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隨着企業出海和跨境業務佈局的需求持續增長，選擇合適的離岸公司註冊地成爲許多創業者和投資者關心的首要問題。 香港、BVI、開曼羣島公司註冊怎麼選？ 一文看懂三地優勢與成本 隨着企業出海和跨境業務佈局的需求持續增長，選擇合適的離岸公司註冊地成爲許多創業者和投資者關心的首要問題。 香港 、 英屬維爾京羣島（BVI） 和 開曼羣島 是目前最受歡迎的三個離岸註冊地點，各有其獨特的優勢和適用場景。本文爲你詳細拆解三地的核心差異，助你做出最適合的選擇。 一、香港——國際金融中心的穩健之選 香港作爲國際金融中心，擁有發達的金融、法律和商業基礎設施，長期受到國際投資者和跨國公司的青睞。在稅務方面，香港利得稅率較低，且沒有增值稅或銷售稅，對於開展跨境業務的企業來說極具吸引力。 透明度方面 ，香港要求董事及股東資料可公開查冊，同時公司需設立「重要控制人登記冊」（SCR）並可供當局查閱，屬於透明度較高的司法管轄區。法律體系採用英式普通法，透明且穩定。 靈活度方面 ，香港的合規要求相對較多，法例嚴格，財務報表與審計要求較高，架構變更與公司治理的彈性相對較低。 費用參考 ： 政府官費：2026年4月1日起，政府費用合計約3,895港元（含公司註冊費1,545港元及一年期商業登記證2,350港元）。 市場平均服務費： 坊間諮詢顧問公司的全包套餐（含政府規費、公司祕書、註冊地址等）市場主流收費約爲 HKD 5,000 – 15,000 不等。 年度維護成本：每年需支付商業登記證續期、週年申報表規費、法定公司祕書及地址服務費；另加強制性年度會計與審計費。 市場平均每年總開支： 約 HKD 5,000 – 20,000+（視乎公司營業額及業務複雜度而定）。 註冊時間： 一般1至14日即可完成。 最適業務類型： 實體運營、亞洲貿易、科技、跨境業務。 二、英屬維爾京羣島（BVI）——靈活保密的控股架構首選 BVI以其靈活的公司法規定和高度保護投資者隱私而聞名，同時享有零稅率和簡化的報告要求。作爲離岸金融中心，BVI吸引了大量國際業務和投資。 需要特別關注的是： 2025年6月，BVI被正式納入FATF「增強監控名單」（即「灰名單」），銀行開戶審覈週期延長、跨境資金到賬速度變慢、備案所需材料增多。這是在選擇BVI時需要考量的重要因素。 透明度方面 ，BVI屬高度保密司法管轄區，董事及股東資料不需公開，也無公開的股東董事名冊。 靈活度方面 ，BVI的公司法極爲彈性，文件要求簡化，常用於多層控股和資產安排。 費用參考（坊間服務供應商平均範圍） ： 政府官費：BVI的政府費用具體金額與公司 註冊資本（授權股本） 掛鉤 費用類別 註冊資本≤5萬股的公司 註冊資本＞5萬股的公司 政府法定規費 550美元 1350美元 註冊代理人服務費 300-800美元 300-800美元 註冊地址費 200-500美元 200-500美元 合計常規年審成本 1570-1750美元 2370-2500美元 市場平均服務費：坊間顧問公司辦理標準股本公司的收費範圍 (首年全包) 約在 USD 1,700 – 3,500（摺合約 HKD 13,000 – 27,000）。 年度維護成本：無需報稅與審計，每年主要支付政府牌照費及代理人年費。 市場平均每年總開支： 約 USD 1,570 –2,440（摺合約 HKD 12,300 – 20,000）。 註冊時間： 可於7至21日完成。 審計與報告要求： 無需審計、無需稅務申報（但有經濟實質申報要求）。 最適業務類型： 控股、資產管理、財富管理、SPV。 三、開曼羣島——國際資本市場的上市通道 開曼羣島同樣擁有顯著的稅務優勢，沒有企業所得稅、資本利得稅、遺產稅或增值稅。其靈活的法律框架適用於各種業務結構，作爲離岸金融中心吸引了大量國際企業和投資者。 透明度方面 ，開曼比BVI更透明，並受國際市場（如港交所、納斯達克）的廣泛接受。 靈活度方面 ，開曼的公司法高度配合基金、私募股權/風險投資（PE/VC）及IPO的需求，支持複雜股權、回購、拖售條款等安排，是私募和投資架構中彈性最高的選擇。 費用參考： 政府官費：開曼羣島開放註冊的商事主體分爲三類，不同類型對應不同註冊官費標準，具體明細如下： 公司類型 2025-2026年基礎註冊官費（USD） 註冊資本≤5萬美元對應官費（USD） 註冊資本＞5萬美元對應官費（USD） 備註 豁免有限公司（常用） 1043 1043 1500-3000 跨境架構、紅籌上市主體的主流選擇，無需在當地實際經營 普通居民有限公司 1043 1043 需在開曼有實際經營場所，每年需申報本地經營所得 豁免有限合夥企業 視GP及基金架構而定，通常高於普通公司 視GP及基金架構而定，通常高於普通公司 視GP及基金架構而定，通常高於普通公司 多用於基金架構、投資持股平臺，無需披露普通合夥人以外的出資人信息 市場平均服務費：坊間顧問公司辦理標準豁免公司（Exempted Company）的費用約爲 USD 3,000 – 5,000（摺合約 HKD 23,400 – 39,000）。 年度維護成本：每年須向開曼政府繳交定額牌照費，並維持當地註冊代理人及地址。市場平均每年總開支： 約 USD 2,000 – 4,500+（摺合約 HKD 15,600 – 35,000+，如涉及基金或上市架構費用會更高）。 註冊時間： 通常需7至10日（基金架構會更久）。 審計與報告要求： 視公司型號而定，基金類需高度合規。 最適業務類型： IPO、基金、跨國集團、紅籌架構。 四、三地核心對比速覽 指標 香港 BVI 開曼羣島 透明度 高（董事/股東資料可公開查冊） 低（高度保密） 中高（國際市場接受度高） 法律體系 英式普通法，透明穩定 英式普通法，彈性高 英式普通法，國際金融專用度高 靈活度 中（合規限制較多） 高（架構與文件要求彈性大） 高（私募、投資架構彈性最高） 註冊時間 1–14日 2–21日 3–5日 審計與報告 必須審計、報稅、年報 無需審計，有經濟實質申報 視公司型號而定 銀行開戶難度 中 高（灰名單影響） 高 最適業務 實體運營、貿易、科技 控股、資產管理、SPV IPO、基金、紅籌架構 五、2026 最新合規風險提示：BVI「灰名單」效應 選擇離岸註冊地時，除成本外，國際反洗錢與監管政策 也是核心考量。 ⚠️ 特別注意： 英屬維京羣島（BVI）已被金融行動特別工作組（FATF）納入 「 增強監控名單 」 （即灰名單）。 這直接導致： 1. 銀行開戶與審查期延長： 各大國際銀行對 BVI 公司的盡職調查（CDD）顯著加強。 2. 跨境資金流轉變慢： 涉及 BVI 實體的資金匯劃易觸發額外合規審查。 3. 備案材料增加： 企業需準備更完備的業務實質與最終受益人（UBO）證明。 因此，若企業旨在搭建多層控股架構或進行資本運作，需提前規劃銀行開戶策略及經濟實質（Substance）申報。 六、企業如何選擇最適合的註冊地？ 選擇註冊地應基於公司具體需求和業務性質，最重要的前提是瞭解各司法管轄區的申請條件及適用情況，確保符合當地法律和監管要求。 以下幾點可供參考： 若您需要在亞洲開展 實體業務、跨境貿易、科技研發 ，或希望利用香港發達的金融與法律體系進行銀行融資，香港是首選。 若您的核心需求是 海外投資、個人/家族財富管理、資產隔離 ，或是建立多層控股架構中的中間層公司（SPV），BVI 依然具備極高的保密性與架構彈性。 若企業的終極目標是赴 港交所（HKEX）或美股（Nasdaq/NYSE）上市、發行海外私募股權基金（PE/VC） ，開曼羣島是國際資本市場認可度最高的頂層架構首選。 無論選擇哪個註冊地，建議在決策前諮詢專業的法律和稅務顧問，根據企業的實際情況制定最優的註冊方案。 [完結 - 香港、BVI、開曼羣島公司註冊怎麼選？一文看懂三地優勢與成本] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The article is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

衷心感謝各位踴躍參與我們於2026 年 9 月 24 日（星期四） 舉辦的「從監管視角解讀522新規／通函 —— 內地投資者帳戶的合規管理對策」線上研討會。本次活動反應熱烈，吸引了眾多持牌法團管理層及合規專業人士線上出席與觀看直播，我們深感榮幸。 【活動回顧】 「從監管視角解讀522新規／通函 —— 內地投資者帳戶的合規管理對策」網絡研討會及要點總結 (2026.09) 衷心感謝各位踴躍參與我們於 2026 年 9 月 24 日（星期四） 舉辦的「從監管視角解讀522新規／通函 —— 內地投資者帳戶的合規管理對策」線上研討會。本次活動反應熱烈，吸引了眾多持牌法團管理層及合規專業人士線上出席與觀看直播，我們深感榮幸。 隨著監管機構針對內地投資者帳戶頒佈最新指引及 522 新規，持牌法團在開戶流程、身份核實、持續監察及合規審查等方面均面臨更嚴格的要求。 本次研討會由我們的專業團隊—— Tommy Chung 與 Ken Leung 主講，從監管角度剖析新規細節，並分享了具體可行的實務合規對策。 以下為本次演講的核心合規要點總結： 📌 網絡研討會要點總結 全面解讀監管通函與核心標準 ：精準拆解 522 新規的核心要點，協助持牌法團掌握最新的合規審查範疇與開戶/身份核實標準。 優化持續監察與風控流程 ：深入分析新規對日常業務營運的具體影響，強調定期落實持續監察機制以及時識別異常帳戶活動。 落實切實可行的合規應對方案 ：針對持牌法團的營運痛點，提供具體改善建議，助力機構主動降低潛在違規風險並強化內部控管。 感謝所有持牌法團管理層及業界同仁的支持！天匯合規將繼續致力於提供專業的合規支援，與大家攜手應對監管新趨勢。 我們非常重視您的寶貴意見。若您對本次培訓有任何建議，或希望我們在未來的研討會中涵蓋特定主題，歡迎隨時與我們分享。 期待不久的將來再次為業界舉辦更多具啟發性的專題分享！ 📞 歡迎聯繫我們，獲取專屬的合規咨詢服務和建議！ [Event Recap] Webinar & Key Highlights: "Regulatory Insights on the May 22 Circular — Compliance Strategies for Mainland Investor Accounts" (Sept 2026) We would like to express our sincere gratitude to everyone who participated in our online webinar, "Regulatory Insights on the May 22 Circular — Compliance Strategies for Mainland Investor Accounts," held on Thursday, September 24, 2026. We were truly honored by the overwhelming response and the active participation of management teams and compliance professionals from licensed corporations who joined the live broadcast. Following the latest guidelines and the May 22 Circular issued by the regulatory authorities regarding Mainland investor accounts, licensed corporations are facing heightened requirements across account opening procedures, identity verification, ongoing monitoring, and compliance reviews. In this webinar, our expert team— Tommy Chung and Ken Leung —analyzed the intricate details of the new regulations from a regulatory perspective and shared practical, actionable compliance strategies. Below is a summary of the key compliance highlights covered during the presentation: 📌 Webinar Key Highlights Comprehensive Interpretation of the Regulatory Circular & Core Standards: A detailed breakdown of the key elements of the May 22 Circular, helping licensed corporations navigate the latest compliance review scopes, as well as account opening and identity verification standards. Enhancing Ongoing Monitoring & Risk Control Protocols: An in-depth analysis of the specific impact of the new regulations on daily operations, emphasizing the routine implementation of ongoing monitoring mechanisms to identify abnormal account activities in a timely manner. Executing Practical Compliance Solutions: Actionable improvement recommendations tailored to the operational pain points of licensed corporations, enabling institutions to proactively mitigate non-compliance risks and strengthen internal controls. Thank you once again to all the management personnel and industry peers for your continued support! ComplianceOne remains dedicated to delivering professional compliance support and partnering with you to navigate emerging regulatory trends. We highly value your feedback. If you have any suggestions regarding this training or would like us to cover specific topics in future webinars, please feel free to share your thoughts with us. We look forward to hosting more insightful sessions for the industry in the near future! 📞 Contact us today for tailored compliance advisory services and professional guidance!

