JunHe assisted a leading financial institution (‘the Client’) to successfully upgrade its Type 1 license with the Hong Kong Securities and Futures Commission (Hong Kong SFC). This license upgrade enables the Client to offer comprehensive virtual asset-related trading services in Hong Kong, including providing virtual asset trading services to clients through omnibus account arrangements. This marks a significant advancement in the Client’s virtual asset business development and is another successful case of JunHe assisting clients in developing compliant virtual asset businesses under the Hong Kong SFC regulatory framework.
JunHe acted as the legal advisor and assisted the Client throughout the upgrade application process, allowing them to provide virtual asset trading services under omnibus account arrangements. JunHe designed the project framework based on the regulatory requirements for omnibus account arrangements, prepared and reviewed the application materials, drafted business plans and other documents including client agreements, and responded to subsequent inquiries from the Hong Kong SFC. Leveraging its understanding of the Hong Kong SFC’s regulatory approach to virtual asset trading, JunHe conducted a comprehensive assessment of the Client’s proposed business model, corporate governance structure and operational processes to ensure all aspects of the license upgrade application met the evolving regulatory standards of the Hong Kong SFC and were implementable within the Client’s internal systems. With a thorough understanding of Hong Kong’s virtual asset regulatory requirements, JunHe evaluated the Client’s business model, governance structure and operational processes to ensure the application plan met the regulatory standards and could be implemented in internal operations.
JunHe also assisted in drafting and revising the legal documents related to the virtual asset business, supporting the Client in establishing risk management, internal controls and compliance execution systems. JunHe further assisted the Client in responding to inquiries from the Hong Kong SFC, including refining the supporting documents, drafting clear and persuasive regulatory responses, and closely collaborating with the Client’s internal team to ensure that the issues and requirements raised by the regulatory body were efficiently addressed and met regulatory expectations. The successful completion of this license upgrade reflects the Client’s significant progress in compliant operation and business development in the virtual asset field.
QIAO, Zheyuan (Jacqueline) was the lead partner for this project.
