In the context of Hong Kong actively embracing Web3 and building a digital asset center, combating money laundering related to virtual assets has become a top priority for regulatory agencies. On November 17, 2025, the Hong Kong Securities and Futures Commission (SFC) issued an important circular urging licensed corporations and virtual asset trading platforms to remain vigilant against suspicious fund transfers that show signs of layered trading activities to prevent money laundering. This is not only a response from the SFC to the rising trend of criminals using licensed institutions for money laundering activities but also reflects its deep cooperation with agencies such as the Hong Kong Police Force, enhancing the detection and prevention capabilities against virtual asset crimes through the "24/7 stop payment" mechanism.
- SFC Takes Strong Action: Strict Prevention of Virtual Asset "Layered Money Laundering"
The circular issued by the Hong Kong SFC directly addresses the increasingly rampant "layered money laundering" activities in the virtual asset sector.
New Trend in Money Laundering: The SFC pointed out in the circular that there is a continuous upward trend of criminals using licensed institutions for layered trading activities, with some individuals attempting to disguise the source and destination of illegal funds to launder proceeds from fraud and deception cases.
Warning Signs of Layered Trading: Common warning signs of layered trading activities involve a series of suspicious behaviors, including frequent, rapid, and organized deposits of funds into customer accounts, followed by immediate withdrawals in the form of funds or virtual assets.
Reiteration of Strict Standards: The SFC reiterated the strict standards required for licensed institutions to detect and prevent layered trading activities, emphasizing that licensed institutions (especially their senior management) must ensure the integrity of their operations and the Hong Kong financial system.
- Regulatory and Law Enforcement Coordination: "24/7 Stop Payment" Mechanism Shows Effectiveness
In response to the risks posed by the rising trend of licensed institutions being used for money laundering, the SFC has strengthened cooperation with the Hong Kong Police Force (including the Anti-Fraud Coordination Centre's Joint Wealth Intelligence Group) and a wide range of licensed institutions.
Public-Private Collaboration: This reflects a close "public-private collaboration" model between regulatory agencies, law enforcement, and industry stakeholders.
"24/7 Stop Payment" Mechanism: Since September 2025, all licensed institutions have agreed to cooperate with the Anti-Fraud Coordination Centre's "24/7 stop payment" mechanism to expedite the interception of criminal proceeds and the recovery of related funds.
Significant Results: Within two months, about one-third of the criminal proceeds confirmed to be involved in fraud and scams that flowed into licensed institutions were successfully intercepted, demonstrating the significant effectiveness of this mechanism.
Webinar Strengthens Training: To promote compliance with regulations against money laundering and terrorist financing, the SFC held a webinar today to explain the latest observations and related regulatory responses regarding investigations into the Hong Kong securities and virtual asset markets to licensed institutions.
- Hong Kong Web3 Market: Acceleration of Compliance Process, International Banks Entering the Scene
While the SFC strictly prevents money laundering, Hong Kong's Web3 market is also accelerating its compliance process, attracting international banking giants.
AMINA Bank Licensed: On November 18, it was reported that Swiss crypto bank AMINA (Hong Kong) Limited received an upgrade to a Type 1 license from the Hong Kong SFC, becoming the first international banking group to offer crypto spot trading and asset custody to professional investors in Hong Kong. The services cover 24/7 trading, custody, and crypto asset deposits and withdrawals to whitelisted addresses, initially supporting 13 types of crypto assets (including BTC, ETH, USDC, USDT, and mainstream DeFi tokens) and utilizing SOC 1/2 Type 2 level infrastructure. AMINA stated that it will subsequently expand into private fund management, structured products, derivatives, and RWA tokenization, targeting institutions, enterprises, and high-net-worth clients.
Crackdown on Unlicensed Platforms: On November 15, the Hong Kong SFC included a virtual asset trading platform named "HKTWeb3" on its warning list of suspicious virtual asset trading platforms, indicating that the platform has not obtained a license from the Hong Kong SFC. This shows that while promoting compliance, the SFC continues to combat unlicensed operations.
- Challenges in Regulation and Future Outlook
The SFC's circular is a continuous monitoring of licensed institutions' compliance with regulations against money laundering and terrorist financing.
Decisive Regulatory or Law Enforcement Actions: The SFC continues to monitor licensed institutions' compliance with relevant regulations against money laundering and terrorist financing and will take decisive regulatory or law enforcement actions against licensed institutions that fail to fulfill their legal and regulatory responsibilities.
Enhancing Vigilance: Dr. Ye Zhiheng emphasized that licensed institutions (especially their senior management) must maintain a high level of vigilance against layered trading activities, which could effectively prevent the implementation of strict controls against money laundering and terrorist financing. Licensed institutions should enhance their vigilance against suspicious transaction alerts and regularly assess the soundness and effectiveness of their internal monitoring measures.
Conclusion:
The Hong Kong SFC's circular urges licensed institutions to be vigilant against virtual asset "layered money laundering" activities and collaborates with the police through the "24/7 stop payment" mechanism, marking a solid step forward in combating virtual asset crimes in Hong Kong. In the Web3 era, security and compliance are the cornerstones of the healthy development of virtual assets. Hong Kong is committed to building a safe, transparent, and trustworthy digital asset market through its stringent regulatory framework, public-private collaboration model, and continuously upgraded law enforcement capabilities, leaving no place for crypto crime to hide.
Related Reading: HKTWeb3 Listed on Warning List! Hong Kong SFC: Unlicensed Platforms Posing as Licensed Institutions
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