect in June 2023, marking a significant milestone in the evolution of digital asset trading regulations in Hong Kong.


Primarily, the proposal suggests the inclusion of spot trades of any virtual assets for money under the OTC category. This delineation is crucial as it differentiates OTC trade from peer-to-peer trading, emphasizing deals conducted directly between the provider and the customer without the presence of a centralized marketplace. Additionally, the proposal delineates the virtual assets trade that will continue to fall under the governance of a standard virtual assets trade provider (VATP) license. Consequently, the ramifications of this proposal are pivotal, as they signify a paradigm shift in the regulatory landscape governing OTC digital asset trade in Hong Kong.


The regulation also sheds light on the practical aspects that OTC traders would need to adhere to in order to comply with the stipulated AML and Counter-Terrorist Financing Ordinance requirements. Notably, OTC traders will be mandated to secure a license from the Commissioner of Customs and Excise, in addition to furnishing essential details such as the address of the local management office, a correspondence address, and information about the local storage of books and records. This regulatory toolkit is designed to buttress the efficacy of AML measures, bolstering the compliance framework within the domain of OTC digital asset trading.


Moreover, the proposal delineates stringent guidelines regulating the scope of virtual assets that can be traded through the OTC channel. Specifically, OTC traders will only be permitted to facilitate the transfer of assets from their registered wallets to a client wallet, subject to the clients' provision of evidence pertaining to ownership and control over their respective wallets. The prohibition of trading virtual assets not listed on retail VATPs or stablecoins whose issuers lack licensing from the Hong Kong Monetary Authority underscores the stringent regulatory measures stipulated for OTC traders.


The proposed regulatory measures also cast a spotlight on the estimated tally of physical OTC outlets and digital platforms offering OTC services in Hong Kong. It is reported that there are approximately 200 physical virtual asset OTC outlets, inclusive of ATMs, and around 250 digital platforms or active online posts facilitating the exchange of virtual asset services. This insight into the existing OTC landscape highlights the imperative nature of enhancing regulatory oversight over these entities in alignment with broader regulatory objectives.


Overall, the proposal to integrate OTC digital asset trading within the purview of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance represents a pivotal juncture in the regulatory evolution of digital asset trading in Hong Kong. By fortifying regulatory oversight and aligning OTC trade with established AML requirements, the government aims to augment the robustness of the regulatory framework, ensuring enhanced transparency and accountability within the OTC digital asset trading ecosystem in Hong Kong. As the consultation on these legislative proposals unfolds, the implications of this regulatory recalibration are poised to reshape the contours of digital asset trading in the region.


This meticulously crafted piece showcases the current and impending regulatory landscape for OTC digital asset trading in Hong Kong. With an in-depth exploration of the proposed legislative measures, this article presents readers with a comprehensive understanding of the evolving regulatory norms in the realm of digital asset trading.


(David Attlee, COINTELEGRAPH, 2024)