APAC Monthly Private Wealth Legal Developments - September 2025
Blog Private Wealth and Trust Disputes Notes

Australia

ASIC remakes managed investment products consideration instrument

ASIC has announced that it has remade ASIC Instrument 2015/847 which governed the pricing of interests in managed investment schemes, other than time-share schemes, registered before 1 October 2013. ASIC Instrument 2025/629 continues the relief available under ASIC Instrument 2015/847 with minor changes which:

• simplify the requirements to document exercises of discretion affecting the pricing of interests;
• reduce the level of prescription in the instrument’s provisions; and
• provide that schemes with interests quoted on a financial market operated by Cboe Australia Pty Ltd may rely on the relief.

Relief was extended to schemes with interests quoted on a financial market operated by Cboe Australia Pty Ltd in response to consultation feedback that the instruments should be drafted in a more market-neutral manner.  [29 Sep 2025]

ASIC: Rest Super pays two infringement notices for alleged false or misleading representations

ASIC has announced that Retail Employees Superannuation Pty Ltd (Rest Super) has paid two infringement notices totalling $37,560 which were issued by ASIC for alleged false or misleading representations. From June 2024 until January 2025, Rest Super issued statements to certain members indicating they had death, total and permanent disability and/or income protection insurance in the fund, despite these members not holding such insurance.

The statements issued contained the alleged false or misleading representations that Rest Super had a right to activate insurance cover for the members and deduct insurance premiums from the member’s superannuation account. Addressing member service failures in the superannuation sector aligns with ASIC’s 2024/25 strategic priority to secure better retirement outcomes and members services.  [29 Sep 2025]

ASIC outlines approach to breach and complaints data publications

ASIC has published a feedback statement which outlines its approach to publishing two public-facing dashboards containing Internal Dispute Resolution (IDR) and Reportable Situations (RS) data.

Following consultation, ASIC has decided to proceed with plans to publish IDR data at firm-level. However, it has decided not to proceed with its initial proposal to publish firm-level RS data; ASIC will instead publish aggregate-level RS data.

While proceeding with plans to publish firm-level IDR data, ASIC has made changes to how the data will be presented, including around complainant privacy, data comparisons, and explanatory material to support contextualisation.

ASIC plans to publish the RS dashboard in October and the IDR dashboard later in 2025.  [25 Sep 2025]

ASIC issues DDO stop orders against La Trobe Australian Credit Fund and US Private Credit Fund

ASIC has announced that it has made interim design and distribution obligations (DDO) stop orders against:

• the 12 Month Term Account and 2 Year Account products offered under the La Trobe Australian Credit Fund, a registered managed investment scheme operated by La Trobe Financial Asset Management Limited (La Trobe); and
• the La Trobe US Private Credit Fund, a registered managed investment scheme operated by La Trobe.

The orders were made due to deficiencies in the target market determination (TMD) for the funds.

More specifically, in relation to the Australian Credit Fund, ASIC is concerned that the target market for the 12 Month Term Account and 2 Year Account products suggest an inappropriate level of portfolio allocation given the risks of the fund, and do not include appropriate distribution conditions. As for the US Private Credit Fund, ASIC is also concerned that the TMD suggests an inappropriate level of portfolio allocation given the risks of the fund, and that it does not adequately specify an investment timeframe for retail clients.

The interim orders prevent La Trobe from dealing in interests giving a product disclosure statement for, or providing general financial product advice to, retail clients recommending an investment in the 12 Month Term Account and 2 Year Account products offered under the Australian Credit Fund, and the US Private Credit Fund generally. The orders are valid for 21 days unless revoked earlier.  [18 Sep 2025]

ASIC supports innovation through exemptions for distributors of Australian stablecoin

ASIC has announced that it has granted class relief for intermediaries engaging in the secondary distribution of a stablecoin issued by an Australian financial services (AFS) licensed issuer. As and when more issuers of eligible stablecoins obtain an AFS licence, ASIC will consider extending the above relief to intermediaries distributing those stablecoins.

The first-of-its-kind relief exempts intermediaries from the requirement to hold separate AFS, Australian market, or clearing and settlement facility licences when providing services related to stablecoins issued by an AFS licensee. Intermediaries benefiting from this relief must make the exempt stablecoin’s product disclosure statement available to their clients (where an issuer has prepared a Product Disclosure Statement).

