Contents

License Application
1. Function introduction
II. Basic Qualification Requirements
III. Application Process and Cycle
IV. Application Period
License Acquisition
Acquisition process and time
Service Introduction
Customer type
License Case
team introduction
FAQ

9. Introduction to the functions of Hong Kong Asset Management License No. XNUMX

Hong Kong Type 9 License is issued by the Securities and Futures Commission (SFC) under the Securities and Futures Ordinance (SFO) and belongs to Type 9 regulated activity (asset management). Its main functions are as follows:

  1. Asset Management Business :

    • Portfolio Management: The license holder can fully manage the investment portfolio of securities or futures contracts for the client and make investment decisions independently based on the client's authorization, covering traditional assets such as stocks, bonds, derivatives, etc.
    • Fund management: Allows management of various types of investment funds, including hedge funds, private equity funds, mutual funds, real estate investment trusts (REITs), etc., formulate investment strategies and implement asset allocation.
    • Customized services：Provide personalized asset management solutions based on the client's risk tolerance, investment objectives and market demand, suitable for active or passive investment strategies.

  2. Virtual asset management :

    • Virtual asset investment：If the license holder plans to manage an investment portfolio that includes virtual assets (VA, such as cryptocurrencies, tokens, etc.), and virtual assets account for 10% or more of the total asset value (GAV), or virtual asset investment is a clear investment goal, it is necessary to apply for a Type 9 Licence Uplift. After the upgrade, you must comply with the SFC's special terms for virtual assets (VA Fund Manager T&Cs), including asset custody, risk management and anti-money laundering requirements.
    • Compliance requirements：Licensed persons who manage virtual assets must ensure secure custody (such as cold wallets, multi-signature wallets), comply with anti-money laundering/counter-terrorism financing (AML/CFT) regulations, and report regularly to the SFC.
    • market opportunity: As Hong Kong pushes to become Asia's virtual asset hub, Type 9 license holders can participate in the fast-growing crypto asset market and attract institutional investors and high net worth clients.

  3. The difference between the functions of Big 9 and Small 9 :

    • Big 9 :
      • Directly manage client assets: Allows the licensee to directly hold or control client assets (such as funds or securities), usually involving a single pool of funds or retail fund business.
      • Applicable scenarios: Suitable for institutions that manage retail funds or need to directly control client assets, such as large asset management companies or bank subsidiaries.
      • Capital requirements: Higher capital thresholds must be met, with a minimum paid-in capital of HK$500 million and a minimum liquid capital of HK$300 million.
      • Service objects：Can serve retail investors (non-professional investors) and must comply with stricter compliance requirements to protect the public interest.
    • Small 9 :
      • Does not directly manage client assets：The license holder is not allowed to hold client assets. Client assets must be deposited in an independent custodian institution (such as a bank or brokerage firm). The license holder only provides investment instructions or management services.
      • Applicable scenarios：Commonly seen in external asset managers (EAMs), family offices or private equity fund managers, assets are usually held in trust by a third party to reduce operational risks.
      • Capital requirements: There is no minimum paid-in capital requirement, and the minimum liquid capital is HK$10, which is a relatively low threshold.
      • Service objects: Usually limited to professional investors (such as institutional investors or high net worth individuals), and the compliance requirements are relatively light.
    • Functional impact: Big brands allow a wider scope of business (such as retail fund distribution) and asset control, but have higher compliance costs and regulatory requirements; small brands are more suitable for business models that focus on professional investors or entrusted management, with flexible operations and lower costs.

  4. Service Targets and Market Expansion :

    • Diversified Customers：Licensed persons can serve local and international clients, including institutional investors (such as pension funds), high net worth individuals, family offices, etc., to meet cross-border asset management needs.
    • Marketing: License Type 9 allows the license holder to carry out fund promotion and research analysis (without the need for additional License Type 1 or 4), making it easier to expand the customer base and enhance market influence.

       
    • Cross-border advantages：Support licensees to participate in the global asset management market, especially the Asian market, and consolidate Hong Kong's position as an international financial center.

  5. Synergy with other licenses :

    • Supplementary Services: License No. 9 can be combined with License No. 1 (Securities Trading), License No. 4 (Securities Advisor) or License No. 6 (Corporate Finance Advisor) to provide comprehensive services ranging from investment advice, transaction execution to asset management.
    • Flexible Operation: For example, a company holding a No. 9 license can provide full power of attorney management for the securities trading business of a No. 1 license, expand the scope of services, and enhance customer experience.