The Hong Kong Government will implement enhanced regulations for licensed money lenders in two phases. The first phase in August 2026 introduces a Debt Servicing Ratio (DSR) cap for low-income borrowers and bans the use of loan referees. The second phase in June 2027 mandates... ComplianceOne's Market Insights : Mainland Enterprises "GoGlobal" Task Force: Background, Development, and Professional Implementation (May 2026) I. Background: The "Value-Added Super-Connector" in National Strategy As Mainland enterprises transition from domestic dominance to global expansion, Hong Kong’s role at the intersection of the "Dual Circulation" strategy has evolved from a traditional window to a high-capacity "Value-Added Super-Connector." To systematically support Mainland firms in leveraging Hong Kong's advantages for international growth, the Chief Executive proposed a dedicated mechanism in the 2025 Policy Address to coordinate territory-wide resources for enterprises "going global." The Mainland Enterprises "GoGlobal" Task Force was officially established in October 2025. This high-level, cross-departmental platform led by the HKSAR Government serves as a proactive one-stop hub for recruitment and support. Within this policy framework, professional regulatory consultancies such as ComplianceOne play a pivotal role in translating policy into executable solutions, ensuring that enterprises enjoy policy dividends while aligning precisely with international regulatory standards. II. High-Level Governance: Cross-Agency Synergy and Professional Leadership The Task Force is overseen by the Secretary for Commerce and Economic Development (SCED), Mr. Algernon Yau, and is guided by a Steering Committee comprising the core pillars of Hong Kong’s financial, trade, and regulatory infrastructure: Policy & Coordination: Permanent Secretaries from the Commerce and Economic Development Bureau (CEDB), Constitutional and Mainland Affairs Bureau (CMAB), Financial Services and the Treasury Bureau (FSTB), and the Innovation, Technology and Industry Bureau (ITIB). Execution & Promotion: Invest Hong Kong (acting as the Secretariat), the Trade Development Council (HKTDC), and the Productivity Council (HKPC). Finance & Risk Management: The Hong Kong Monetary Authority (HKMA), HKEX, and the Hong Kong Export Credit Insurance Corporation (ECIC). While this "Whole-of-Government" approach ensures rapid access to administrative resources, the operational success of an enterprise hinges on technical execution. Specific nuances—such as the establishment of trust structures, company secretarial maintenance, and license applications—require professional service providers like ComplianceOne, a licensed Trust or Company Service Provider (TCSP), to bridge the gap between administrative frameworks and commercial reality. III. Development Milestones: From Strategic Consensus to Precision Implementation Since its inception, the Task Force has rapidly expanded its service network through high-profile engagements and strategic agreements: November 2025: Shanghai Promotion Conference The Task Force hosted the "Hong Kong: The Preferred Platform for Mainland Enterprises to Go Global" conference, highlighting Hong Kong’s core functions in cross-border supply chain management and offshore trade. December 2025: Launch of the Professional Services Platform Initiated by the Department of Justice (DOJ) with support from the CEDB, the "Hong Kong Professional Services Going Global Platform" was officially launched. In this context, ComplianceOne actively supports Mainland enterprises in establishing headquarters and expanding overseas through its one-stop compliance solutions, providing deep support in Anti-Money Laundering (AML) monitoring and corporate governance. February 2026: Elevating Ministry-Level Cooperation The CEDB signed a Memorandum of Understanding (MOU) with the Ministry of Commerce of the People's Republic of China regarding "Strengthening Exchange and Cooperation in the Field of Overseas Comprehensive Services." As a leading compliance expert, ComplianceOne is committed to upholding the spirit of this MOU by combining professional regulatory advisory with the Task Force's policy guidance to enhance the global adaptability of Mainland firms. March 2026: Beijing Seminar & Digital Launch InvestHK and the China Council for International Investment Promotion co-organized their first large-scale event in Beijing. Simultaneously, the "GoGlobal" Dedicated Website was launched. With the surge in demand for high-quality professional services, ComplianceOne stands as a trusted partner, offering expert insights into SFC licensing, corporate structural optimization, and cross-border tax compliance. IV. Vision: A "Safe Harbor" and "Booster" for Global Growth The core value of the Task Force lies in "Precision Matching" and "End-to-End Support." Looking ahead, the HKSAR Government will continue to provide policy leadership, while ComplianceOne will continue to serve as a professional regulatory consultant, transforming complex compliance requirements into efficient operational pathways. Through this dual protection of "Government Platforms + Professional Institutions," we help Mainland enterprises transform Hong Kong into an irreplaceable global headquarters, achieving generational legacy and stable growth. Sources of Reference HKSAR Government. (2026, March 20). Seminar on empowering Mainland enterprises to go global with Hong Kong's business advantages held in Beijing [Press Release]. Retrieved from: https://www.info.gov.hk/gia/general/202603/20/P2026032000232.htm Department of Justice, HKSAR. (2025, December 13). Launch of "Hong Kong Professional Services Going Global Platform" marks new phase in supporting Mainland enterprises [Press Release]. Retrieved from: https://www.doj.gov.hk/tc/community_engagement/press/20251213_pr1.html Xinhua News / LOCPG. (2026, March 23). InvestHK officially launches dedicated website for Mainland Enterprises "GoGlobal" Task Force . Retrieved from: http://big5.locpg.gov.cn/20260323/7889fc869007455880052fe575e3d005/c.html Commerce and Economic Development Bureau. (2025, November 6). "Hong Kong: The Preferred Platform for Mainland Enterprises to Go Global" promotion held in Shanghai [Press Release]. Retrieved from: https://www.cedb.gov.hk/tc/news/press_release/2025/pr06112025a.html HKSAR Government. (2025, October). The Chief Executive’s 2025 Policy Address: Reform for Enhancement — Building a Brighter Future Together [Section 80]. Retrieved from: https://www.policyaddress.gov.hk/2025/tc/p80.html InvestHK. (2025). Mainland Enterprises "GoGlobal" Task Force Steering Committee holds first meeting . Retrieved from: https://www.investhk.gov.hk/zh-hk/news/goglobal-task-force-steering-committee-holds-first-meeting/ [End of ComplianceOne's Market Insights : Mainland Enterprises "GoGlobal" Task Force: Background, Development, and Professional Implementation – May 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

我們非常榮幸能與 MOSS Group 共同舉辦本次環境、社會及管治(ESG)「新常態」：從自願到合規生存關鍵研討會，並感謝近 200 位嘉賓的熱情參與！ 【活動回顧】MOSS Group x 天匯合規共同舉辦 - 環境、社會及管治(ESG)「新常態」：從自願到合規生存關鍵 (2026.03) 我們非常榮幸能與 MOSS Group 共同舉辦本次環境、社會及管治 (ESG) 研討會，並感謝近 200 位嘉賓的熱情參與！ 在研討會中，我們深入探討了 ESG 監管的最新發展。以下是當天的核心洞察分享： 1. 監管環境的根本轉變： 香港正對標 ISSB 國際標準，全面轉向具備全球可比性的披露框架。合規已從「不遵守就解釋」演進為核心監管要求 。 2. 氣候風險管理的實務挑戰： 2025 年新規定要求企業具備評估實體風險與轉型風險的能力。特別是範疇三排放的收集，需要與供應鏈合作夥伴建立有效的協作機制 。 3. 基金經理的合規義務： 證監會要求擁有投資酌情權的基金經理必須在投資流程中系統性考慮氣候風險，並遵循「相稱性」原則建立管治與風險管理體系 。 4. 建立防禦性的紀錄： 在監管趨嚴的背景下，「行動是關鍵，紀錄是證據」。企業應確保所有 ESG 評估與決策過程皆完整留痕，以應對未來的合規審查 。 再次感謝當日講師與嘉賓帶來的精彩討論。在 ESG 全面合規的新時代，ComplianceOne 與 MOSS Group 將繼續為您提供專業導航。 期待在下一次活動中與您再次交流！ We are honored to have co-hosted this seminar with MOSS Group and would like to extend our sincere gratitude to the nearly 200 distinguished guests for their enthusiastic participation. The session provided a deep dive into the latest developments in ESG regulation. Below are the key insights shared during the event: 1. Fundamental Shift in the Regulatory Landscape Hong Kong is rapidly aligning with ISSB international standards, transitioning toward a disclosure framework characterized by global comparability. Compliance has evolved from a "comply or explain" approach into a core regulatory mandate. 2. Practical Challenges in Climate Risk Management New regulations taking effect in 2025 require enterprises to possess the capability to assess both physical and transition risks. In particular, the collection of Scope 3 emissions data necessitates the establishment of effective collaboration mechanisms with supply chain partners. 3. Compliance Obligations for Fund Managers The Securities and Futures Commission (SFC) requires fund managers with investment discretion to systematically integrate climate risks into their investment processes. Furthermore, they must establish governance and risk management systems in accordance with the "proportionality" principle. 4. Establishing Defensive Documentation In an environment of tightening supervision, "action is key, but records are evidence." Companies must ensure that all ESG assessments and decision-making processes are fully documented to create a robust audit trail for future compliance reviews. Once again, we thank our guest speakers and attendees for the insightful discussions. In this new era of comprehensive ESG compliance, ComplianceOne and MOSS Group remain committed to providing professional guidance. We look forward to connecting with you again at our next event!

The topics discussed in this monthly newsletter for Licensed Corporations are as follows: ComplianceOne Newsletter – July 2026 The topics discussed in this monthly newsletter are as follows: Market News Hong Kong’s AUM grew 20% to record high: SFC’s 2025 survey on asset and wealth management The Hong Kong Securities & Futures Professional Association Urges the SFC to Optimize the CVAP Examination and Raises Concerns over Operating Costs under New VA Policies SFC welcomes new initiatives to advance Hong Kong’s fixed income and currency markets Research Paper No.79: Half-yearly Review of the Global and Local Securities Markets Enforcement News SFC Suspends Wong Tim Hi for Nine months SFC reprimands and fines Victory Securities Company Limited $1.7 million and suspends its responsible officer for regulatory breaches SFC reprimands and fines China Industrial Securities International Asset Management Limited HKD 6.8 million for failing to properly identify and address red flags in dubious arrangements and other failures in managing private fund SFC reprimands and fines Bright Smart Securities International (H.K.) Limited HKD 2.8 million for internal control failures in monitoring suspicious trades SFC reprimands and fines Luk Fook Securities (HK) Limited HKD 2.1 million for inadequate cybersecurity control to fend off cyberattack Market Misconduct Tribunal finds Sir Dickson Poon culpable of insider dealing ahead of disclosure of HKD 1.15 billion corporate windfall A 26-year-old Hong Kong trader is rumoured to have embezzled HKD 150 million by trading Hynix ETFs Regulatory Updates SFC and CSRC hold high-level enforcement cooperation meeting SFC and Securities Commission Malaysia sign MoU to expand mutual recognition of funds and facilitate simplified dual IPO listing framework SFC mandates phishing-resistant authentication methods for internet brokers and VATPs to protect client accounts SFC enhances regulatory framework for daily leveraged and inverse products to ensure orderly market trading Markets News 1. Hong Kong’s AUM grew 20% to record high: SFC’s 2025 survey on asset and wealth management The SFC’s Asset and Wealth Management Activities Survey 2025 confirms that Hong Kong had a record-breaking year. Total assets under management rose 20% year on end to $42.2 trillion, surpassing the previous peak in 2021, driven by a near tripling of net fund inflows (+193%). Growth was based across every major segment: asset management and fund advisory, private banking and private wealth management, and trust services. Metric 2025 YoY Change Total AUM HKD 42,202 billion +20% Net Fund inflows HKD 2,065 billion +193% Asset Management & Fund Advisory AUM HKD 30,957 billion +19% Private Banking & Private Wealth Management AUM HKD 12,945 billion +24% Assets held under Trusts HKD 6,214 billion +8% Mainland-related firms’ AUM HKD 3,949 billion +28% Registered open-ended fund companies 676 +43% Type 9 licensed corporations 2,358 +7% Type 9 licensed individuals 15,747 +5% Total industry headcount 56,557 +5% This survey points to a maturing, institutionally oriented and geographically diversified industry. International investors continued to account for the majority of AUM (54%), while asset managers increasingly allocated capital globally. 56% of Hong Kong managed assets were invested outside the Mainland and Hong Kong, with bonds recording double-digit growth for a second consecutive year. The report is indicative of high growth in Hong Kong’s fund ecosystem as SFC-authorised fund NAV rose 38% alongside registered OFC’s rising 43%. Single-family office population also grew to over 3,380 (rising roughly 680 over two years). Mainland-related firms outperformed the broader market, and mutual market access schemes (Stock Connect, ETF Connect, WMC, MRF) all saw expanded two-way activity. SIGNIFICANCE: Following the release of strong growth data, expect continued momentum on OFC reform, ETF related product rules and mainland connectivity. The standout signals such as the 43% jump in YoY OFC Growth signals Hong Kong’s domestic fund structures are gaining strong market traction and displacing traditional offshore vehicles for regional strategies. Additionally, the rise in mainland-affiliated asset net inflows (80%) underscores the continuing importance of “Southbound” capital corridor and cross-boundary connect schemes. Licensed firms growing 7% to 2,358 and licensed individuals rising to 15,747. This expands the addressable market for compliance and legal teams while heightening competition for qualified regulatory talent. 