Stored Value Facility License in Hong Kong

• Issue and operate a stored value facility (e‑wallet or device‑based)

• Top‑up and redemption of stored value; P2P transfers; merchant payments

• Co‑branding/white‑label arrangements (subject to approvals)

• Agent/distributor networks and cash‑in/cash‑out (subject to controls)

• Locally incorporated company or eligible branch; effective management in Hong Kong

• Paid‑up capital ≥ HKD 25m; ongoing float safeguarding via: trust account(s) with authorised institutions, bank guarantee(s) or insurance arrangement(s)

• Fit & proper shareholders/directors; governance with independent control functions

• Risk management (operational, liquidity, fraud) and settlement arrangements; daily reconciliation of float

• AML/CFT programme under AMLO; sanctions screening; transaction monitoring; STRs to JFIU

• IT & cybersecurity controls per HKMA requirements; incident reporting; BCP/DR testing

• Consumer protection: clear T&Cs/fees, redemption rights, complaints handling & disclosures

• Outsourcing/vendor oversight (critical ICT, agents/distributors); data protection & retention

Core Hong Kong team (indicative):

• CEO/Responsible Officer; Company Secretary

• Head of Compliance & MLRO; Risk Manager

• Operations/Wallet Lead; Settlement/Reconciliation

• IT/Security (CISO); DevOps/Infrastructure; QA

• Finance/Accounting; External auditor

• Customer Protection/Complaints officer

• Core ledger/e‑wallet; merchant acquiring/gateway integrations; QR/FPS interfaces

• Safeguarding automation (daily client money calc, attestations); trust/guarantee workflows

• KYC/AML stack (IDV, screening, monitoring, case management)

• API‑first architecture; webhooks; developer docs

• Reporting dashboards; incident & complaints registers; audit trails & retention

• Security controls: IAM, logging/SIEM, vulnerability mgmt, pen‑tests; incident management

Hong Kong domestic authorisation; cross‑border features subject to partners and destination rules.

• Profits Tax: 16.5% (standard corporate rate).

• No VAT/GST; no capital gains tax regime.

• Payroll and other employment taxes per Hong Kong law.

• Trust/safeguarding accounts with authorised institutions in Hong Kong.

• Operational settlement accounts; FPS participation for merchant/peer payments (direct/indirect).