The relief instrument – ASIC Corporations (Stablecoin Distribution Exemption) Instrument 2025-631 – will take effect once registered on the Federal Registration of Legislation. ASIC’s explanatory statement is also available.  [18 Sep 2025]

ASIC issues new legislative instrument to facilitate digital disclosures

ASIC has announced the making of a new legislative instrument to continue relief provided for digital disclosures. The instrument consolidates the relief previously provided in ASIC Corporations (Facilitating Electronic Delivery of Financial Services Disclosure) Instrument 2015/647 and ASIC Corporations (Removing Barriers to Electronic Disclosure) Instrument 2015/649 (the electronic disclosure instruments), which will sunset on 1 October 2025.

ASIC assessed that the relief was operating effectively and continues to form a necessary part of the legislative framework, but made minor amendments to the relief to update references. The relief under Instrument 2015/649 has been extended to a Cash Settlement Fact Sheet ensuring consistency with other financial services disclosures. The new instrument will expire on 1 October 2030.  [18 Sep 2025]

ASIC and APRA host superannuation CEOs to discuss high-risk superannuation switching

APRA and ASIC have released public notes from the Superannuation CEO roundtable held on 27 August 2025, attended by ten superannuation trustee CEOs that manage the majority of superannuation platform products. Attendees discussed issues related to high-risk superannuation switching models and the urgent need to lift practices to prevent future harm to investors and consumers. Other topics discussed included:

• the impact of the Shield Master Fund and First Guardian Master Fund matters on the superannuation system, including the potential for them to weaken confidence in the system;
• trustees’ responsibilities under the SIS Act;
• trustees’ oversight of advice fee deductions;
• possible steps for trustees’ to improve governance, risk detection and adviser monitoring;
• the tools being used to identify anomalies; and
• the need for industry collaboration, shared standards, and real-time data to best protect members and address systemic risks.  [18 Sep 2025]

AFMA makes changes to repurchase agreements conventions

The Australian Financial Markets Association (AFMA) has advised its members and market participants generally that its repurchase agreements committee (Repo Committee) has voted to adopt various changes to its Repo Conventions. The new conventions and amendments are to take effect from 16 September 2025. The changes include:

• amendments to define 'evergreen repos' and 'extendable repos' so that the definitions are more consistent with the European Repo and Collateral Council (ERCC) definitions (sections 2.4 and 2.5);
• amendments to the definition of general collateral (GC1) to remove the adjective 'actively traded' because it is not necessary (section 3.1.1);
• the adoption of a convention to provide high-level guidance for market participants with marked-to-market considerations with substitutions (section 3.7); and
• the adoption of an addendum to the conventions to clarify what is required from market participants when applying for a settlement extension from the Reserve Bank Information and Transfer System (RITS) (addendum 3). [15 Sep 2025]

FSC Policy Update – Issue 86: Key developments across financial services

The Financial Services Council (FSC) has released Issue 86 of the FSC Policy Update, which outlines recent legislative and regulatory changes affecting the financial services industry. It covers updates in superannuation, investments, financial advice, tax, technology, and innovation. The issue highlights what is shaping the sector and provides links to detailed insights on each topic.  [12 Sep 2025]

ASIC to remake financial advice relief instruments

ASIC has made a new legislative instrument that continues the relief provided under the following three financial advice-related instruments that are due to sunset on 1 October 2025:

• ASIC Corporations (Advertising by Product Issuers) Instrument 2015/539
• ASIC Corporations (General Advice Warning) Instrument 2015/540
• ASIC Corporations (Financial Services Guides) Instrument 2015/541 

The relief provided helps reduce compliance burdens for AFS licensees when giving general advice, particularly in advertisements and expert reports.  For example, Instrument 2015/539 exempts product issuers from needing an AFS licence for general advice in ads, provided the ad includes a disclaimer, while Instrument 2015/540 allows verbal general advice warnings instead of written ones. Instrument 2015/541 exempts experts from providing a Financial Services Guide when giving general advice in a report included in a disclosure document.  [11 Sep 2025]

ASIC granted leave to appeal Block Earner decision

The High Court of Australia has granted the ASIC special leave to appeal a decision involving Block Earner, a crypto-related financial services provider.

Block Earner, trading as Web3 Ventures Pty Ltd, offered a product called Earner, which allowed consumers to earn fixed returns by lending crypto-assets. ASIC alleged that this product was a financial product under the Corporations Act 2001 and should have been offered under a financial services licence.

In February 2024, the Federal Court found that Block Earner had engaged in unlicensed financial services conduct when offering the Earner product. However, the court dismissed ASIC’s claims regarding another product, Access, and later relieved Block Earner from paying penalties for the Earner product. ASIC appealed the penalty relief decision, while Block Earner cross-appealed the finding that it needed a licence. In April 2025, the Full Federal Court found in favour of Block Earner, dismissing ASIC’s appeal and allowing Block Earner’s cross-appeal.