2. The Hong Kong Securities & Futures Professional Association Urges the SFC to Optimize the CVAP Examination and Raises Concerns over Operating Costs under New VA Policies The Hong Kong Securities and Futures Professional Association ( HKSFPA ) met with the Legislative Council’s Deputy Commissioner for Financial Affairs and the Treasury, Mr. CHAN Joseph, and senior SFC officials including the executive director of intermediaries, senior director, and the head of the fintech group on 03 July 2026. The two sides exchanged ideas on a four core issues including the latest policies on virtual assets ( VA ), the licensing regime, operating costs, and the industry-wide Certification Programme for Virtual Asset Professionals ( CVAP ). Numerous policy changes were discussed, including the removal of the previous 10% minimum exemption for virtual asset management and an immediate effective date of new rules without a transition period . However, arrangement details are yet to be clarified. Representatives of the HKSFPA stated plainly that new regulatory provisions are based on principle and lack operational guidance, placing significant operational and compliance pressures on firms engaged or entering into the virtual asset businesses. CVAP Examination Reform Commitments Commitment Detail Separation of course and examination HKSI will decouple mandatory coursework from the examination. Candidates will be able to sit the exam without attending compulsory classes, reducing talent training costs for firms Examination Fee Reduction Standalone exam will be supported by official study materials Fees will be reduced to align with existing SFC examination benchmarks (HKSI Paper 2&3) VATP Issues and Recommendations Issue Industry Concern Recommendation Hardware Security Modules ( HSM ) HSM Supply is near monopolized driving high costs and limited bargaining power for intermediaries. Regulators should adopt “technology neutral” principle and accept Multi-Party Computation ( MPC ). Hot/cold Wallet Ratio Requirement Hot wallet cap at 2% of total client assets and minimum 3 persons required per asset transfer requires significant manpower and time costs in daily operations. Review and optimize ratio while maintaining risk controls. Insurance Coverage 50% cold wallet insurance coverage is required with only 2 insurers that currently underwrite VA insurance. This creates extremely high premiums, reportedly demanding as high as 50% profit margins. Encourage regulators to engage insurance industry to revise coverage ratios and introduce more rational actuarial models. On-chain transfer fees Substantial gas fees are generated by real-time individual transfers. Allow batch processing within a compliant framework to reduce operational burden and transfer costs. Beyond the discussion of CVAP and VA operating costs, the association raised five structural regulatory questions seeking further clarity. Firstly, to clearly delineate technology services and regulated activities. It aims to foster innovation by enhancing licensing transparency and expediting product approvals, while simultaneously clarifying market arrangements for tokenized assets. Furthermore, it will define the regulatory division of labor for VA payments and establish clear guidelines for private equity fund self-custody arrangements. Key Area Industry Concern/ Recommendation Technology vs Regulated Activities Urges clearer delineation of regulated activities; pure tech service providers not handling client assets or charging fees should not face unnecessary licensing burdens. Requests categorical guidance for models like tech access, system development, trading support and advisory. Licensing Approval Transparency Notes SFC manpower constraints causing uncertain VASP processing times; recommends adopting phased frameworks (e.g. “serviced offices“ model) and clearer timelines aid resources and capital planning. Innovative Products & Tokenized Assets Retail market limited to 5 spot pairs with no shorts/hedging; SFC’s Feb 2026 perpetual contract framework for pros lacks timelines/pilot details. Urges faster derivatives approval and clarity on price discovery, offshore data and trading hours for cross-market tokenized assets. VA Payment Regulatory Division Concerns over firms with only MSO (Customs) licenses conducting large-scale VA payments; MSO does not cover VA businesses. Urges clarification of inter-agency responsibility and clear policy direction/timeline. Private Fund Self-Custody Lack of guidance on SFC notification, mandatory requirement (asset segregation, authority management), risk controls and audit standards for self-custody arrangements. Expect specific guidance to build internal compliance. SIGNIFICANCE: The two CVAP commitments are near-term improvements that will directly reduce training costs for VATPs seeking to bring practitioners into regulatory compliance. Firms should factor these changes into their CVAP planning timelines once implementation details are published by HKSI and the SFC. Licensed VATPs and firms preparing to apply for VATP status should monitor HKSI and SFC announcements for the revised CVAP examination structure and fee schedule. For operating firms, internal review of operating costs through compliance channels will be beneficial. Technology service providers operating adjacent to the VA regulatory perimeter should seek legal advice on whether their business models fall within the definition of regulated activities. 3. SFC welcomes new initiatives to advance Hong Kong’s fixed income and currency markets On 7 July 2026, the SFC jointly announced eleven measures alongside the People’s Bank of China ( PBOC ) and Hong Kong Monetary Authority ( HKMA ) to advance the Hong Kong fixed income and currency ( FIC ) markets and offshore RMB ecosystem. The SFC’s commentary focused on two initiatives directly within its regulatory remit. The centrepiece is a new electronic FIC trading platform to be developed by the China Foreign Exchange Trade System ( CFETS ) in collaboration with Hong Kong Exchanges and Clearing Limited ( HKEX ). The platform will be registered and operated in Hong Kong making the SFC its primary regulatory and thus requiring participants of the platform to have relevant SFC licenses. The platform is built around four key principles: adherence to international market standards; openness to international institutional participation’ alignment with Hong Kongs broader financial ecosystem and market-driven focus on improving trading efficiency and transparency while reducing transaction costs. A launch timeline will be announced in due course. Beyond the FIC trading platform, a second initiative was welcomed by the SFC to expand the range of eligible collateral for HKEX’s two clearing houses (HKFE Clearing Corporation Limited and The SEHK Options Clearing House Limited) to onshore China Government Bonds and policy banks through Northbound Bond Connect. Target is set for end of year 2026. Additional plans to enhance Swap Connect by adding seven-day fixing repo rate for depositary institutions as a reference rate for RMB interest rate swaps are planned for Q4 2026. HKEX also confirmed it will launch five-year China government bond futures contracts on 3 August 2026, providing global investors with an offshore hedging too. SIGNIFICANCE: The FIC Trading Platform invites global banks, fund managers, and other institutional participants to access Chinese fixed income and currency markets through a Hong Kong regulated, internationally friendly venue. Institutions planning to participate in said platform need to obtain or extend SFC licenses to cover relevant regulatory compliance. The collateral eligibility expansion for Northbound Bond Connect holdings and the 7-day Fixing Depository-Institutions Repo Rate ( FDR007 ) Swap Connect enhancements should be noted by treasury and fixed income desks to factor into their hedging and collateral strategies. 4. Research Paper No.79: Half-yearly Review of the Global and Local Securities Markets On 30 July 2026, the SFC issued a report analysis on Global and Hong Kong market performance, trading activity, and cross-border connectivity trends in H1 2026 against a backdrop of heightened geopolitical tensions, US monetary policy uncertainty, and divergent AI-driven rallies across markets. Key highlights include performance of global markets and trading and fund-raising activities in the first half of 2026: Overseas and Mainland China indices delivered positive H1 2026 performance, led by Nasdaq and SZCOMP, while Hong Kong benchmarks underperformed sharply. The disconnect reflects stronger AI-driven momentum in overseas markets and weaker technology exposure within local Hong Kong indices. SIGNIFICANCE: Markets face ongoing volatility from lingering Middle East conflicts, higher-for-longer US rates, stretched overseas valuations, and revealed global debt levels. Geopolitical and trade policy uncertainty remain key headwinds to investors sentiment. By explicitly stating that Hong Kong lacks the AI/semiconductor heavyweights propping up US markets, the SFC is managing expectations. It is an admission that the local market is more vulnerable to geopolitical shocks and old-economy headwinds. The SFC anticipates stress in the second half of 2026 and is laying the groundwork for why it will enforce stricter margin, liquidity, and risk controls because the fundamental market structure does not offer the same tech shield as the NASDAQ. Enforcement News 5. SFC Suspends Wong Tim Hi for Nine months The SFC suspended Mr. Wong Tim Hi (also known as Timmy Wong) ( Wong ) ( CE No: ACN818 ), a former licensed representative of Yuanta Securities (Hong Kong) Company Limited, for nine months from 3 June 2026 to 2 April 2027. The disciplinary action followed Wong’s misconduct between June 2016 and May 2017, during which Wong allowed two third parties to effectively take control of four client accounts without written authorisation from the account holders. His involvement was active, sharing confidential client account information directly with those third parties, including account details, transaction records, fund balances and fund movement data without client knowledge or consent. This case is linked to a larger market manipulation scheme involving shares of Ching Lee Holdings Limited ( HK Stock Code: 8318 ), where three individuals – including one of the third parties operating through client accounts – were convicted of conspiracy to carry out false trading between 52 and 80 months in May 2024. The SFC took into account Wong’s remorse, acceptance of the sanction, and otherwise clean record in, sentencing him to a nine-month suspension rather than a longer or permanent ban. *For more details, please click on the Statement of Disciplinary Action for Wong’s case. SIGNIFICANCE: Firms should utilize this case to reinforce training on specific prohibition against sharing client account information with third parties, including family members, friends or referrers of the client. Written third-party authorisation must be obtained and retained on file before any access is granted. Firms should also note that long enforcement horizons are the norm, not the exception as represented by this case. Additionally, being a peripheral participant in a scheme that later produces criminal convictions does not insulate a licensed individual from regulatory consequence. 6. SFC reprimands and fines Victory Securities Company Limited $1.7 million and suspends its responsible officer for regulatory breaches On 24 July 2026, the SFC reprimands Victory Securities (Hong Kong) Limited ( Victory ) and ordered it to pay a fine of HKD 1.7 million for regulatory breaches related to client due diligence failures and temporarily suspended its responsible officer Mr. CHIU Che Leung ( CE No: AAF386 ) for three months from 22 July 2026 to 21 October 2026. The SFC found that in October 2019, Victory accepted account opening documents from a client including purported broker statement as proof od shareholding without conducting adequate scrutiny. The firm failed to verify the authenticity of these documents before executing sell orders, breaching the Code of Conduct and AML/CFT regulations regarding KYC and due diligence obligations. Client Onboarding and Red Flags A client opened an account on 29 October 2019 intending to sell shares held elsewhere. The client provided broker statements as proof of holdings, but the claimed share value was incommensurate with the client’s declared financial profile—a clear red flag under CDD and AML expectations. Failure to Scrutinize Victory executed sell orders without making adequate enquiries or obtaining satisfactory explanations for the discrepancies before acting on the client’s instructions. Possible False Documents Subsequent information suggested the client may have submitted false documents to facilitate a transaction, yet Victory did not report the suspicious or potentially fraudulent conduct to the SFC as required. *For more details, please click on the Statement of Disciplinary Action for Victory’s case. SIGNIFICANCE: This case serves as a reminder to the industry that the cost of compliance failures goes far beyond fines; they also include license risks, reputational damage, and loss of customer trust. Licensed corporations should take this opportunity to conduct a comprehensive review of existing KYC, transaction monitoring, and suspicious transaction reporting mechanisms, ensuring effective collaboration among frontline staff, compliance departments, and management to avoid repeated failures. 7. SFC reprimands and fines China Industrial Securities International Asset Management Limited HKD 6.8 million for failing to properly identify and address red flags in dubious arrangements and other failures in managing private fund On 27 July 2026, the SFC publicly reprimanded and fined China Industrial Securities International Asset Management Limited ( CISIAM ) ( CE NO: AZB374 ) HKD6.8 million for regulatory failures as manager of a private fund set up for Tahoe Life Insurance Company Limited between August 2019 and September 2020. At the request of Tahoe Life’s Chief Investment Officer, CISIAM executed a chain of unnecessarily complex trades—buying structured notes linked to debt issued by a Tahoe Life related company, then moving those notes into a different manager’s fund. The structure added cost and risk, had no clear commercial rationale, and raised red flags about hidden asset flows/ connected-party dealing. CISIAM did not exercise independent investment discretion, skipped adequate due diligence, and failed to identify or challenge the red flags. It also let the fund breach its own investment restrictions/ objectives and had no effective risk identification, management, or monitoring framework. As Mr. DUIGNAN Michael, SFC Director of Enforcement, said: “Fund managers must remain vigilant and must not allow their services to be used as a conduit for facilitating misconduct. Before proceeding with a proposed fund arrangement, a fund manager should critically assess an investor driven proposal for potential red flags and ensure that any legitimate concerns have been satisfactorily addressed. Those who fail to make reasonable enquiries may face serious regulatory consequences.” *For more details, please click on the Statement of Disciplinary Action for CISIAM’s case. SIGNIFICANCE: This SFC has moved from guidance to enforcement on its long-standing rule that a licensed asset manager may not act as a passive execution conduit for client-driven, structurally complex arrangements and the penalty lands on both the licensed corporation and its senior individuals, even when an institutional client hands a detailed trade idea to the fund manager, the licensed corporation still owe the fund independent investment judgement. “We just followed the client’s instruction” is explicitly rejected by the SFC as a defence. 