Points to note

  • Regulatory restrictions: License No. 9 does not cover activities such as securities trading, fund distribution or direct investment advice, which require additional application for corresponding licenses.
  • Virtual asset regulation trends: With the implementation of the Virtual Asset Trading Platform (VATP) licensing system in June 2023 and the SFC’s new rules on virtual asset custody and over-the-counter trading in 6, Type 2025 licensees need to pay close attention to regulatory developments to ensure compliance.
  • Big or small card selection: In actual operations, most private equity funds or family offices choose small brands because they do not need to directly hold assets and have low compliance costs; big brands are more suitable for institutions with retail business or large funding pool needs.

4. Companies applying for Hong Kong Type XNUMX License (Securities Advisor) need to meet the following basic eligibility requirements:

1. Fit and Proper Requirements

The SFC requires that the applicant company and its relevant personnel (such as major shareholders, directors, responsible personnel) are "fit and proper persons", including:
  • financial soundness :
    • The company needs to prove that it is in good financial condition and has no bankruptcy or major financial problems.
    • Minimum Liquid Capital Requirement: Depending on the size of the business, usually HK$100,000 to HK$3,000,000 (depending on whether it involves client asset management or just providing advice).
  • Character and Integrity :
    • The company and its key personnel have no criminal record or violations of financial regulatory requirements.
    • Any past regulatory penalties or legal proceedings need to be disclosed.
  • Professional ability :
    • The company needs to demonstrate that it has the expertise and operational capabilities to engage in securities advisory activities.
    • Responsible Officers (RO) are required to pass the Hong Kong Securities and Investment Institute (HKSI) qualification examinations (such as Paper 1 “Basic Securities and Futures Regulation” and Paper 6 “Securities and Corporate Finance Advisory”) or obtain exemptions.

2. Company establishment requirements

  • Hong Kong registered company :
    • The applicant company must be incorporated in Hong Kong (such as a limited company) or an overseas company registered in Hong Kong.
    • Documents such as the company's incorporation certificate, memorandum of association and articles of association are required.
  • Actual Operation :
    • The company must have actual business operations in Hong Kong, such as setting up an office and hiring local employees or responsible persons.
    • The SFC may require proof that the company’s business activities in Hong Kong are genuine and ongoing.

3. Responsible Officer (RO) Requirements

  • Appointment of RO :
    • The company is required to appoint at least two Responsible Officers (RO) to oversee the regulated activities of License IV.
    • At least one RO must be an executive director and be based in Hong Kong to perform supervisory duties.
  • RO Qualification :
    • Have at least 3 years of relevant industry experience (2 years of which must be management experience).
    • Pass the HKSI qualifying examinations (e.g. Paper 1 and Paper 6), or possess a recognised professional qualification (e.g. CFA, CPA) and apply for exemption.
    • No bad record and meets the "fit and proper candidate" standard.
  • RO Responsibilities :
    • Ensure the company complies with the regulations and compliance requirements of the Securities and Futures Commission.
    • Responsible for overseeing the operations and risk management of securities advisory activities.

4. Compliance and Internal Control

  • Compliance Framework :
    • Companies need to establish comprehensive compliance policies and internal control mechanisms, such as anti-money laundering (AML) and customer knowledge (KYC) procedures.
    • Submit a compliance manual outlining how conflicts of interest, client data protection and fairness of advice are managed.
  • Risk Management :
    • Risk management policies need to be formulated to ensure sound business operations and protect customer interests.
  • independent audit :
    • The company needs to appoint an independent auditor to audit its financial statements regularly and submit them to the Securities and Futures Commission.

5. Business Plan

  • Detailed business plan :
    • Submit a business plan describing the scope of the Company's activities (e.g., providing securities advice, research reports, or investment strategies).
    • Including target customer groups, market positioning, revenue model and operating structure.
    • If security-type virtual assets (such as security tokens) are involved, the relevant business model and compliance measures must be clearly stated.
  • Technology and System :
    • Demonstrate that the firm has technology systems in place to support securities advisory activities, such as data analytics tools or client management systems.

