Money Service Operator License
License for crypto-to-fiat exchange services and OTC trading operations with AML compliance.
Money Service Operators Ordinance (Cap. 615)
Capital Required
No statutory minimum; professional indemnity insurance required
Timeline
4-6 months
Fees
HKD 50,000-100,000 application + HKD 40,000-80,000 annual
Regulatory Body
Securities and Futures Commission (SFC) / Hong Kong Monetary Authority (HKMA)
Legislative Framework
Securities and Futures Ordinance (SFO), Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), Stablecoins Ordinance 2025
Last updated: August 2025
Key Requirements
Professional indemnity insurance of minimum HKD 500,000-1,000,000 covering MSO operations
Comprehensive AML/CFT procedures compliant with AMLO including customer verification for transactions over HKD 8,000
Beneficial ownership and governance documentation with fit-and-proper declarations for persons >25%
Clear operating procedures for crypto-to-fiat exchanges and OTC trading with documented pricing
Segregated customer fund accounts with AMLO-regulated financial institution for collection and transfer
Compliance Officer appointment with AML/CFT experience for regulatory oversight of operations
Record-keeping policies for customer files and transaction documentation maintained 5 years minimum
Annual independent audit of financial statements and AML/CFT compliance procedures to AMLO
Application Process
Submit Money Service Operator License application to AMLO specifying exchange and OTC services
Provide beneficial ownership documentation and fit-and-proper declarations for board and key personnel
Include comprehensive AML/CFT procedures, customer agreements, and operating procedures for exchanges
Arrange MSO bank account with AMLO-regulated institution and provide documentation and arrangements
Submit professional indemnity insurance certificate and compliance officer appointment confirmation
AMLO review and approval following assessment of AML/CFT controls and operational procedures
Expected Total Timeline
4-6 months
Ongoing Obligations
After obtaining your Money Service Operator License, these are the continuing compliance requirements you must maintain.
Quarterly transaction volume reports and annual independent audit by AMLO-approved auditors
Monthly AML suspicious activity reporting and quarterly AML/CFT compliance certifications to AMLO
Annual fit-and-proper assessments for board members and compliance officer with updates to AMLO
Maintenance of customer files and transaction records 5 years minimum with AMLO audit access
Immediate notification to AMLO within 5 days of material breaches or significant customer complaints
Annual review of MSO procedures with certification to AMLO of continued AML/CFT compliance
Cost Summary
Capital Requirement
No statutory minimum; professional indemnity insurance required
Application & Licensing Fees
HKD 50,000-100,000 application + HKD 40,000-80,000 annual
Jurisdiction Setup Cost
$120,000-$350,000
Annual: $100,000-$300,000
Other Hong Kong Licenses
Explore other license types available in Hong Kong.
VATP License
Stablecoin Issuer License
Type 9 Asset Management License
Type 1 Dealing in Securities
Need help with Money Service Operator License?
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