SFC conclusions restrict unlicensed crypto exchange titles
The SFC will ask LegCo to restrict unlicensed crypto exchange titles after nine submissions, using word pairings and a schedule open to faster amendment.
The Securities and Futures Commission (SFC) published conclusions that restrict unlicensed crypto exchange titles in Hong Kong by a pairing test: one product word joined to one venue word. A November 6, 2026 news release, reference 26PR187, says the SFC will finalise amendments to the Securities and Futures Ordinance (SFO) and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), aiming to introduce a Legislative Council bill. A restricted title is, or closely resembles, one term from each of two tables.
The test is narrower than a bar on "exchange" alone, and it reaches a person who operates in Hong Kong or keeps a physical presence there. The consultation conclusions, reference 25CP5, set that limit after a respondent said offshore platform names had been left aside. "Tokenised assets" stays, and the restriction applies when that phrase is paired with a venue word such as "exchange".
From June 12, 2025, to August 11, 2025, nine written submissions all backed a wider section 34 of the SFO and a parallel provision under Part 5B of the AMLO. Section 34 already reserves "stock exchange" and "commodity exchange" for use with SFC approval. The AMLO limb covers virtual asset trading platforms (VATPs) and virtual assets outside securities and futures that may be traded or cleared on a VATP.
Which pairings the restricted lists would catch
Five Table A terms would be restricted under the SFO alone: "commodity", "derivatives", "futures", "securities" and "stock". Both ordinances would cover 12 more: "crypto", "cryptoasset", "cryptocurrency", "crypto coin", "digital asset", "digital coin", "digital currency", "token", "tokenised assets", "virtual asset", "virtual coin" and "virtual currency". Table B adds 12 venue terms under both, among them "exchange", "market", "trading platform" and "clearing house". The updated FAQ uses worked examples that include the unlicensed crypto exchange titles "crypto exchange" and "digital currency trading platform".
The proposals target two impressions: that a business is regulated or licensed by the SFC when it is not, or that it is associated with an established exchange, clearing house or VATP, in Hong Kong or elsewhere, when it is not. A name under both ordinances needs authorisation under both, filed as one application.
What the nine submissions changed in the draft
Annex 1 publishes eight names, among them The Hong Kong Association of Banks, The Hongkong and Shanghai Banking Corporation Limited, the Law Society of Hong Kong and Web3 Harbour, plus a withheld submission. After two respondents asked for a faster refresh, the SFC will place the titles in schedules to the SFO and the AMLO, amendable by subsidiary legislation. The conclusions say it is neither possible nor appropriate to do that by circular or guidance, because unauthorised use of a restricted title is a criminal offence and that consequence is meant to deter.
Two respondents asked to drop "tokenised assets". The SFC kept the term, and the Chinese "代幣化資產", as language commonly used for products that are essentially securities, and only where a Table B word such as "exchange" sits beside it. Suggested extras, including "Blockchain", Decentralised Finance (DeFi), "NFT", "Memecoin" and "VATP", stay off the list at this stage. Close resemblance catches a near copy, and names of well-known operations are a separate restriction.
One respondent said dual approval would raise costs for small and medium-sized enterprises. The SFC kept both approvals, through one application, and said added cost should stay limited. On a reasonable excuse, the FAQ says it is not possible to catalogue specimen circumstances. Four respondents asked for a transition. Commencement waits six months after enactment, the FAQ is already updated, and investor education with the Investor and Financial Education Council follows the end of the legislative process.
Rico Leung, executive director of supervision of markets at the SFC, said: "The proposed amendments will strengthen the restrictions and allow the list of restricted titles to be updated more promptly."
On the SFC licensed virtual asset trading platform list, updated October 16, 2026, Hong Kong Virtual Asset Exchange Limited pairs "virtual asset" with "exchange" in its company name, while HashKey Exchange and OSL Exchange place "exchange" next to a house brand. The name rule sits beside wider licensing, from the dealer and custodian regime to stablecoin issuer licensing, and beside the Hong Kong one-time password ban.
Drafting now passes to the Hong Kong government, then to the Legislative Council. Effect follows approval and the six-month deferral, so the paper sets a sequence rather than a calendar day. Subsidiary legislation lets a new pairing arrive ahead of another full bill.
This article is informational analysis only and is not financial, investment, or trading advice. Cryptocurrencies are highly volatile and can lose substantial value rapidly. Past performance and historical patterns do not guarantee future results. Do your own research and consult a regulated financial adviser before making any investment decision.
Reporting by Karthik Subramanian. Filed 9 November 2026, 15:10 GMT.
Digital Assets Correspondent
Karthik Subramanian is a founder, writer, and technology consultant with nine years in the crypto ecosystem.