6. Application documents and fees

  • needed file :
    • A completed SFC prescribed form (Form A or other relevant form).
    • Audited financial statements of the company.
    • Educational background, experience and examination results of the responsible person (if applicable).
    • Compliance manual, business plan and internal control policy.
    • Background information and criminal record certificates of major shareholders and directors.
  • Application Fee :

    • The application fee for a Type 4,740 license is approximately HK$XNUMX (the fee is set by the SFC and may be adjusted over time).

  • Other expenses :
    • This may involve service fees from intermediaries (such as lawyers or consultants), as well as HKSI examination or training fees.

7. Education and examination requirements

  • Education :
    • Responsible officers are usually required to possess relevant academic qualifications (such as finance, economics, law or accounting), or equivalent professional qualifications.
    • The SFC may accept extensive industry experience in lieu of formal academic qualifications, subject to individual case approval.
  • HKSI Examination :
    • Responsible officers and relevant employees are required to pass HKSI’s Licensing Examination, which usually includes:
      • Paper 1: Basic securities and futures regulation.
      • Paper 6: Securities and corporate finance advisers.
    • Exempt: If you have a CFA, CPA or equivalent overseas license and are experienced, you can apply for partial exam exemptions, but you must submit supporting documents.

8. Other things to note

  • application time :
    • The CSRC's approval process usually takes 3-6 months, depending on the completeness and complexity of the application materials.

    • If the information is insufficient, the CSRC may request additional information and extend the approval time.

  • Continuous Compliance :
    • After approval, the company must comply with the CSRC's ongoing regulatory requirements, such as submitting annual financial statements and completing continuing professional training (CPT).
  • Virtual asset related :
    • If the business involves security-type virtual assets (such as security tokens), it is necessary to ensure compliance with the CSRC’s virtual asset regulatory guidelines and may be required to provide additional proof of compliance capabilities.
Summary
Companies applying for Hong Kong's Type 4 license must meet requirements such as financial soundness, compliance framework, professional capabilities and substantial operations. The key is to prove that the company and its responsible persons are "fit and proper persons" and have the ability to engage in securities advisory activities. Submission of a detailed business plan, compliance policy and proof of qualifications of responsible personnel is key.

9. Application process and cycle for Hong Kong Asset Management (VA) Type XNUMX license

Stairs step Main content Estimated time
1. Preliminary preparation Confirm business needs and company establishment – Determine the type of application (big brand/small brand, whether it involves virtual assets).

– Register a limited company in Hong Kong or a branch of a non-Hong Kong company.

– Lease of physical office space.

 2-6 months (depending on the size of the company)
Team building and compliance framework – Appoint at least two Responsible Officers (RO) with 3 years of relevant experience and professional qualifications.

– Develop risk management, anti-money laundering (AML/CFT) and compliance policies.
Financial and operational preparedness – Ensure capital requirements (big players: HK$500 million paid-in/HK$300 million liquid; small players: HK$10 liquid).

– Establish IT system and operation manual.
2. Prepare application documents Collect and compile documents -
Application form
：Form A and its appendices.

-
business plan
: Business model, target market, financial forecast.

-
Compliance Documents
: Risk management, anti-money laundering policy.

-
financial information
: Audited financial statements and capital certification.

-
RO Information
: Education, experience, no criminal record.

-
Company information
: Articles of Association, shareholder structure, office lease contract.

-
Virtual assets (if applicable)
: Hosting arrangements, network security measures.

 1-2 months (overlapping with preliminary preparation)
3. Submit your application Submit application and pay fee – Submit via SFC WINGS platform or paper form.

– Pay the application fee (approximately HK$3,900, there may be additional fees for virtual asset or other licenses).

– Designate a contact person to handle SFC inquiries.

 1-2 weeks (document preparation and submission)
4. SFC approval Initial review – SFC confirms the completeness of the documents and provides feedback on whether additional information is required. 1-2 weeks
detailed assessment – Review financial status, compliance framework, business plan, RO qualifications and “fit and proper” criteria.

- Apply for additional review of virtual asset custody and risk management.

 3-5 months (depending on the complexity of the application)
Supplementary information and interaction – Respond to SFC requests (e.g. supplementary compliance policies, financial certification).

– An RO interview or on-site inspection may be arranged.

 1-3 months (if multiple supplements are needed)
5. Approval and licensing Licensing and Registration – After approval, the SFC will issue a Type 9 license with conditions (such as big/small brand restrictions and virtual asset clauses).

– Registered on the SFC public register.