8. SFC reprimands and fines Bright Smart Securities International (H.K.) Limited HKD 2.8 million for internal control failures in monitoring suspicious trades On 27 July 2026, the SFC reprimanded and fined Bright Smart Securities International (H.K.) Limited ( BSSIHK ) ( CE NO: AEZ575 ) HKD 2.8 million for failing to maintain adequate and effective internal controls to monitor and detect client wash trades . From 01 November 2023 to 13 September 2025, BSSIHK’s weak controls allowed 1,021 pairs of wash trades across 615 clients accounts, involving 763 stocks and warrants. Before March 2024, BSSIHH relied mainly on post-trade monitoring and manual review, so clients could complete wash trades before detection. On March 2024, BSSIHK introduced a pre-trade interception arrangement, but it was manual, not automated, and only triggered after a second instance of wash trading was already detected. However, this fix was still inadequate. *For more details, please click on the Statement of Disciplinary Action for BSSIHK’s case. SIGNIFICANCE This BSSIHK case is significant to every SFC licensed corporation because it reframes wash-trades surveillance from a back-office nice-to-have into a core licensing obligation under the Code of Conduct. The SFC did not allege BSSIHK itself traded fraudulently, it penalized the broker for letting clients do it through deficient controls. That distinction is what makes the precedent matter to all licensees. A licensed corporation is responsible for maintaining the system that would have prevented the client abuse, independent of intent. 9. SFC reprimands and fines Luk Fook Securities (HK) Limited HKD 2.1 million for inadequate cybersecurity control to fend off cyberattack On 28 July 2026, the SFC has reprimanded and fined Luk Fook Securities (HK) Limited ( LFSHK ) ( CE No: ACU547 ) HKD 2.1 million for failing to maintain adequate and effective cybersecurity controls, a lapse that left LFSHK unable to withstand a 19 September 2022 ransomware attack and took roughly three weeks to fully recover core systems. Cybersecurity System Deficiencies on LFSHK Insufficient Network Security Controls Inadequate Controls over Remote Access Inadequate User Access and Privileged Account Management Poor Password Management Practices Use of Unsupported Legacy Systems Lack of Control over External Device Security Outdated Antivirus Protection Insufficient Cybersecurity Awareness Training *For more details, please click on the Statement of Disciplinary Action for LFSHK’s case. SIGNIFICANCE Cyber resilience is a Code of Conduct obligation, not an IT-department footnote. Senior management owns the design, testing and currency of controls outdated patches, unencrypted secrets, and “we restored in phases” are no longer acceptable narratives. With the SFC’s newer guidance pushing automated threat detection, OTP retirement and AI-era hardening, LFSHK sets the baseline enforcement benchmark for every Type 1/ Type 7/ VATP-adjacent licensee. 10. Market Misconduct Tribunal finds Sir Dickson Poon culpable of insider dealing ahead of disclosure of HKD 1.15 billion corporate windfall On 31 July 2026, the Market Misconduct Tribunal ( MMT ) rules that Sir Dickson Poon and his vehicle equity advantage engaged in insider dealing by buying 2.76 million Dickson Concepts (International) Limited ( Dickson Concepts ) ( HK Stock Code: 113 ) shares in late 2019 while sitting on price-sensitive news: PayPal’s USD 4 billion acquisition of Honey Science Corporation would deliver HKD 1.15 billion cash into Dickson Concepts, a gain of HKD 929 million over book value. He withheld the information from the board until late December, causing both personal trading violations and a corporate disclosure failure under Section 270 and Section 307B of the SFO. The MMT did not find Pearson Poon, also an executive director, liable for the company’s breach since he only relied on his father and the senior management to assess price sensitive information. As Mr. DUIGNAN Michael, the SFC’s Executive Director of Enforcement, says “The Tribunal's findings reinforce two sacrosanct principles of Hong Kong's securities market: namely, insiders, particularly senior professionals on whom others rely, must not trade while in possession of material non-public information, and listed companies must disclose price-sensitive information as soon as reasonably practicable. Since a fair and orderly market depends on investors having equal and timely access to material information, the SFC will continue to take resolute action against insider dealing and corporate disclosure failures that undermine market integrity and investor confidence.” SIGNIFICANCE This case tells every SFC licensee that MNPI must reach beneficial owners and control-person vehicles, that pre-disclosure trading is culpable regardless of issuer silence, and that reliance defences survive only with documented governance and not with organizational hierarchy. This MMT ruling is a compliance benchmark that reinforces three layers of exposure: personal trading by connected persons, institutional handling of client/MNPI, and the duty to police disclosure pipelines of listed issuers that SFC-licensed corporation advise or trade for. 11. A 26-year-old Hong Kong trader is rumoured to have embezzled HKD 150 million by trading Hynix ETFs On 27 July 2026, a 26-year-old trader at Chief Wealth Investment Limited (rumoured to be subsidiary of Chief Group) was arrested for the theft after allegedly misappropriating HKD 50 million of company funds from January to July 2026 into a margin account and used the funds to purchase CSOP 2x Leveraged SK Hynix ETF (XL2CSOPHYNIX) ( HK Stock Code: 07709 ), a double-leveraged derivative tracking the South Korean memory-chip maker. The combined effect of margin financing and the ETF’s built-in 2x daily leverage amplified losses sharply when the semiconductor sector corrected in July. The ETF had surged to a record high of HKD 193.65 per share at the end of June 2026 but plunged to HKD 52.58 by July 20, a drop of more than 72%. Due to the leveraged involved, the HKD 50 million principal translated into a marked-to-market loss approximately HKD 150 million. According to police, the positions remain open, meaning the final loss could still fluctuate with market movements. SIGNIFICANCE This case is not merely a theft case; it is a control-design failure. Paragraph 4.3 of SFC’s Code of Conduct requires licensees to prevent unauthorized trading through marker-checker fund transfers, hard pre-trade limits on margin utilization, and mandatory approval gates for leveraged products. Though Chief Wealth Investment Limited is not a licensed corporation, when a single individual can convert HKD 50 million into HKD 150 million of contingent liability without triggering any alert, the firm’s internal controls and authority-setting procedures are, by definition, inadequate. Regulatory Updates 12. SFC and CSRC hold high-level enforcement cooperation meetin g The SFC and China Securities Regulatory Commission ( CSRC ) convened for their 17 th high-level enforcement meeting in Hong Kong, attended by Mr. DUIGNAN Michael, the SFC’s Executive Director of Enforcement, and Mr. LI Yubai, the CSRC’s Director-General of the Enforcement Bureau. The meeting covered three substantive areas: sharing updates on enforcement priorities and trends in both jurisdictions, discussion of important cross-boundary enforcement cases including experience sharing on investigatory assistance, and exploration of ways to further deepen collaboration in combating cross-boundary securities crimes and misconduct. Mr. Duignan emphasised that continuing to deepen enforcement cooperation and information sharing between the two regulators will enhance effectiveness in enforcement and contribute to stable and orderly development of financial markets in both jurisdictions. SIGNIFICANCE As market integration deepens, regulatory enforcement is increasing. This meeting singles that neither regulator treat the Hong Kong-Mainland border as a shield for market misconduct. The focus on expanding information exchange means investigative lead times for cross-border market manipulation, insider trading or fraudulent disclosures will continue to shorten. Increased coordination increases probability of concurrent or joint enforcement actions spanning both jurisdictions. 13. SFC and Securities Commission Malaysia sign MoU to expand mutual recognition of funds and facilitate simplified dual IPO listing framework The SFC and the Securities Commission Malaysia ( SC ) signed a Memorandum of Understanding on 23 July 2026 to expand cross-border capital market connectivity between Hong Kong and Malaysia across two distinct channels: an expanded mutual recognition of funds ( MRF ) scheme and a new simplified dual IPO listing framework. MRF Scheme Overview The SFC and SC signed an MoU to enable Malaysian and Hong Kong funds to be offered across both markets through a streamlined authorization process. Expanded Product Scope MRF now covers non-Islamic Exchange Traded Funds ( ETFs ) (including futures-based, leverages & inverse and commodity ETFs) and REITs, significantly broadening the range of cross-border investment products. Fund Eligibility Malaysian funds must remain authorized and supervised by the SC, satisfy MRF eligibility requirements, and obtain a SC certification before applying for SFC authorization. Distribution Requirements Malaysian funds offered in Hong Kong must be distributed through SFC-licensed or registered intermediaries and appoint a Hong Kong representative in accordance with the UT code. Regulatory Cooperation The SFC and SC will strengthen supervisory cooperation through information sharing, ongoing oversight, and coordinated regulatory action to support investor protection. Market impact Allows greater cross-border capital flows, expands investment opportunities and improves connectivity between Hong Kong and Malaysian asset management markets. Expansion of Fund Eligibility in Malaysian Markets ETFs MRF now covers a wider range of Hong Kong ETFs including: Passive index-tracking ETFs Futures-based leveraged & inverse ETFs Synthetic ETFs Commodity ETFs Country-specific government bond/fixed income ETF Listed REITs Eligible Hong Kong listed REITs can be offered under the MRF, provided they satisfy minimum market capitalization, regulatory track record and public float/security holding spread requirements. Fund Structure Eligible funds may now be constituted as Open-ended Fund Companies ( OFCs ), unit trusts or other forms of collective investment schemes recognized under Hong Kong law. *For more details, please click on the Mutual Recognition of Funds (MRF) between Malaysia and Hong Kong and Cross-listings of Malaysian real Estate Investment Trust in Hong Kong . SIGNIFICANCE The introduction of new product scopes creates new distribution channels for Hong Kong and Malaysian ETF managers seeking listing venues mutually. Additionally, the simplified dual IPO framework addresses the historical dual listing process between Hong Kong and Malaysia, dramatically reducing paperwork hassles and legal costs, the pipeline of dual listings between Malaysian companies seeking access to Hong Kong’s investor base and vice versa is likely to accelerate. This positions Hong Kong as a gateway to mainland Chinese capital for Malaysian issuers and investors, while positioning Malaysia as a gateway for Southeast Asian capital for Hong Kong-listed companies. The SFC Chairman, Dr. WONG Kelvin’s framing of the two markets as “Vital financial gateways connecting global capital with Chinese Mainland and Southeast Asia” is a precise articulation of this complementarity. 14. SFC mandates phishing-resistant authentication methods for internet brokers and VATPs to protect client accounts On 09 July 2026, the SFC issued a landmark circular tightening cybersecurity rules for licensed virtual asset trading platforms ( VATPs/VASPs ) and internet brokers—driven by a sharp rise in phishing-related breaches. In 2025 alone, phishing made up 57% of all cybersecurity incidents reported to Hong Kong Computer Emergency Response Team ( HK-CERT ), with large-scale SMS phishing campaigns enabling account takeovers via man-in-the-middle attacks that intercepted OTPs. The core message is clear: OTPs sent via email or SMS are no longer acceptable for client login or device binding. The SFC is mandating a shift to Fast Identity Online ( FIDO) certified, phishing-resistant passkeys paired with robust device binding, backed by proactive threat monitoring and strict incident response obligations. Key Requirements Passkey rollout All clients must transition to passkeys within 12 months, by 8 July 2027. New clients enroll during standard KYC onboarding; existing clients with no bound device post-deadline must complete biometric, ID document, or in-person verification to set up new credentials. Device Binding Accounts must be tied to specific hardware attributes, with prohibited weak verification methods and approved checks including biometric matching, ID verification, or in-person validation. Enhanced monitoring Firms must track logins, device binding, and transactions in real time, with mandatory alerts for new device logins, passkey changes, high-risk transactions (withdrawals, contact updates, password resets), and unusual geographic or behavioural patterns. Accountability Senior management—specifically the Managers-in-Charge ( MICs ) for Overall Management Oversight and Information Technology—bear personal liability for timely implementation and preventing client losses. Larger VASPs are expected to deploy controls immediately, while all firms may continue using OTPs during the 12-month transition—but only with heightened monitoring and under close regulatory scrutiny. No deadline extensions will be granted without prior SFC approval. Beyond compliance, this is a strategic opportunity: moving away from vulnerable legacy authentication to a modern, passkey-based framework significantly reduces breach risk and builds stronger client trust—a clear competitive advantage in a crowded market. As Dr. YIP Chi-hang, Executive Director of the SFC’s Intermediaries Division, emphasized: “Protecting customer accounts requires a comprehensive approach combining prevention, detection, response, and education. Licensed companies should strengthen their first line of defence, remain vigilant, and respond promptly.” *For more details, please click on the circular. SIGNIFICANCE This circular marks a new phase in the SFC's cybersecurity regulation of licensed corporations, requiring a shift from passive defense to a proactive, comprehensive, and accountable security system. Licensed corporations should treat this as a strategic priority rather than just a matter of IT compliance, and plan and implement relevant upgrades early to avoid regulatory penalties and protect client trust. 