ASIC is now seeking clarity from the High Court on what constitutes a financial product, especially in cases involving interest-earning crypto products and asset conversion mechanisms. ASIC argues that the definition of financial product is meant to be broad and technology-neutral, and that clarification is in the public interest. The High Court will hear the appeal on a date yet to be set. The outcome could have wide implications for how crypto-related offerings are regulated in Australia.  [5 Sep 2025]

ASIC: Financial firm fined for market gatekeeper failures

ASIC has announced that a financial services firm operating in Australia has been fined $3.88 million by the Market Disciplinary Panel (MDP) for failing to prevent suspicious trading activity on the ASX 24 Market. The penalty follows an investigation by ASIC.

Between May 2023 and February 2024, two clients of the firm placed 33 suspicious orders in electricity and wheat futures contracts. These orders were made in the final minutes before market close and were intended to influence the daily settlement price - a practice known as ‘marking the close’. ASIC noted that the trades occurred during a volatile period in global energy and wheat markets, partly due to supply issues linked to the Russia–Ukraine war.

Despite being contacted by ASIC five times in 2023, the firm did not take effective action. The MDP found its response inadequate, citing deficiencies in compliance and surveillance systems, as well as poor training and oversight in monitoring client trading activity.

The firm is one of the largest participants in the ASX 24 Market. ASIC Chair Joe Longo said the case highlights the importance of market gatekeepers in maintaining integrity and public confidence. He warned that misconduct in energy and commodity derivatives remains a regulatory priority. This is ASIC’s fifth enforcement action in 15 months related to manipulation in electricity and wheat futures markets.  [2 Sep 2025]  

Hong Kong

SFC and HKMA issue supplemental joint circular to update requirements on intermediaries’ VA-related activities

The SFC and the HKMA have issued a supplemental joint circular to intermediaries engaging (or intending to engage) in virtual asset (VA)-related activities, including certain VA dealing services, advisory services, asset management services and/or distribution of investment products with exposure to VAs.  This circular updates the requirements under the joint circular issued on 22 December 2023 (see our previous update).

The SFC and the HKMA have conducted a review of the 2023 joint circular in light of market developments and industry feedback, and are introducing some refinements and relaxations to the requirements with a view to facilitating market development while adhering to investor protection.  These are set out in the supplemental joint circular, and corresponding updates have been made to the Licensing or registration conditions and terms and conditions for licensed corporations or registered institutions providing virtual asset dealing services and virtual asset advisory services (Appendix 6 of the 2023 joint circular).  The updated clean and marked-up versions of these terms and conditions are respectively attached as Appendix A and Appendix B to the supplemental joint circular.

• In April 2025, the SFC issued requirements on staking for licensed platforms and authorised VA funds (see our previous update) and the HKMA issued similar guidance for authorised financial institutions and subsidiaries of locally incorporated authorised financial institutions (see our previous update).  Intermediaries are therefore allowed to provide staking services to their clients subject to complying with the relevant requirements.
• Licensed corporations and registered institutions may now execute trades via the off-platform VA trading services of SFC-licensed platforms.
• The SFC and the HKMA clarify that client subscriptions and redemptions of investment products using VAs or in-kind subscriptions or redemptions of VA funds will not be treated as the provision of VA dealing services.  Intermediaries should notify the SFC (and the HKMA, where applicable) of such activities in advance and comply with other relevant requirements.
• The net worth and risk disclosure statement requirements under paragraph 6.2 and 13 of the 2023 joint circular do not apply to clients who are institutional professional investors or qualified corporate professional investors.

The supplemental joint circular also reminds intermediaries to notify the SFC (and the HKMA, where applicable) before making changes to their VA-related activities, and provide the information set out in the circular.

As for activities involving specified stablecoins issued by an HKMA-licensed issuer under the Stablecoins Ordinance, the SFC and the HKMA will issue guidance in the near future.

Separately, the SFC is inviting tenders for providing system implementation services of a VA trade surveillance system.  [30 Sep & 3 Oct 2025]

SEHK launches consultation on proposed enhancements to structured products listing framework

The Stock Exchange of Hong Kong Limited (SEHK) has published a consultation paper to seek market feedback on proposed amendments to the listing regime for structured products under Chapter 15A of the Listing Rules.  The consultation period will run for six weeks, closing on 11 November 2025.

The proposals are aimed at ensuring that the structured product listing framework is fit for purpose and globally competitive.  It is hoped that the proposals will foster continued product innovation and enhance market efficiency, while upholding robust standards of market quality and investor protection.