 1-2 weeks

Total cycle

  • Standard approval cycle: 4-6 months (from application submission to approval).
  • Total time including preliminary preparation:6-12 months (depending on the complexity of the application, the efficiency of document preparation and whether virtual assets are involved)).
  • Factors affecting the cycle:
    • Application type: Applications from big names (retail funds or directly managed assets) or virtual assets are subject to stricter review and the review period may be extended to 6-8 months.
    • Completeness of documents: The time can be shortened if all documents are submitted for the first time; multiple supplements may extend the time to more than 8 months.
    • Professional assistance: Hiring an attorney or compliance consultant can speed up preparation and response.
Points to note
  • Big brands vs. small brands: Big brands have high capital and compliance requirements and take longer to approve; small brands have low thresholds, are suitable for private equity funds, and have faster approval.
  • Virtual assets: Additional review of security custody and risk management is required, and the cycle may increase by 1-2 months.
  • Ongoing obligations: After approval, you need to submit annual reports and accept SFC inspections.

Hong Kong Virtual Asset Management (VA) No. 9 License Acquisition Process and Timetable

Stairs step Main content Estimated time
1. Needs Assessment and Target Identification Confirm needs and screen targets – Clarify the target (big brand/small brand, virtual asset).

– Screen licensed companies to confirm license status, AUM and compliance records.

 0.5-1 months
2. Sign a Non-Disclosure Agreement (NDA) Sign NDA – Protect financial, customer and compliance information.

– Agree on the scope and period of confidentiality (1-2 years).

– May contain an exclusive negotiation clause.

 About 1 week (1-2 weeks for complicated cases)
3. Due Diligence Financial, regulatory and operational reviews – Review financial statements and capital position.

– Check SFC compliance records and internal controls.

– Assess RO eligibility and virtual asset custody (if applicable).

 1 months
4. Negotiation and Transaction Structure Valuation, LOI and Agreement – Valuation based on AUM and license type.

– Sign LOI to clarify the terms of equity/asset acquisition.

– Drafting of SPA.

 0.5-1 months
5. SFC prior approval Submit change application and approval – Submit Form D and buyer/RO information.

– Demonstrate “fit and proper” status and commitment to compliance.

– Respond to SFC requests.

 2-3 months
6. Transaction Completion and Delivery Contract signing, handover and customer notification – Sign the SPA and complete the payment.

– Update company/SFC registration.

– Notify the customer (if applicable).

– Confirm virtual asset compliance.

 0.5-1 months
7. Subsequent supervision obligations Ongoing compliance and license maintenance – Submit annual reports and accept inspections.

– Maintain capital and RO qualifications.

– Report significant changes.

 ongoing
Total cycle
  • Standard time required: 3-7 months.
  • NDA impact: completed in 1 week under standard circumstances, speeding up the early progress.
  • Acceleration suggestion: Entrust a professional consulting company to coordinate NDA, due diligence and SFC application.

Customer service type

Asset Management Institutions

Asset Manager

Lending Institutions

loan provider

Exchange

cryptocurrency exchange

traditional finance

Traditional Financial

Brokerage Institutions

broker-dealer

OTC institutions

OTC provider

License Case

business planning

Conducting overseas financial business requires comprehensive planning

Corporate Framework

資金
  • Total treasury requirements
  • Liquidity requirements
  • Regulatory agencies’ external requirements
  • Are the funds already overseas?
Background of shareholders and directors
  • Suitable person
  • Industry background
  • Reputation and qualifications
  • Do Hong Kong/offshore license companies need to increase?
Professionals
  • Company person in charge
  • Professional staff (RO)
  • Other financial professionals: sales, compliance, settlement, etc.
  • Do the personnel match the business needs?
Office location
  • Business Location
  • Separation of front office, back office and back office in compliance with regulatory requirements
  • Connections to exchanges
  • Purchase office furniture

Corporate Compliance

license
  • What is the operating area itself?
  • The various laws and regulations that media business must comply with and the Securities and Futures Commission
  • Various periodic and prudent declarations

! The Jingbiantong team will assist customers in making the most appropriate plans and provide corresponding services in various fields according to their actual background and business needs.