15. SFC enhances regulatory framework for daily leveraged and inverse products to ensure orderly market trading On 24 July 2026, the SFC issued an update on regulatory framework for daily leveraged and inverse ( L&I ) products authorized for retail sale in Hong Kong. The SFC now permits L&I products with leverage ratios other than the traditional fixed arrangement of 2x for leveraged products and -2x for inverse products. Product providers may propose more tailored daily rebalanced leverage, subject to SFC approval. Item New Requirement Expanded Product Scope Moves beyond traditional Index L&I Products to include Single Stock L&I (initially offshore mega-caps, now including HK-listed mega-caps per 2026 updates) and Defined Outcome Funds (options-based, capped upside/downside). Stricter Naming & Branding L&I Products cannot be called "ETFs." Mandatory formats include "Daily (2x)" and distinct "L" or "I" prefixes with unique stock code ranges on HKEX. Flexible Leverage Structure Introduces dynamic leverage (e.g., dropping from 2x to ~1.1x during stress). Providers must publish the next day’s target leverage on the product/HKEX websites daily after market close. Capacity Monitoring & BCP Continuous monitoring of swap/broker capacity is now a live obligation. For Single Stock L&I: requires proven track record, robust BCPs with specific triggers (volatility, capacity), and pre-agreed stop-loss mechanisms. Enhanced Disclosures Heavy emphasis on Product KFS warnings (not for long-term holding, roll costs, volatility). Mandates a Performance Simulator (except for pure delta-one) with historical data and clear narratives. Market Making & Margin Zero Tolerance on Market Makers: If all market makers resign, the product must terminate. HKEX monitors performance strictly. No Margin Financing: HKEX advises against providing margin financing for these products. Distribution Obligations Reaffirms application of Code of Conduct 5.1A–5.3 (Derivative Products). Emphasizes investor education, staff training, and acting in the client’s best interest (prohibiting gearing-on-gearing). *For more details, please click on the revised circular. SIGNIFICANCE This circular is a market-development gesture with investor-protection strings attached. Issuers get a path to Single Stock L&I and Defined Outcome funds; distributors get a wider shelf. In return, everyone in the chain absorbs tighter naming rules, daily leverage transparency, capacity-reporting duties, BCP obligations for single-stock products, and a distribution regime that threats these instruments as sophisticated trading tools mis-sold to buy-and-hold clients at the firm’s own risk. Early consultation with the Investment Product Division is advised not because the SFC is being polite, but because the facts-and-circumstances calls, what counts as “highly liquid mega-cap”, what leverage a volatile single stock can bear, how a Defined Outcome fund discloses barriers events, will define whether your authorization sails through or stalls. [End of ComplianceOne Newsletter – July 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

在全球經濟充滿變數的大變局下，企業對於跨境資產配置、風險管理及資金靈活調配的需求日益迫切。 南向通擴容與黃金清算系統上線： 金融機構的多牌照合規策略 隨著「南向通」年度投資淨額提升至8,000億元、離岸人民幣流動性加碼至5,000億元，以及香港黃金中央清算系統正式試營運，香港正加速轉型為債券、黃金、大宗商品全面發展的多元化金融中心。金融機構應如何評估多牌照佈局與跨境合規策略？ 政策解讀 · 香港金融基礎設施的多維度升級 中國人民銀行行長潘功勝於固定收益及貨幣峰會上明確表示，中央將全力支持香港建設多元化金融市場體系。與此同時，特區政府推動的 香港黃金中央清算系統亦已正式投入試營運 。 香港正加速從傳統的「以股票見長」架構，蛻變為綜合性的全球資產交易與清算樞紐： 「南向通」大幅擴容： 年度投資淨額由5,000億元 提升至8,000億元 ，債券將納入回購支持，產品範圍拓展至港幣和人民幣債券相關產品。 黃金與大宗商品新賽道： 隨著黃金中央清算系統試營運及境外黃金交割倉庫的設立，兩地將實現黃金交割與交儲互通，未來將推出更多以人民幣計價的大宗商品期/現貨產品。 風險管理工具落地： 香港不久將 上線五年期離岸人民幣國債期貨 ，債券通公司亦將升級為提供債券、貨幣、外匯等服務的綜合性金融交易平台基礎設施。 人民幣流動性加碼： 人民幣業務資金安排規模由2,000億元 大幅增加至5,000億元 ，全面充實離岸市場流動性。 商業洞察 · 金融機構的「多牌照」合規佈局 這一輪由基礎設施驅動的變革，影響範圍遠超單一領域。金融機構需要從更全面的視角評估牌照組合與跨境合規架構： 固定收益與證券交易（1號牌）： 8,000億元南向通額度及國家外匯儲備配置的增加，將直接帶動債券二級市場交易量。持有 第1類（證券交易）牌照 的金融機構需提前做好交易系統與風控流程的對接。 期貨與大宗商品交易（2號牌）： 隨著國債期貨上線、黃金中央清算系統營運及人民幣大宗商品產品的推進，市場對 第2類（期貨合約交易）牌照 的需求將迎來實質性增長。 資產管理多元化（9號牌）： 配合五年期國債期貨等對沖工具的推出，持有 第9類（資產管理）牌照 的機構需積極儲備具備固定收益及衍生品經驗的負責人員（RO），優化跨境資產配置。 跨境清算與 AML 合規： 多資產、跨市場的資金往來更加頻繁，金融機構必須建立更高標準的跨境清算合規體系、反洗錢（AML）審查及風險防控機制。 ⚖️ 天匯合規（ComplianceOne Consulting）專業支持 面對多元化金融轉型， 天匯合規 為您提供全生命週期的合規護航： 多牌照申請： 證監會 1、2、4、9號法團牌照的規劃、架構設計與 RO 「適當人選」評估。 跨境合規維護： 「南向通」及大宗商品交易場景下的持續合規諮詢與證監會現場審查（SFC On-site Inspection）指導。 綜合企業服務： 配合家族辦公室及離岸市場政策，提供基金設立、信託註冊及 TCSP 牌照申請。 🔗 深入了解多牌照申請與合規指引： https://complianceone.cn/services 歡迎於後台留言或透過官方渠道聯絡天匯合規專家團隊，獲取初步架構評估建議。 [完結 - 南向通擴容與黃金清算系統上線：金融機構的多牌照合規策略] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The article is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

「內地企業出海專班」（下稱「出海專班」）於 2025 年 10 月正式成立。這是一個由特區政府主導的高層次、跨部門協作平台，旨在招攬內地企業並提供一站式支援。 天匯合規：市場資訊 內地企業「出海專班」：背景、發展與專業落地實務 (2026年5月4日) 一、背景：國家戰略下的「增值超級聯繫人」 隨著內地企業從「國內競爭」轉向「全球佈局」，香港作為國家「雙循環」戰略的重要交匯點，其角色已由傳統的窗口轉變為具備高度專業能力的「增值超級聯繫人」。為了系統化支援內地企業利用香港優勢開拓國際市場，行政長官在《2025年施政報告》中提出建立專門機制，統籌全港資源協助企業「走出去」。 「內地企業出海專班」（下稱「 出海專班 」）於 2025 年 10 月正式成立。這是一個由特區政府主導的高層次、跨部門協作平台，旨在招攬內地企業並提供一站式支援。在這一政策框架下，如天匯合規等深耕本土的專業合規顧問機構，扮演著將政策轉化為執行方案的關鍵角色，確保企業在享受政策紅利的同時，精準對接國際監管標準。 二、高層架構：跨部門協作與專業引領 出海專班由商務及經濟發展局（商經局）局長丘應樺擔任督導，並成立了「出海專班督導委員會」，成員涵蓋了香港金融、貿易及監管的核心力量。 這種「全政府」式的方法，確保企業能迅速對接到所需的政府資源。然而，企業在落地過程中面臨的具體合規細節——例如信託架構設立、公司秘書維護及持牌申請——則需要像天匯合規這類具備持牌信託或公司服務提供者 (TCSP) 身份的專業服務商來具體執行，以彌合行政框架與商業運作之間的縫隙。 三、 發展歷程：從戰略共識到精準落實 出海專班成立以來，透過一系列高規格活動，快速推進其服務網絡： 2025年12月： 專業服務出海平台啟動 由律政司推動、商經局支持的「香港專業服務出海平台」正式啟動。這標誌著香港的法律及合規行業開始協同作戰。天匯合規在此背景下，積極透過其一站式合規解決方案，支援內地企業在港設立總部並進行海外擴張，提供包括反洗錢 (AML) 監控及企業治理在內的深度支援。 2026年2月： 部省級合作新高度 商經局與國家商務部簽署了《關於加強海外綜合服務領域交流合作諒解備忘錄》。這項協議旨在促進內地出海企業與香港專業機構加強合作。作為業界領先的合規專家，天匯合規致力於落實此備忘錄的精神，透過專業的監管諮詢與「出海專班」的政策指引相結合，提升內地企業在國際市場的適應能力。 2026年3月： 北京研討會與一站式資訊上線 投資推廣署正式推出「出海專班」專題網站。隨之而來的是對高質量專業服務的需求激增。天匯合規憑藉對 SFC 牌照申請、公司架構優化及跨境稅務合規的專業見解，成為內地企業落實「走出去」藍圖時信賴的商業夥伴。 四、 目標與願景：構建全球發展的「避風港」與「助推器」 出海專班的核心價值在於「精確匹配」與「全程支持」。展望未來，特區政府將繼續加強政策引導，而天匯合規將繼續發揮其專業合規顧問的職能，將複雜的監管要求轉化為高效的營運路徑。 透過「政府平台+專業機構」的雙重保障，我們助力內地企業將香港打造為不可替代的全球總部基地，實現世代傳承與穩健增長。 參考資料 香港特別行政區政府。 (2026年3月20日)。〈香港營商優勢賦能內地企業出海研討會在北京舉行〉[新聞公報]。 取自： https://www.info.gov.hk/gia/general/202603/20/P2026032000232.htm 香港特別行政區政府律政司。 (2025年12月13日)。〈「香港專業服務出海平台」正式啟動 支援內地企業出海邁向新階段〉[新聞公報]。 取自： https://www.doj.gov.hk/tc/community_engagement/press/20251213_pr1.html 新華社 / 中央人民政府駐香港特別行政區聯絡辦公室。 (2026年3月23日)。〈香港特區政府投資推廣署正式推出內地企業出海專班專題網站〉。 取自： http://big5.locpg.gov.cn/20260323/7889fc869007455880052fe575e3d005/c.html 香港特別行政區政府商務及經濟發展局。 (2025年11月6日)。〈「香港：內地企業出海首選平台」推介大會在上海舉行〉[新聞公報]。 取自： https://www.cedb.gov.hk/tc/news/press_release/2025/pr06112025a.html 香港特別行政區政府。 (2025年10月)。《行政長官2025年施政報告：齊改革同發展 惠民生建未來》[第80條]。 取自： https://www.policyaddress.gov.hk/2025/tc/p80.html 投資推廣署 (InvestHK)。 (2025年)。〈內地企業「出海專班」督導委員會舉行首次會議〉。 取自： https://www.investhk.gov.hk/zh-hk/news/goglobal-task-force-steering-committee-holds-first-meeting/ [完結 - 天匯合規最新市場資訊 | 內地企業「出海專班」：背景、發展與專業落地實務 - (2026年5月)] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The article is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

The topics discussed in this monthly newsletter for Licensed Corporations are as follows: ComplianceOne Newsletter – August 2026 The topics discussed in this monthly newsletter are as follows: Market News SFC welcomes NFRA’s announcement for supporting Mainland insurers to invest in Hong Kong ETFs under Stock Connect Stronger Mainland connectivity reinforces Hong Kong’s leading role as China assets gateway: SFC Quarterly Report Enforcement News SFC obtains 13-year disqualification orders against former top executives of China Candy Holdings Limited for corporate malfeasance SFC obtains six-year disqualification order against former executive director of National United Resources Holdings Limited over fictitious transactions Former SFC staff member charged following joint investigation with ICAC SFC revokes Ernest Chan Tsz Kin’s licence and bans him for 10 years Markets News 1. SFC welcomes NFRA’s announcement for supporting Mainland insurers to invest in Hong Kong ETFs under Stock Connect On 18 August 2026, the SFC welcomed the NFRA's announcement supporting Mainland insurance funds to invest in Hong Kong ETFs under Stock Connect, enriching their offshore asset allocation options through Hong Kong. SFC Chairman Dr Kelvin Wong thanked the NFRA for fostering financial connectivity, noting the policy reflects the Nation's commitment to high-quality financial liberalisation. CEO Ms Julia Leung said the policy will bring more development opportunities to Hong Kong's asset management industry and consolidate Hong Kong's position as a leading wealth management hub. SFC Executive Director Ms Elisa Ng joined a Hong Kong delegation led by Secretary for Financial Services and the Treasury Christopher Hui in Beijing to meet NFRA Vice Minister Mr Xiao Yuanqi on coordinated capital market development. 31 Hong Kong ETFs are eligible for southbound Stock Connect trading (market cap: HKD 343.6 billion as of 31 July 2026). Southbound turnover grew 59% year-on-year to HKD 780.7 billion in January–July 2026, about 7% of total turnover. SIGNIFICANCE: This opens a substantial new channel of Mainland insurance capital into Hong Kong ETFs. Licensed corporations, particularly asset managers and ETF providers are encouraged to assess ETF product eligibility for southbound trading and ensure compliance infrastructure can handle increased Mainland participation. Furthermore, licensed corporations need to review their distribution strategies to engage Mainland insurance institutions and monitor further NFRA and SFC policy developments on mutual market access. 2. Stronger Mainland connectivity reinforces Hong Kong’s leading role as China assets gateway: SFC Quarterly Report On 26 August 2026, the SFC published its Quarterly Report for the quarter ending June 2026, highlighting strong growth across Hong Kong's capital markets driven by offshore product breakthroughs, sustained Stock Connect inflows, and vibrant IPO activity. Category Metric Figure YoY/Note RMB Rates & Offshore Hedging 5 Year China Govt Bond Futures Approved First offshore CGB futures Swap Connect ADV RMB 284 billion per day +50% YoY Swap Connect cumulative IRS notional RMB 13.3 trillion - Stock Connect/ Southbound Consecutive months net inflow 34 months Longest streak on record Cumulative net inflow since launch HKD 5.4 trillion - Southbound share of HK ADV 22% - IPO/ Equity Funding Q2 IPO funds raised HKD 100 billion +12% YoY A-share à H-share IPOs 9 issuers >HKD 50 billion raised Specialist tech + biotech IPO funds - +420% YoY Authorized ETFs/ L&I Total market cap (ETFs & L&I) HKD 756.3 billion +43% YoY Tokenization/ VA 15 Tokenized retail products AUM HKD 10.3 billion +280% YoY 11 VA spot ETFs market cap USD 451 million +55% since launch Licensing/ LC Base License Applications 2,456 +9% YoY Licensed Corporations +5% YoY Headcount Licensed Individuals +5% YoY Headcount Enforcement/ Supervision Auditor compensation settlement HKD 1 billion pot Misleading financials case Mainland-investor account-opening review Completed Extra KYC circular issued SFC RedNote followers >22,000 Anti-scam outreach *For details, please refer to the SFC Quarterly Report dated 26 August 2026. Enforcement News 3. SFC obtains 13-year disqualification orders against former top executives of China Candy Holdings Limited for corporate malfeasance On 6 August 2026, the SFC obtained 13-year disqualification orders in the Court of First Instance against three former top executives of China Candy Holdings Limited (“ China Candy ”) (HK Stock Code: 8182) for their involvement in schemes that substantially overstated the company's cash and bank balances by falsifying accounting records, misleading the auditors, and concealing the company's true financial position in its 2016 interim report and annual report, overstating the figures by RMB 38.1 million and RMB 43.48 million respectively amounting to 87% and 97% of the reported balances. The three former top executives subject to the disqualification orders are: Mr XU Jinpei, former chairman and executive director; Ms HONG Yinzhi, former executive director, chief executive officer and compliance officer; and Mr WANG Zhihong, former chief financial controller and compliance officer. Under the orders, they are prohibited, without leave of the Court, from acting as directors, liquidators, receivers or managers of the property or business of any listed or unlisted corporation in Hong Kong for 13 years. The Court also ordered the trio to pay the SFC's costs in the proceedings. As Mr Michael Duignan, SFC’s Executive Director of Enforcement, said: "Accurate corporate financial reporting is fundamental to market integrity and investor confidence. Senior executives, including finance professionals who are not directors, will be held accountable for misdeeds involving falsifying records, distorting financial statements, facilitating misconduct, or turning a blind eye to serious irregularities. Those entrusted with safeguarding corporate integrity but undermine it instead risk being removed from positions of corporate responsibility for an extended period." *For more details, please refer to the Court of First Instance’s judgement on China Candy’s case. SIGNIFICANCE: This case is significant to every SFC licensed corporation because it confirms that personal accountability under section 214 of the SFO extends beyond directors to compliance officers and finance professionals who are not board members. The 13-year disqualification period — close to the statutory maximum of 15 years — sends a clear signal that the SFC will pursue the most severe sanctions against those who falsify financial records, mislead auditors, or turn a blind eye to serious irregularities. Licensed corporations should use this case to reinforce training on financial reporting integrity, ensure their compliance function has genuine independence, and verify that internal controls prevent the fabrication of bank statements and accounting records. Firms should also confirm that external auditors have unrestricted access to source documents and are not supplied with falsified information. 