1 Listing, authorised products and emerging assets
Separate listing approval, public-offer authorisation, selling conduct and platform licensing.
Listing and public offers
Listing Rules / SFO Part IV- The SEHK is the frontline administrator of the Listing Rules; the SFC has separate roles under the dual filing regime and statutory powers. Compare
- Listing, SFC authorisation and suitability for sale to a particular client are different questions; one does not automatically prove the others. Trap
四問法
For a product, ask: is it securities/CIS, is it offered to the public, does it require authorisation, and what licence does the distributor need?
Two-layer virtual-asset regulation
SFO / AMLO- A token with securities characteristics may involve Type 1 dealing; a centralised VATP operating in or actively marketing to Hong Kong must also be licensed under the applicable regime. Exam
- A non-security token is not thereby 'securities' under the SFO, but platform activity is not wholly outside SFC regulation; the AMLO VASP regime may apply. Trap
- Distribution of a fund investing in virtual assets may still be Type 1 because the fund interest being distributed is itself securities. Definition
2026 更新
Classify the asset first, then the business model. 'The token is not a security' answers only the first layer.