我們的團隊

Director and Founder

▶ Honorary Fellow of Hong Kong Baptist University
▶ Served as executive director and independent non-executive director of several listed companies
▶ Manage the regulated business of comprehensive financial enterprises (listed and unlisted):
-Securities business (CSRC No. 1 license)
-Futures business (CSRC license No. 2)
-Investment Banking Business (China Securities Regulatory Commission License No. 6)
-Asset management business (CSRC license No. 4 and 9)
-Insurance Brokerage Business (PIBA Member)
-Money Lending Business (Money Lenders Licence)
▶ Served as the head of the legal and compliance department of a listed financial company, dealing with different regulatory agencies

Director and Founder

▶ Bachelor of Science, Master of Business Administration, Master of Financial Engineering, Hong Kong University of Science and Technology
▶ Long-term management of regulated businesses of comprehensive financial enterprises:
-Securities business (CSRC No. 1 license)
-Futures investment business (CSRC license No. 2, 5)
-Investment Banking Business (China Securities Regulatory Commission License No. 6)
-Automated Trading (CSRC License No. 7)
-Asset management business (CSRC license No. 4 and 9)
-Insurance Brokerage Business (IA Member)
-Money Lending Business (Money Lenders Licence)
▶ He has over 15 years of experience in asset management, investment research and compliance management and is a senior consultant in the industry.

General Manager

Bachelor of Arts from the Chinese University of Hong Kong, Master of Social Sciences in Communication from the Chinese University of Hong Kong, Master of Professional Accounting and Corporate Governance from the City University of Hong Kong.
She is a member of the Hong Kong Institute of Corporate Governance and the Institute of Chartered Secretaries and Administrators in the United Kingdom, and possesses the professional qualifications of Chartered Secretary (CS) and Corporate Governance (ACG).
Active in the compliance industry for over ten years.

Senior Vice President

Master of Finance from the Hong Kong Polytechnic University. Chartered Financial Analyst (CFA) charterholder.
He has nearly ten years of experience in the Hong Kong securities and asset management industry, managing assets worth over HK$30 billion.
Possess the qualification of Responsible Officer (RO) of a licensed company. Familiar with the products and compliance operations of Hong Kong securities firms and asset management companies.

Vice President

Bachelor of Science from the University of Hong Kong. With nearly ten years of experience in applying for various financial-related licenses and establishing software and hardware supporting facilities,
The clients we have served are located in many regions around the world, spanning different backgrounds, and their licensing needs are comprehensive and complex.

※ The list of professional team members is not exhaustive. There is also an advisory team including professional accountants from licensed institutions, lawyers, and former management members of regulatory agencies.

🏆 The team is more than 100 Different types of financial licenses provide various compliance-related services. Including but not limited to:

-State-owned enterprise group affiliated companies
-Subsidiary of China's Top 500 Private Enterprises
-Subsidiaries of major domestic real estate developers
-Hong Kong Main Board listed financial group

-Former fund manager of a large investment bank
-Algorithmic Trading Hedge Fund Firms
-Fin-tech companies under listed technology companies
-Top domestic law firms

🏆 The founder has managed listed financial companies and handled securities regulatory affairs.experienceRich, other team members have practical management and operation experience in well-known financial industries,Practical operationlevelWe provide feasible compliance ideas and compliance solutions to help customers develop their business.

🏆 The team has served mainland enterprises and entrepreneurs for many years.FamiliarDomestic conditions and customer needs, can assist customersadaptThere are many differences between the two places in terms of culture, supervision, system, business environment, etc.