4. SFC obtains six-year disqualification order against former executive director of National United Resources Holdings Limited over fictitious transactions On 13 August 2026, the SFC obtained a six-year disqualification order against Mr TIAN Songlin (“ Tian ”), former executive director of National United Resources Holdings Limited (“ NUR ”), for breaching his fiduciary duties by recklessly involving a NUR subsidiary in fictitious transactions. Tian was disqualified for six years from managing any listed or unlisted corporation in Hong Kong and ordered to pay the SFC's costs in the proceedings. The order was made under the Carecraft procedure based on an agreed statement of facts and agreed proposed orders. The case involved two back-to-back fuel oil transactions in 2015 totalling USD 75.46 million between NUR’s subsidiary, NUR Clean Energy Investment Limited (“ NUR Clean ”) and two external parties. The transactions were fictitious, the purported supplier and customer were controlled by NUR or connected parties, the bills of lading were not genuine, and funds circulated among related parties before returning to NUR. The SFC has also accused three other former directors and senior management of NUR of serious misconduct. They are currently unlocatable: Respondent Title/Designation SFC’s Allegations Mr LI Hui Former Executive Director Involved in binding NUR Clean to the fictitious transactions. Mr FENG Yongming Former Executive Director Involved in approving related payments totalling over HKD 302 million. Mr LI Tao Alleged de facto/shadow controller of NUR Orchestrated the fictitious transactions and controlled the related fund movements. In November 2025, the SFC obtained a three-year disqualification order against Mr LO Ka Wai, another former executive director of NUR, who admitted to negligence in committing NUR Clean to the fictitious transactions. Proceedings against the three unlocatable respondents are ongoing. *For details, please refer to the Court of First Instance's judgement (Case No: HCMP 896/2022) SIGNIFICANCE: This case demonstrates the personal accountability of executive directors under section 214 of the SFO for fictitious transactions executed through subsidiaries. The Court will impose more severe sanctions on those who actively facilitated misconduct over those merely negligent in oversight. This case shows how essential having a governance control, active board engagement, robust payment authorization processes, and accurate disclosure practices. 5. Former SFC staff member charged following joint investigation with ICAC On 16 August 2026, the SFC announced that the Independent Commission Against Corruption (“ ICAC ”) has charged a former SFC manager with obtaining access to a computer with a view to dishonest gain, following a joint SFC-ICAC investigation. The staff member's employment was terminated immediately upon her arrest, and the SFC has cooperated fully with the ICAC. The SFC emphasized that protecting highly confidential regulatory information and enforcing strict controls over internal system access are core institutional responsibilities. It has launched an ongoing comprehensive review of the risks and internal governance issues highlighted by the case. The SFC reiterated its zero-tolerance policy against misconduct, holding staff to the highest standards of integrity, professional conduct, and confidentiality that is consistent with the regulatory requirements it imposes on licensed corporations. As court proceedings and related investigations remain active, the SFC is unable to comment further on the specifics of the case. SIGNIFICANCE: This case is a stark reminder that insider threats, particularly unauthorized access to confidential regulatory information can originate within the regulator itself. For SFC-licensed corporations, the case underscores the importance of implementing robust access controls and monitoring systems for sensitive data; maintaining strict segregation of duties to prevent any single individual from exploiting system access; conducting regular reviews of internal governance and risk management frameworks; and enforcing zero-tolerance policies for misconduct at all levels of the organization. Licensed corporations should take this opportunity to review their own information security protocols, ensuring that access to confidential client and regulatory data is appropriately restricted and monitored, and verify that their internal whistleblowing and reporting mechanisms are functioning effectively. 6. SFC revokes Ernest Chan Tsz Kin’s licence and bans him for 10 years On 24 August 2026, the SFC revoked the licence of Mr Ernest Chan Tsz Kin (“ Chan ”), former responsible officer (RO) of Keptain Securities and Asset Management Limited (“ Keptain ”), and banned him from re-entering the industry for 10 years for window dressing Keptain's financial resources between June 2016 and March 2018. Chan caused Keptain to window dress its liquid capital in 15 financial returns submitted to the SFC, creating the false appearance of compliance with the liquid capital requirement under the Securities and Futures (Financial Resources) Rules (“ FRR ”). In each return, Chan deposited cheques (issued by himself or connected companies) at month-end to inflate Keptain's liquid capital, but the cheques were dishonoured a few days later before the returns were submitted. Excluding these dishonoured cheques, Keptain would have breached the required liquid capital level every reporting month. Despite liquid capital deficits ranging from HKD 731,000 to HKD 3,473,000 over 20 months, Keptain did not notify the SFC as required under the SFO and FRR. The SFC considered that Chan's conduct was intentional, called into question his honesty and integrity, and that he was directly responsible for Keptain's window dressing. Mitigating factors included Keptain having no active clients during the Relevant Period and Chan's cooperation with the SFC. *For details, please refer to the SFC Statement of Disciplinary Action for Ernest Chan Tsz Kin. SIGNIFICANCE: This case highlights the SFC's zero-tolerance approach to window dressing of financial resources. The SFC mandates all licensed corporations including the RO who submits the FRR that the liquid capital calculations must reflect genuine, settled funds (cheques that are subsequently dishonoured must not be included) in the liquid assets. The ROs bear personal responsibility for the accuracy of financial returns submitted to the SFC, and signing off on false returns constitutes serious misconduct. As per FRR rules, licensed corporations must notify the SFC immediately when its liquid capital falls below required thresholds, failure to do so is a separate breach. The SFC will impose severe sanctions such as licence revocation and a 10-year ban even if there were no clients harmed from the incident. ROs should review their financial resources reporting processes, ensure robust controls over month-end capital calculations, and implement cheque clearing verification before submitting financial returns. [End of ComplianceOne Newsletter – August 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

在全球經濟充滿變數的大變局下，企業對於跨境資產配置、風險管理及資金靈活調配的需求日益迫切。 42.2萬億元歷史新高！香港資產管理業加速增長，金融機構如何精準佈局？ 摘要： 香港證監會發布《2025年資產及財富管理活動調查》，本港管理資產總值按年大幅攀升20%至42.2萬億港元。面對資金流入與非香港投資者佔比高企的紅利期，金融機構如何合規高效地佈局核心的「9號牌（資產管理）」及家族辦公室業務？ 香港作為全球頂級國際金融中心與離岸人民幣樞紐的地位，在最新的官方數據中再次得到了有力印證。 近日，香港證券及期貨事務監察委員會（證監會）發表了《2025年資產及財富管理活動調查》，報告指出，本港管理資產總值（AUM）按年顯著增長 20% ，達到 42.2萬億港元 ，刷新歷史紀錄。這一數據相較於2021年創下的35.5萬億元紀錄增幅達19%，充分反映出香港資產及財富管理業務在2025年呈現出強勁的加速增長態勢。 數據洞察：國際資本的重塑與多元化策略 縱觀整份調查報告，香港財富管理市場呈現出以下三個核心趨勢，極具商業戰略參考價值： 1. 淨資金流入呈爆發式增長 報告顯示，本港淨資金流入按年飆升 1.93倍 至 2.1萬億元 ，錄得連續第三年上升。在各大業務板塊中，資產管理及基金顧問業務管理資產增長19%至31萬億元；而私人銀行及私人財富管理業務的管理資產更是大幅飆升 24% 至12.9萬億元，顯示出高淨值群體對香港財富管理生態的深厚信心。 2. 非香港投資者結構保持穩健 截至2025年底，源自非香港投資者 的資產高達 26萬億元 ，佔整體資產及財富管理業務的 63% 。其中，海外投資者資產達22.2萬億元（佔54%），而香港及內地投資者則分別佔37%及9%。這表明香港依然是連接國際資本與中國機遇的「超級聯繫人」。 3. 多元化資產配置與固定收益市場崛起 過去5年間，非股票投資的比例上升了7個百分點至 58% 。這反映出本港資產管理人正面對瞬息萬變的全球市況，積極採取多元化策略應對，同時也彰顯了香港固定收益及貨幣市場的日益壯大。 戰略佈局：9號牌（資產管理）的合規挑戰與機遇 隨着市場規模與資產淨值的雙重增長，行業准入與從業人數也在同步擴張。數據顯示： 在香港獲發牌進行資產管理（第9類受規管活動）的機構數目上升7%，達到 2,358家 。 獲發牌進行第9類受規管活動的人數增長5%，達到 15,747人 。 獲註冊開放式基金型公司（OFC）的數目亦錄得 43% 的顯著升幅。 財政司司長陳茂波先生亦指出，在國家「十五五」規劃下，香港將持續促進更多金融產品創新、提升市場深度廣度與效率。 在這一背景下， 第9類牌照（9號牌） 作為進行資產管理和全權委託投資組合的核心資質，已成為金融機構與跨國團隊爭相佈局的戰略要地。然而，隨着資產規模擴大與監管政策的優化，證監會對於持牌法團（Licensed Corporations）及核心負責人員（RO）的專業適格性、架構合規性及風險控制提出了更高、更細緻的要求。 天匯合規：您可信賴的金融合規與牌照顧問 面對龐大的全球資本機遇與日益嚴格的監管環境，如何確保牌照申請的高效推進以及持牌後的合規運營，是企業穩健發展的基石。 作為業內專業的金融合規諮詢機構， 天匯合規 緊貼最新市場趨勢與政策紅利，為擬持牌機構及現有持牌法團提供覆蓋全生命週期的專業支持。 為了助您全方位對接本港金融機遇，天匯合規打造了以下核心服務矩陣： ⚖️ 金融牌照申請與架構設計 我們提供包括 證監會法團牌照（重點聚焦於第9類資產管理牌照，以及1/4/6號牌等） 、香港交易所參與者及交易權的專門申請諮詢。同時，協助跨國團隊辦理金錢服務經營者（MSO）、保險經紀（IA）牌照申請，以及境外的美國 MSB 註冊和 MTL 牌照申請。 🔍 監管合規與持續日常維護 拿牌只是起點，合規運營才是長久之道。天匯合規為持牌法團提供 持續合規服務 ，協助企業優化內部控制流程，並能針對證監會現場審查（SFC On-site Inspection）提供模擬審查與專業應對指導。此外，我們亦提供網上持續培訓（CPT）及監管能力評核考試的技術支持。 🏢 企業服務與離岸架構設立 迎合香港對家族辦公室（Family Office）的大力支持及開放式基金型公司（OFC）的增長趨勢，我們為客戶提供 家族辦公室成立服務、基金設立服務及信託公司註冊 。同時涵蓋 TCSP 牌照申請、會計記帳及前沿的 ESG（環境、社會及管治）諮詢與報告服務。 天匯合規：您可信賴的金融合規與牌照顧問 在全球資產管理加速增長的黃金期，精準且合規的戰略推進將為企業贏得實質性的先發優勢。 若您的機構正計劃在香港申請 9號資產管理牌照 ，或需要評估現有業務的合規架構，歡迎訪問我們的專屬頁面了解更多技術細節與合規指引： 🔗 https://complianceone.cn/services/fl1 您亦可通過本公眾號後台或官方渠道與我們的資深合規專家取得聯繫，我們將為您提供初步的架構評估與專業建議。 [完結 - 42.2萬億元歷史新高！香港資產管理業加速增長，金融機構如何精準佈局？] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The article is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

天匯合規顧問有限公司（Compliance One）非常榮幸地宣布，我們的客戶 快付香港有限公司（KUAIPAY HK LIMITED） 已於 2026 年 8 月 順利獲得由香港海關頒發的金錢服務經營者牌照（MSO License）！ 【成功案例分享】天匯合規助力「快付香港」順利獲發香港金錢服務經營者（MSO）牌照(2026.08) 【喜報】熱烈祝賀快付香港有限公司順利獲發香港 MSO 牌照！ 天匯合規顧問有限公司（Compliance One）非常榮幸地宣布，我們的客戶 快付香港有限公司（KUAIPAY HK LIMITED） 已於 2026 年 8 月 順利獲得由香港海關頒發的金錢服務經營者牌照（MSO License）！ 本次牌照申請歷時 14 個月（2025 年 6 月至 2026 年 8 月）。在天匯合規專業團隊的全程護航下，快付香港成功順利通過海關嚴格的合規審查與評核，邁向全球跨境支付與金融科技發展的新里程！ 客戶背景與強大內地持牌資質 強強聯手，戰略協同 ：快付香港有限公司在香港設立本地辦事處，致力於為全球個人及企業客戶提供優質、安全、便捷的跨境支付與貨幣兌換服務。 頂尖內地支付牌照背書 ：快付香港與內地領先的電子支付企業—— 快錢支付清算信息有限公司（簡稱「快錢公司」） 達成戰略協同。快錢公司成立於 2004 年，是中國內地首批榮獲中國人民銀行頒發《支付業務許可證》（ 許可證編號：Z2000831000014 ）的知名支付企業，具備互聯網支付、移動電話支付及全國銀行卡收單等全方位服務資質，累計服務逾 4 億個人用戶及 650 萬商業合作夥伴。依託強大的產業協同與合規實力，快付香港將持續拓展東南亞、歐美等全球市場。 香港 MSO 行業趨勢與合規挑戰 自 2019 年起，香港海關對金錢服務經營者（MSO）的監管與審查顯著收緊： 持牌數量驟減 70%：本地持牌機構數量已由 2020 年初的 2,500 多間 急劇減少至現時的 600 多間。 轉型科技驅動：多數機構未能成功續牌，主因在於打擊洗錢（AML）政策漏洞、人員配置不足及缺乏合規工具。與此同時，行業正加速從傳統模式演變為科技驅動、規範化運營的國際性跨境支付業務。 天匯合規的全方位顧問服務 作為香港市場佔有率最高、累積處理超過 200 宗 MSO 牌照申請及續牌的專業顧問團隊，天匯合規為快付香港提供了覆蓋全流程的專業服務，包括： 一站式 MSO 牌照申請顧問 ： 針對高級管理人員「適當人選」、業務流程及營業處所規範提供事前合規建議； 按海關最新指引精心審閱及編寫《業務計劃》（Business Plan）與《打擊洗錢及恐怖分子資金籌集政策》（AML/CFT Policy）； 代表客戶向海關遞交申請、協助實地考察，並全期跟進海關查詢直至審批通過。 海關會前培訓與《能力評核》模擬試題 ： 提供獨家開發的 7 大單元《能力評核》模擬試題庫，協助客戶深入掌握監管要求； 提供海關會面前培訓及「常見問題拆解」，確保會面表現符合監管預期。 專屬反洗錢（AML/CFT）合規培訓 ： 為快付香港及其員工提供不少於 2 小時的專業合規培訓（涵蓋盡職審查、風險為本原則、可疑交易識別等），並頒發培訓證明證書。 關於天匯合規 天匯合規憑藉在金融服務業的豐富經驗，多次獲得監管機構及關員讚賞。無論是 MSO 新牌照申請、牌照續期、反洗錢培訓，還是模擬考試系統支持，天匯合規均能為您的業務發展保駕護航！ 如有任何 MSO 牌照或合規諮詢需求，歡迎隨時與我們聯絡！

The topics discussed in this monthly newsletter for Licensed Corporations are as follows: ComplianceOne Newsletter – February 2026 The topics discussed in this monthly newsletter are as follows: Regulatory Updates SFC Launches Three Major Trading Initiatives to Boost Digital Asset Market Vibrancy in Hong Kong SFC Announces Key Liquidity-Focused Enhancements Under ASPIRe Roadmap to Deepen Hong Kong’s Virtual Asset Market Depth and Global Competitiveness Market News HKMA Targets Issuance of First Batch of Stablecoin Issuer Licences in March with Very Limited Number to Prioritise Prudent and Risk-Based Development Hong Kong’s Single-Family Offices total surpasses 3,380, Contributing Approximately $12.6 Billion Annually to Hong Kong’s Economy SFC Hosts Third Broker Forum to Strengthen Industry Collaboration, Address Emerging Risks, and Promote Compliant Innovation in Hong Kong’s Capital Markets Enforcement News - Intermediaries SFC reprimands and fines Kylin International (HK) Co., Limited $9 million for fund management failures Masterminds jailed up to 24 months in securities fraud case involving social media “stock tips” of alleged ramp-and-dump schemes Retail trader sentenced in SFC’s false trading case SFC obtains worldwide court orders in Hong Kong and England and Wales to freeze suspects’ assets up to HK$4.3 million in alleged insider dealing SFC bans Andy LAU Ka Ho for life for Serious Misconduct Enforcement News - Listed Companies SFC obtains compensation and disqualification orders against former SFC Reaches Settlement Agreement with Sino Wealth International Limited and Clear Prosper Global Limited for Breaches of Takeovers Code Rules Regulatory Updates 1. SFC Launches Three Major Trading Initiatives to Boost Digital Asset Market Vibrancy in Hong Kong On 11 February 2026, the Securities and Futures Commission (“ SFC ”) of Hong Kong issued a package of 3 new initiatives as part of its ongoing ASPIRe Roadmap (initially published in February 2025 ). These measures aim to enhance liquidity, expand product diversity, and strengthen Hong Kong's position as a sustainable and competitive virtual asset (“ VA ”) hub. The 3 Initiatives Announced: VA Financing to securities margin clients Licensed corporations providing VA dealing services (“ VA brokers ”) are now permitted to offer financing for VA trading to their securities margin clients. This is subject to sufficient collateral (initially including Bitcoin and Ether), prudent haircuts, concentration limits, robust governance, and investor safeguards aligned with existing securities margin financing principles. *Please refer to SFC Circular on VA dealing services issued on 11 Feb 2026 , for further information. High-Level Framework for VA Perpetual Contracts The SFC introduced a principles-based framework guiding licensed virtual asset trading platforms (“ VATPs ”) in developing and proposing perpetual contracts (“ Perp ”, leveraged instruments without expiry dates) exclusively for professional investors. Requirements emphasize transparent product design, risk disclosures, margin/liquidation mechanisms, operational controls, and market surveillance. *Please refer to the SFC Framework paper on Perp issued on 11 Feb 2026 , for further information. Aacceptance of Affiliated Market Makers on VATPs Affiliates of licensed VATPs may now act as market makers on their platforms, providing additional liquidity channels. Strict safeguards must be implemented to mitigate conflicts of interest, including information barriers, functional independence, data security, and priority for client orders. *Please refer to SFC Circular on permitting VATPs to accept affiliated market makers issued on 11 Feb 2026 , for further information. SIGNIFICANCE: In Feb 2026, Dr Eric Yip, the SFC’s Executive Director of Intermediaries delivered his speech at Consensus Hong Kong “Our structured development approach based on the ASPIRe Roadmap is essential to scaling our digital asset market. These targeted initiatives to enhance liquidity showcase the SFC’s unswerving commitment to developing Hong Kong’s digital asset market in a sustainable and collaborative manner.” *Please refer to topic 2 of this Newsletter; and Keynote speech at Consensus Hong Kong 2026 issued on 11 Feb 2026 , for further information. These targeted enhancements build on Hong Kong's pro-innovation yet risk-controlled VA regulatory ecosystem. By enabling responsible leverage, deeper liquidity provision, and broader participation (particularly for sophisticated investors), the SFC aims to improve market depth, price discovery, and investor confidence while maintaining strong protections. 