As we discuss in our memorandum released today and available here, the Hong Kong Securities and Futures Commission (“SFC”) last week took a significant step in its regulation of virtual asset activities by establishing a new, opt-in regulatory sandbox framework for virtual asset trading platform operators, proposing new licensing requirements for portfolio managers and imposing new requirements on fund distributers engaged in virtual asset activities.  These actions were issued through several documents, including a “Circular to intermediaries – Distribution of virtual assets funds” (the “Circular”) and a “Statement on regulatory framework for virtual asset portfolios managers, fund distributors and trading platform operators” (the “Statement”, together with the Circular, the “November 2018 Updates”) and discussed in a speech by Mr. Ashley Alder, CEO of the SFC.


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Martin Rogers

Mr. Rogers is a partner in Davis Polk’s Litigation Department, based in Hong Kong. He is regarded as one of Asia’s leading litigation and financial services regulatory lawyers, with nearly 30 years’ experience in Asia. [Full Bio]

Bo Huang

Mr. Huang is an associate in Davis Polk’s Litigation Department, currently practicing as a Registered Foreign Lawyer in Hong Kong. [Full Bio]

Noble Mak

Ms. Mak is an associate in Davis Polk’s Litigation Department, resident in Hong Kong. [Full Bio]