Jurisdictions/Hong Kong/Type 9 Asset Management License
馃嚟馃嚢Hong KongSecurities and Futures Commission (SFC) / Hong Kong Monetary Authority (HKMA)

Type 9 Asset Management License

SFC license for managing crypto investment funds where virtual assets exceed 10% of gross asset value.

Securities and Futures Ordinance, SFC Type 9 Regulated Activity

Capital Required

HKD 5,000,000 paid-up + HKD 3,000,000 liquid capital

Timeline

4-6 months

Fees

HKD 250,000 application + HKD 100,000-150,000 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

1

Minimum HKD 5,000,000 paid-up share capital and HKD 3,000,000 liquid capital continuously per SFO Type 9

2

Two Responsible Officers (RO) with Type 9 competency certifications and fund management experience

3

Detailed fund management policies specifying crypto exposure limits (>10% triggers Type 9), leverage, and valuation

4

Qualified custodian with SFC license for asset safekeeping and segregation of holdings

5

Annual independent audits of fund accounts and quarterly investor reporting with NAV valuations

6

Professional indemnity insurance of minimum HKD 1,000,000-2,000,000 covering fund liabilities

7

Clear fund prospectus with transparent fee structures, risk disclosures, and performance fee methodologies

8

Cybersecurity framework meeting SFC Technology Risk Management Guidelines with annual assessments

Application Process

1

Submit SFC Type 9 Asset Management License application specifying fund strategies and crypto exposure

2

Provide fund documentation including prospectus, investment policy, and custody/administration agreements

3

Submit CVs for two Responsible Officers with Type 9 competency certifications and fit-and-proper declarations

4

Arrange custodian appointment with SFC-licensed institution and submit agreement documentation

5

Provide detailed fund valuation methodology and crypto asset pricing sources with verification procedures

6

SFC review and approval following assessment of fund management framework and investor protections

Expected Total Timeline

4-6 months

Ongoing Obligations

After obtaining your Type 9 Asset Management License, these are the continuing compliance requirements you must maintain.

Quarterly fund valuations with investor reporting including asset composition, performance, and fees

Annual independent audit of fund accounts by SFC-approved auditors within 4 months of year-end

Monthly custodian reconciliation statements and quarterly verification of segregation and NAV accuracy

Annual fit-and-proper assessments for both Responsible Officers with mandatory SFC notification

Quarterly compliance certifications regarding investment policy adherence and crypto exposure limits

Annual cybersecurity assessments and documented testing results submitted to SFC per guidelines

Cost Summary

Capital Requirement

HKD 5,000,000 paid-up + HKD 3,000,000 liquid capital

Application & Licensing Fees

HKD 250,000 application + HKD 100,000-150,000 annual

Jurisdiction Setup Cost

$120,000-$350,000

Annual: $100,000-$300,000

Need help with Type 9 Asset Management License?

Our team manages the full Hong Kong licensing process -from application preparation through post-approval implementation.

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