2. SFC Announces Key Liquidity-Focused Enhancements Under ASPIRe Roadmap to Deepen Hong Kong’s Virtual Asset Market Depth and Global Competitiveness On 11 February 2026, Dr Eric YIP , Executive Director of Intermediaries of the SFC, delivered a keynote speech titled “All about Liquidity” at Consensus Hong Kong 2026. The address outlined the SFC’s strategic emphasis on cultivating high-quality liquidity in Hong Kong’s VA ecosystem as the next phase of development under the ASPIRe Roadmap. The roadmap structures its initiatives across several pillars, with this year’s priority placed on Pillar A (Access) and Pillar P (Products) to enhance market depth, improve price discovery, and build investor confidence through calibrated reforms and responsible innovation. Key announcements and ongoing initiatives on Pillar A and Pillar P: ASPIRe - Pillar(s) Sub-Sections Details Enhancing Accessibility - Pillar A (Access) Completion of VA licensing regimes The SFC has concluded consultation on proposals to regulate: (i) VA dealing; (ii) VA Custody; (iii) VA Advisory; and (iv) VA Management; services and is advancing the legislative process at full speed. Fast-track licensing assessments will facilitate a seamless transition to the new statutory framework upon enactment, ensuring continuity for market participants. Permitting affiliated market makers (“ AFMMs ”) Licensed VATPs may allow their affiliates to act as market makers, subject to robust safeguards including conflict-of-interest controls, information barriers, data security, functional independence, client order priority, and clear identification of market-making activities. This is expected to narrow spreads and provide more consistent liquidity. Shared order book Licensed VATPs will be enabled to integrate intra-group and global liquidity pools, giving Hong Kong investors access to deeper order books. Expanding Hong Kong’s product suite – Pillar P (Products) VA margin financing VA brokers may offer financing for VA trading to securities margin clients, anchored to the existing securities margin financing framework. Additional guardrails cover collateral quality (including use of VA as collateral), concentration limits, prudent haircuts, and governance requirements to support responsible leverage without compromising stability. VA perpetual contracts A principles-based framework has been introduced for licensed VATPs to develop leveraged perpetual contracts offered exclusively to professional investors. Key requirements include transparent product design, risk disclosures, valuation, margining and liquidation protocols, loss allocation management, and insurance-fund governance. Upcoming Initiatives under Pillar Re (Relationships) A structured communication channel between the SFC and industry innovators (operated through an appointed agent) will provide regulatory clarity, support efficient resource allocation, and facilitate exploration of new market-making models, financing mechanisms, and leveraged products. SIGNIFICANCE: The SFC’s latest initiatives reflect a mature, balanced approach to scaling Hong Kong’s VA market in a sustainable manner. By expanding access channels, broadening product offerings with appropriate safeguards, and fostering structured innovation dialogue, the regulator aims to enhance liquidity, attract global flows, and strengthen price discovery while upholding investor protection and financial stability. Market News 3. HKMA Targets Issuance of First Batch of Stablecoin Issuer Licences in March with Very Limited Number to Prioritise Prudent and Risk-Based Development During the Legislative Council Panel on Financial Affairs briefing on 2 February 2026, the HKMA Chief Executive Eddie YUE Wai-man (“ YUE ") provided an update on the implementation of the Stablecoins Ordinance (effective 1 August 2025). Upcoming license initiation plan The HKMA aims to issue the first batch of licences in March 2026 and confirmed it has received 36 licence applications for fiat-referenced stablecoin issuers and is in the final stages of assessment. HKMA state that the initial number of licences will be very less, with stability and prudence as the overriding objectives. Briefed Slides submitted to LegCo The briefing slides submitted to LegCo on 26 January 2026 (and presented on 2 February 2026) outlined the HKMA’s core functions, including maintaining currency stability under the Linked Exchange Rate System, promoting financial system stability (including the banking system), supporting Hong Kong’s role as an international financial centre, and managing the Exchange Fund. For more details of the slides, please refer to: HKMA’s PPT Presentation on 2 February 2026 ; and HKMA’s PPT Presentation submitted to LegCo on 26 January 2026 . Background Timeline of HKMA plans of Stablecoins: Date Event May 2025 Stablecoins Bill passed by the Legislative Council 1 August 2025 Stablecoins Ordinance takes effect August–September 2025 Application window open; 77 expressions of interest received (36 formal applications) 2 February 2026 HKMA Chief Executive Eddie YUE briefs LegCo Panel; confirms 36 applications under review, targets March issuance of very limited first batch March 2026 (target) First batch of licences expected to be issued SIGNIFICANCE: The HKMA’s cautious approach limiting the initial batch to a very small number of licences while placing heavy emphasis on robust risk management, particularly anti-money laundering controls and reserve asset quality, reflects a deliberate strategy to foster stable, responsible growth in the stablecoin sector. This high-bar entry threshold aims to mitigate potential financial stability risks in an emerging asset class and reinforces Hong Kong’s reputation as a trusted, innovation-friendly yet prudently regulated international financial centre. Successful issuance of the first licences in March 2026 would mark a concrete step forward in Hong Kong’s virtual asset ecosystem development, complementing parallel SFC initiatives on virtual asset trading platforms and liquidity enhancements. 4. Hong Kong’s Single-Family Offices total surpasses 3,380, Contributing Approximately $12.6 Billion Annually to Hong Kong’s Economy On 10 February 2026, the Financial Services and the Treasury Bureau (“ FSTB ”) and Invest Hong Kong (“ InvestHK ”) jointly released findings from the Market Study on the Family Office Landscape in Hong Kong , commissioned by InvestHK and conducted by Deloitte. The study estimates that 3,384 single-family offices were operating in Hong Kong as of the end of 2025, marking an increase of 681 offices (over 25%) since the end of 2023. Two major affects to the Hong Kong Market: Economic Impact: Single-family offices contribute approximately HK$12.6 billion annually to the local economy through operating expenditures alone and directly employ over 10,000 full-time professionals. When including multifamily offices and supporting service providers, the overall economic benefits are expected to be substantially greater. Hong Kong’s Wealth Management Position: As of end-2024, assets under management in Hong Kong reached approximately HK$35 trillion (about US$4.5 trillion). The city ranked second globally in the number of ultra-high-net-worth individuals as of June 2025, reinforcing its status as a leading destination for family offices. Key highlights from the announcement and study: Upcoming measures in 2026 Upcoming measures include legislative proposals in the first half of 2026 to expand preferential tax regimes for funds and single-family offices to cover additional asset classes such as precious metals, loans, private credit investments, and digital assets. Achieving the new target set out in the Chief Executive's 2025 Policy Address The Government aims to assist more than 220 family offices to establish or expand in Hong Kong from 2026 to 2028. *The target was set out in the Chief Executive's 2025 Policy . Comments from Representatives of FSTB and InvestHK Mr Christopher HUI, Secretary for Financial Services and the Treasury, attributed the sustained growth to Hong Kong’s advantages under the “one country, two systems” framework, including its role as a leading global asset and wealth management hub with predictable environment, connectivity to the mainland and the world, and supportive policies. Ms Alpha LAU, Director-General of Investment Promotion at InvestHK, highlighted strong overseas interest (particularly from Europe and Southeast Asia) in Hong Kong’s flexible investment environment, no geographical restrictions on investments under the preferential tax regime, high privacy (no general licensing requirement for single-family offices), and tax incentives. SIGNIFICANCE: The surge in single-family offices underscores Hong Kong’s strengthened position as Asia’s premier wealth and asset management hub, attracting diverse global capital through targeted policy enhancements, tax competitiveness, privacy protections, and strategic connectivity. The substantial annual economic injection of HK$12.6 billion (via operating expenditures) and direct employment of over 10,000 professionals highlight the sector’s growing role in driving local financial services growth, job creation, and broader ecosystem development. With forthcoming tax expansions (including digital assets) and ambitious growth targets, these developments reinforce Hong Kong’s appeal to ultra-high-net-worth families amid global shifts toward sustainable wealth management and intergenerational planning, further solidifying its status as a trusted international financial centre. 5. SFC Hosts Third Broker Forum to Strengthen Industry Collaboration, Address Emerging Risks, and Promote Compliant Innovation in Hong Kong’s Capital Markets On 2 February 2026, the SFC successfully hosted its third broker forum at the SFC office and online, attracting over 600 participants from the financial sector. The event served as a key platform for open dialogue between the regulator and industry participants, fostering a culture of compliance while supporting market development and financial innovation. Key highlights from the forum: For the first time, the forum included a dedicated panel discussion examining the regulatory and commercial implications of the growing prevalence of finfluencers (financial influencers) in the market. Other sessions covered important industry developments and regulatory updates, including: Latest progress on the Integrated Fund Platform; Conduct issues related to IPO sponsors (referencing the SFC’s circular issued on 30 January 2026 ); Enhanced controls for client onboarding processes and measures to prevent potential layering activities. SIGNIFICANCE: The third broker forum underscores the SFC’s proactive and collaborative approach to regulation, engaging directly with market participants to better understand industry’s challenges, support industry development and tackle emerging risks, particularly the influence of finfluencers and conduct issues in IPO sponsorship and client onboarding while promoting innovation in areas such as fund platforms and broader asset management. Enforcement News - Intermediaries 6. SFC reprimands and fines Kylin International (HK) Co., Limited $9 million for fund management failures On 9 February 2026, the SFC has reprimanded and fined Kylin International (HK) Co., Limited (CE: BCH442 ) (“ Kylin ”) HKD 9 million for multiple failures in managing private funds over a period of three years. **Kylin ceased carrying on regulated activities on 31 December 2023. Following its application, the SFC revoked its license on 22 January 2025 The misconduct occurred between August 2018 and July 2021, during which Kylin acted as the investment manager or consultant for six sub-funds of a Cayman-incorporated fund. The SFC identified failures across Five Key Areas : 1) Failed to manage and disclose conflicts of interest arising from six loans extended by it or its director to four of the sub-funds. 2) Failed to appoint an independent auditor to audit the sub-fund’s financial statements and failed to perform monthly reconciliations or regular valuations of the sub-funds’ assets. 3) Failed to implement adequate systems and controls for KYC and suitability assessment. 4) Neglected to maintain records demonstrating compliance with AML/CFT regulations. 5) Misrepresented its regulatory obligations by incorrectly informing investors that it was exempt from the suitability assessment requirement as they were classified as professional investors. *For more details of the background, please refer to the Statement of Disciplinary Action The SFC attributed the misconduct to failures by senior management, including Mr. Steven WONG Yung (former Responsible Officer and CEO) and Ms. ZHU Hong (former director and manager-in-charge). The SFC had previously taken separate disciplinary actions against WONG (March 2025) and ZHU (August 2025) . SFC Reminders for All Licensed Asset Managers Asset managers are strongly reminded to carefully review and implement the guidance set out in the circular to licensed corporations engaged in asset management business, issued by the SFC on 9 October 2024. SIGNIFICANCE: Licensed Corporations, particularly private fund managers, must ensure robust systems and controls are in place and functioning, to accurately understand and discharge their regulatory obligations, and to remind that senior management will also be held responsible for any systemic deficiencies. This high-profile SFC enforcement action reinforces the regulator's zero-tolerance stance on governance lapses, conflicts of interest, and AML/CTF weaknesses in asset management, particularly for private funds. 