FAQs

If virtual assets account for less than 10% of the total asset value (GAV) and are not an investment target, there is no need to comply with the SFC’s Virtual Asset Fund Management Provisions (VA Fund Manager T&Cs). However, basic risk management (such as cybersecurity) must be implemented and the proportion of virtual assets must be disclosed to the SFC. When the ratio approaches 10%, the SFC may request clarification and recommend proactive compliance (refer to SFC – Statement on virtual asset portfolios）
It is doable, but be careful. A Cayman fund can reduce its Hong Kong tax burden (e.g. by taking advantage of the zero tax rate on carried forward profits of a Hong Kong LPF), but if management activities are carried out in Hong Kong, the Type 9 license requirement cannot be exempted. The SFC focuses on the actual place of management. Offshore structures must ensure that investment decisions are not made in Hong Kong, otherwise they may involve dual supervision. In terms of taxation, you need to consult a tax expert to comply with the transfer pricing rules of the Hong Kong Inland Revenue Department and the OECD (refer to Timothy Loh LLP – SFC License Type 9 FAQs).
No direct approval is required, but the SFC requires ensuring data security, privacy protection and operational continuity of the third-party platform, especially the cloud system must comply with the SFC's cybersecurity guidelines. If virtual assets are involved, additional proof of the platform's anti-hacking capabilities is required.
There is no need to surrender the license, but the company needs to notify the SFC of the suspension of business and maintain minimum capital and compliance requirements (such as RO qualification, annual reporting). If there is no operation for a long time, the SFC may question the necessity of the license and recommend submitting an updated business plan (refer to SFC – Do you need a license or registration?).
It is necessary to apply to the SFC for business changes, especially when changing from a small brand (professional investor) to a big brand (retail fund), which requires meeting higher capital (HK$500 million paid-in/HK$300 million liquid) and compliance requirements. The approval may take 3-6 months.
Hong Kong's No. 9 license benefits from its status as an Asian financial center, its zero tax rate policy for LPFs and its virtual asset regulatory framework, attracting international clients. Singapore’s MAS licensing process is faster (3-6 months), but Hong Kong’s proximity to the Chinese market and SFC’s international recognition are higher.
If the sub-manager is located overseas and does not directly carry out regulated activities in Hong Kong, a Hong Kong Type 9 license is not required, but the licensee must ensure that the sub-manager's activities comply with the SFC's entrusted management requirements (such as due diligence and monitoring). If the sub-manager operates in Hong Kong, a Type 9 license or exemption qualification is required. It is recommended to clarify the responsibilities in the entrustment agreement and disclose it to the SFC.
The SFC determines the principal business location based on the location of investment decisions, operation center and customer asset management location. If some activities are conducted overseas, it is necessary to prove that Hong Kong is still the core management location (e.g. RO stationed in Hong Kong, record keeping). Otherwise, additional disclosure or structural adjustment may be required. Cross-border activities need to be wary of overseas regulatory conflicts and it is recommended to submit a business model report to the SFC
The SFC generally does not hold licensees liable for market losses if they have fully disclosed the risks, complied with the code of conduct (such as treating clients fairly) and implemented reasonable risk management. However, if there are undisclosed high-risk investments (such as leveraged tokens) or insufficient internal controls, they may face investigations or even fines. It is recommended to improve the risk disclosure document and record the customer's consent
If you actively promote your services to EU clients, you will need to comply with MiFID II (such as investor protection and disclosure requirements) and may need to register in the EU or rely on exemptions (such as serving only professional investors). Passively accepting EU customers generally does not require additional registration, but it is necessary to disclose cross-border business to the SFC and ensure anti-money laundering compliance.
Asset management in mainland China is regulated by the China Securities Regulatory Commission (CSRC), and Hong Kong Type 9 license is not directly applicable. If you want to conduct business in the Mainland, you need a Mainland license (such as private equity fund manager qualification) or go through cross-border programs such as QDLP/QFII. SFC requires disclosure of mainland business to ensure no violation of Hong Kong regulation, and recommends coordination with mainland lawyers
LPF offers zero tax rate on carried interest and is applicable to eligible fund managers (such as Type 9 license holders). It is necessary to ensure that the fund structure complies with the requirements of the Hong Kong Inland Revenue Department (such as substantial economic activities) and avoid being regarded as a tax avoidance arrangement.
Offshore companies charging management fees need to prove that the income is not from Hong Kong, otherwise they may need to be subject to Hong Kong profits tax. The SFC requires disclosure of offshore structures to ensure that regulations (such as anti-money laundering) are not circumvented. The OECD's BEPS rules may affect tax arrangements. It is recommended to confirm with tax and legal advisors
Due diligence requires reviewing customer contracts, complaint records and legal proceedings, and it is recommended to ask the seller to provide a statement of no disputes. The share transfer agreement (SPA) should contain an indemnity clause that specifies the seller’s liability for undisclosed disputes. After the acquisition, it is necessary to notify customers and update compliance policies to reduce the risk of SFC investigation (refer to the discussion of the acquisition process above).
Hong Kong allows virtual asset ETFs (such as the Bitcoin/Ethereum ETF approved in 2023), but the Type 9 license is limited to asset management, and the distribution of ETFs requires a Type 1 license (securities trading). It is necessary to comply with the SFC’s virtual asset product guidelines (such as risk disclosure, custody) and coordinate listing requirements with the Stock Exchange.

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