7. Masterminds jailed up to 24 months in securities fraud case involving social media “stock tips” of alleged ramp-and-dump schemes On 9 February 2026, the District Court sentenced two masterminds to substantial prison sentences (22 and 24 months) their wives to community service (180 and 120 hours), after convictions for securities fraud involving the shares of four Hong Kong-listed companies. Involved Individuals (here referred to as “ Defendants ”) Defendants Background Mr. LI King Hong (“ LI ”) Mastermind(s) of the Schemes Former SFC-licensed representative for Type 2 regulated activity, accredited to Core Pacific-Yamaichi Futures (H.K.) Limited until 15 January 2021 Mr. LAM Hin Fai (“ LAM ”) Mastermind(s) of the Schemes Ms. CHAN Ngai See (“ CHAN ”) Mastermind(s)’s Wives, directed by the mastermind(s) Ms. Betty HUI Pui Yan (“ HUI ”) Mastermind(s)’s Wives, directed by the mastermind(s) Case Details Between June and September 2020, LI and LAM act as the masterminds, directed CHAN and HUI to deceive an account executive at CVP Securities Limited (" CVP ") on nine occasions. They falsely represented ownership of shares in the following companies to induce CVP to place selling orders: NOIZ Group Limited (formerly Merdeka Financial Group Limited, stock code: 08163) National Investment Fund Limited (stock code: 01227) Contel Technology Company Limited (stock code: 01912) Sino Prosper (Group) Holdings Limited (stock code: 00766) Acting on information from “WeChat teachers” promoting the schemes on social media, the defendants engaged in naked short selling. They sold shares at inflated prices despite not owning them, then repurchased the shares at lower prices after subsequent declines to close their short positions. This resulted in illicit profits of HK$3.3 million while exposing CVP to significant risk of losses and undermining the integrity of the securities market. Court Order Defendants Sentenced to Mr. Li King Hong 24 months in prison Mr. Lam Hin Fai 22 months in prison Ms. Chan Ngai See 180 hours of community service Ms. Betty Hui Pui Yan 120 hours of community service *For further details, refer to SFC press releases dated 23 June 2023 , 18 August 2023 , and 12 September 2024 . SIGNIFICANCE: Account executives and compliance staffs of brokerage firms plays a critical role as the first line of defence. They must carefully verify share ownership and be vigilant against client attempts to engage in naked short selling or other deceiving practices. Apart from that, the successful outcome of this case demonstrates the effectiveness of SFC’s close collaboration with the Police in tackling financial crime to protect the integrity of our securities market. 8. Retail trader sentenced in SFC’s false trading case Following a criminal prosecution brought by the SFC, the Eastern Magistrates' Courts has sentenced Mr. NG Ka Hei to 220 hours of community service for false trading in the shares of six Hong Kong-listed companies. The court also ordered Mr. NG to pay a fine of HKD 117,715, which represents the profit gained from his illicit trading activities, as well as HKD 199,669 to cover the SFC's full investigation costs. Mr. NG made illicit profits by selling shares at artificially high prices he created through “scaffolding” and wash trading between 20 September 2022 and 24 October 2024. He placed and cancelled trading orders at increasing prices and traded between his various securities accounts as both buyer and seller. SIGNIFICANCE: The SFC will pursue criminal sanctions for market manipulation, seeking not only to punish and deter but also to fully recover illicit gains and the costs of enforcement. Robust compliance and surveillance are essential to avoid similar severe penalties. As Mr. Michael Duignan, SFC’s Executive Director of Enforcement, said: “False trading undermines investor confidence in the market. The SFC is committed to taking resolute action against such misconduct to protect market participants and uphold the integrity of Hong Kong’s securities markets . ” 9. SFC obtains worldwide court orders in Hong Kong and England and Wales to freeze suspects’ assets up to HK$4.3 million in alleged insider dealing On 24 February 2026, the SFC announced that it has secured a worldwide interim injunction order from the Court of First Instance of Hong Kong (“ HK Order ”) against: Involved Individuals Background Mr. CHAN Ching Wa (“ CHAN ”) Former Assistant Vice President in the Listing Division of the Hong Kong Exchange and Clearing Limited (“ HKEX ”) Extended relatives with LAM and CHAU Mr. LAM Cho Man (“ LAM ”) Extended relatives Mr. CHAU Chi Kwong (“ CHAU ”) Extended relatives The SFC alleges that CHAN accessed confidential and price-sensitive information about various Hong Kong-listed companies prior to their public announcements and used it for insider dealing. In parallel, the SFC initiated proceedings in England and Wales, obtaining an interim injunction order from the High Court of Justice Business and Property Courts of England and Wales (“ UK Order ”) to freeze the assets of CHAN and CHAU in that jurisdiction. This marks a first-of-its-kind action by the SFC in England and Wales, aimed at preserving assets where suspects have left Hong Kong and transferred holdings overseas. Case Details The SFC’s ongoing investigation involves 24 listed companies in total. The allegations center on insider dealing in shares of at least seven Hong Kong-listed companies: Jinmao Hotel and Jinmao (China) Hotel Investments and Management Limited (Stock code: 6139); SOHO China Limited (Stock code: 0410); Beijing Capital Land Limited (Stock code: 2868); Lifestyle International Holdings Limited (Stock code: 1212); Get Nice Financial Group Limited (Stock code: 1469); Ping An Healthcare and Technology Company Limited (Stock code: 1833); and ENN Energy Holdings Limited (Stock code: 2688). CHAN allegedly procured LAM to trade shares on his behalf or counseled him to do so using the inside information. LAM is further accused of disclosing the information to CHAU, who then traded the relevant shares. Court Order The HK Order and UK Order prohibit the three individuals from disposing of or diminishing the value of their assets in Hong Kong and overseas (including England and Wales), up to specified values: CHAN Ching Wa LAM Cho Man Assets up to HKD 3,709,566 are frozen CHAU Chi Kwong Assets up to HKD 604,545 are frozen SIGNIFICANCE: This case marks a significant escalation in the SFC’s enforcement strategy. It establishes that the geographic movement of persons or assets will not be a barrier to accountability . The ultimate message is that the cost and risk of engaging in market misconduct like insider dealing have been substantially raised, reinforcing the principle that Hong Kong's markets are fair, orderly, and protected by a regulator with a long and forceful reach. 10. SFC bans Andy LAU Ka Ho for life for Serious Misconduct On 26 February 2026, the SFC imposed a permanent prohibition on Mr. Andy LAU Ka Ho (“ LAU ”), a former licensed representative of Sun Hung Kai Group Licensed Entities, from re-entering the industry for life over serious misconduct, based on an investigation initiated by the following entities. The action stemmed from an SFC investigation initiated by a joint self-report from: Sun Hung Kai Investment Services Limited (“ SHKIS ”); Sun Hung Kai Commodities Limited (“ SHKCOM ”); and SHK Fund Management Limited (“ SHKFM ”) (collectively, “ SHK Entities ”; now known as Everbright Securities Investment Services (HK) Limited, CES Commodities (HK) Limited and Bright Fund Management Limited respectively). In imposing the lifetime ban, the SFC considered the persistent nature of the misconduct and its severe deceptive elements, which included: Conducting unauthorized trades in a client’s account. Executing online trades without the client’s knowledge or authorisation. Fabricating trading instructions from the client’s email. Providing forged account statements showing inflated cash balances and portfolio values. Blocking a cash withdrawal by falsely claiming a fictitious high-interest deposit arrangement and providing a forged confirmation to support it. *For more details of the background, please refer to the Statement of Disciplinary Action . SIGNIFICANCE: LCs must build a multi-layered defence system combining effective supervision, strong internal controls, direct client verification, technological safeguards, and a strong compliance culture to prevent, detect, and stop such misconduct. Reliance on an employees’ integrity alone is a severe and unacceptable control failure. Enforcement News - Listed Companies 11. SFC obtains compensation and disqualification orders against former directors of Arta TechFin Corporation Limited for Breaches of Directors' Duties Causing Substantial Company Losses On 10 February 2026, the SFC has secured a Court of First Instance order mandating that Mr. Andrew LIU (“ LIU ”), a former non-executive director of Arta TechFin Corporation Limited (formerly Freeman Financial Corporation Limited), and Mr. Quincy HUI Kwong Hei (“ HUI ”), its former managing director, jointly compensate the company for the financial loss incurred. The compensation of $57.5 million relates to losses sustained by Arta TechFin from its acquisition and subsequent disposal of a stake in LIU’s Holdings Limited. LIU, HUI and other seven other former executive directors were disqualified from acting as a director or in any way being concerned with or taking part in the management of Arta TechFin and any other corporation without leave of the Court. LIU Andrew 8 years disqualification HUI Quincy Kwong Hei 6 years disqualification Seven other former executive directors and independent non-executive directors of Arta TechFin Ranging from 1 to 2 years depending on their involvement and the severity of their misconduct. SIGNIFICANCE: This case is a reminder for all directors and senior managers in Hong Kong-listed companies to exercise heightened diligence, particularly in conflict-of-interest situations. It affirms the SFC’s commitment to holding individuals accountable to maintain market integrity and protect investors as Mr. Michael Duignan, SFC’s Executive Director of Enforcement, said: “ We welcome the judgement. This judgment sends a clear and unequivocal message that directors, whether executive or non-executive or independent non-executive, who neglect their fiduciary duties or fail to protect the company’s interests will be held fully accountable. The SFC stands resolute in its commitment to enforcing the highest standard of corporate governance and individual accountability. We will not hesitate to take decisive action to protect investors, safeguard company assets, and uphold the integrity of our markets .” 12. SFC Reaches Settlement Agreement with Sino Wealth International Limited and Clear Prosper Global Limited for Breaches of Takeovers Code Rules On 16 February 2026, the SFC has finalized a settlement with Sino Wealth International Limited and Clear Prosper Global Limited regarding breaches of the Takeovers and Mergers Code related to dealings in Giordano International Limited shares. The case centres on their parent company, CHOW Tai Fook Nominee Limited (“ CTFN ”), and a group of parties acting in concert with it (the “ Relevant Concert Group ”). Key Findings of the Breach Settlement Terms The SFC’s Takeovers Executive concluded that the Relevant Concert Group’s total shareholding in Giordano crossed the 30% threshold on 18 May 2016. This crossing should have triggered a mandatory general offer to all other shareholders at HKD 3.60 per share, but no such offer was made. A voluntary general offer (“ VGO ”) made by Clear Prosper in June 2022 at HKD 1.88 per share. The Executive found that this VGO was wrongly declared lapsed on 13 September 2022, even though its sole condition had been met based on the concert group’s holdings and valid acceptances received. Sino Wealth and Clear Prosper have agreed to provide compensation payments to independent shareholders who held Giordano shares on the dates of the two breaches. The total maximum compensation could reach approximately HKD 1.5 billion depending on the number of valid victims. SIGNIFICANCE: This case serves as a critical reminder that extreme diligence is required when assessing the fulfilment of conditions for voluntary general offers; allowing such an offer to lapse improperly constitutes a separate breach. This outcome emphasizes that strict, ongoing scrutiny of concert party relationships and associated obligations is essential to avoid significant financial liability and regulatory sanction. Moreover, the SFC remains committed to taking appropriate action to safeguard public interest and maintain the integrity of Hong Kong’s securities market. [End of ComplianceOne Newsletter – February 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. 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衷心感謝各位踴躍參與我們於 2026 年 6 月 27 日（星期六）舉辦的「監管科技反洗錢實戰：合規工具與策略」研討會。 【活動回顧】感謝您的參與：「監管科技反洗錢實戰：合規工具與策略」研討會(2026.06) 衷心感謝各位踴躍參與我們於 2026 年 6 月 27 日（星期六）舉辦的「監管科技反洗錢實戰：合規工具與策略」研討會。隨著金融科技的飛速發展與監管環境的日益嚴格，反洗錢（AML）與合規風控已成為金融業、金錢服務業（MSO）及匯款業務不可忽視的核心課題。 在剛過去的星期六（2026年6月27日），由 天匯合規顧問有限公司 (ComplianceOne Consulting Limited) 聯同共同主辦方 AIA (The Association of International Accountants - Hong Kong Branch) 及 華人內部審計師公會 (Association of Chinese Internal Auditors) 舉辦的「監管科技反洗錢實戰」專業培訓研討會已圓滿落幕！ 無論是親臨香港管理專業協會金鐘中心的線下嘉賓，還是透過 Zoom 線上參與的專業人士，感謝各位的踴躍支持與積極互動！ 🔮 科技賦能合規的未來 在本次研討會中，我們共同探討了如何運用先進的 監管科技（RegTech）工具 打破傳統合規的瓶頸。透過數據驅動的智能系統，企業不僅能大幅提升審查效率，更能精準識別潛在風險，將「被動合規」轉化為「主動防禦」的商業優勢。 📢 溫馨提示： 圓滿完成整場研討會並符合資格的學員，相關的培訓時數證明（3小時）將於近日透過電子郵件陸續發送，請密切留意您的收件箱。 再次感謝所有主辦單位、講者及業界同仁的參與。天匯合規將繼續致力於搭建專業的交流平台，與大家攜手走在合規與金融科技的最前線！ [Seminar Review] Thank You for Participating: RegTech AML in Practice: Compliance Tools & Strategies Seminar (2026.06) We sincerely appreciate your participation in our recent webinar, " RegTech AML in Practice: Compliance Tools & Strategies," held on Saturday, 27th June 2026. With the rapid advancement of FinTech and an increasingly stringent regulatory landscape, Anti-Money Laundering (AML) and compliance risk control have become pivotal priorities for the financial services, Money Service Operators (MSO), and remittance sectors. This past Saturday (June 27, 2026), the "RegTech AML in Practice" professional training seminar—jointly organized by ComplianceOne Consulting Limited (天匯合規) , AIA (The Association of International Accountants - Hong Kong Branch) , and the Association of Chinese Internal Auditors (華人內部審計師公會) —successfully drew to a close! We would like to extend our heartfelt gratitude to all our professional attendees, both those who joined us in person at The Hong Kong Management Association Admiralty Centre and those who participated virtually via Zoom, for your enthusiastic support and active engagement! 🔮 Empowering the Future of Compliance Through Technology During the seminar, we delved into how advanced Regulatory Technology (RegTech) tools can break through the bottlenecks of traditional compliance operations. By leveraging data-driven intelligent systems, enterprises can significantly boost vetting efficiency and accurately identify latent risks—effectively transforming "passive compliance" into a strategic "proactive defense" business advantage. 📢 Friendly Reminder: For participants who completed the entire seminar and met the eligibility criteria, your Certificate of Attendance (3 CPD/training hours) will be distributed via email over the coming days. Please keep an eye on your inbox. Once again, thank you to all co-organizers, esteemed speakers, and industry peers for making this event a resounding success. ComplianceOne remains dedicated to building a premier platform for professional exchange, walking hand-in-hand with you at the forefront of compliance and FinTech innovation!