The key proposals aim to achieve three objectives:

1. Increasing market competitiveness, for example:

• Lowering the minimum issue price requirement for derivative warrants from HK$0.25 to HK$0.15, and removing the minimum issue price for callable bull/bear contracts;
• Changing the eligibility threshold for an exchange traded fund as underlying security for structured products issuance to at least HK$1 billion of assets under management, from at least HK$4 billion of public float capitalisation, over a 60-day qualifying period;

2. Enhancing market quality and investor protection, for example:

• Raising the minimum net asset value requirement for issuers from HK$2 billion to HK$5 billion and mandating that issuers be regulated entities;
• Mandating investment grade ratings by all credit rating agencies from which credit ratings are sought (the credit rating requirement may be fulfilled by the issuers, guarantors or their respective holding companies);
• Mandating the minimum service level for liquidity provision specified in the listing documents to comply with minimum service levels as published by the SEHK from time to time;

3. Elevating market efficiency, for example:

• Removing the requirement to publish launch announcement and streamlining listing document for further issues of structured products to reduce issuers’ administrative burden without compromising the amount of information available to investors.  [30 Sep 2025]

SFC appoints Interim Head of Investment Products

The SFC has appointed Ms Alexandra Yeong, Senior Director of Investment Products, as Interim Head of Investment Products with effect from 1 November 2025, pending the appointment of a new Executive Director to head the Investment Products Division.  This was necessary given that the current Head of Investment Products, Ms Christina Choi, will assume the role of Executive Director of Corporate Finance from 1 November 2025.

Ms Yeong joined the SFC in 2007 and worked in the Supervision of Markets Division and the Corporate Finance Division prior to being transferred to the Investment Products Division.  She was promoted to her current position in 2017 to direct investment products activities including the review of the Code on Unit Trusts and Mutual Funds, supervising assessments on collective investment schemes, and formulating policy work relating to investment products.  [30 Sep 2025]

HKEX publishes Compliance Bulletin (Issue no. 15) reminding participants of obligations relating to deposit of securities and usage of COCA

The HKEX has published the 15th issue of its Compliance Bulletin to remind participants of the following requirements:

• Hong Kong Securities Clearing Company Limited (HKSCC) participants' obligations in relation to the deposit of securities – The HKSCC circular of 6 August 2025 reminded participants in relation to such obligations (see our previous update).  HKSCC participants should implement robust control measures to ensure that all deposit orders are properly verified for authenticity and eligibility.
• Usage of Client Offset Claim Account (COCA) – The HKEX notes that during its ongoing monitoring of clearing participants’ activities, it was observed that some participants of the HKFE Clearing Corporation Limited and the SEHK Options Clearing House Limited had misunderstood certain requirements and displayed inappropriate usage of the COCA.  The attachment to the compliance bulletin explains the relevant COCA requirements, highlights common deficiencies observed, and provides clarifications to frequently asked questions.

The HKEX notes that the requirements and examples set out in the compliance bulletin are not exhaustive.  Participants should take into consideration their own circumstances to ensure full compliance with the relevant rules and requirements, and seek their own professional advice on their specific situations where appropriate.

The HKEX strongly advises participants to review their current set up and implement appropriate measures to strengthen their controls.  Where necessary, they should take appropriate action to address any potential rule breaches or deficiencies.  [30 Sep 2025]

OTC Clear reminds clearing members of payment obligations and strongly recommends review of existing procedures

The OTC Clearing Hong Kong Limited (OTC Clear) has issued a circular to remind clearing members of the importance of having proper risk management and robust funding arrangements in place to adequately monitor their exposure and fulfill their OTC Clear payment obligations on time.

As a best practice, members should have in place established procedures to project the amount of payment obligations to OTC Clear and arrange sufficient funding to meet such requirements in a timely manner.  Clearing members should refer to the Clearing Procedures provisions highlighted in the circular as well as the summary of payment obligations set out in the Appendix to the circular.

Failure to adhere to settlement timelines constitutes an event of default, the consequences of which include disciplinary proceedings and/or disciplinary actions, which may lead to suspension of membership and/or imposition of penalties.

OTC Clear strongly advises clearing members to review their existing operational and monitoring procedures and introduce enhancement measures where appropriate. The following are some examples of the areas that should be covered in the review:

• Operational capabilities to perform trade affirmation, contract settlement, portfolio valuation, portfolio reporting and system linkage with an Approved Trade Registration System;
• Adequate risk management systems;
• Contingency and business continuity plan, such as back up sites and system connection resilience; and
• Back-up staff arrangements.  [30 Sep 2025]

SFC reprimands and fines licensed corporation HK$2.1 million for mishandling of client money

The SFC has reprimanded and fined Roofer Securities Limited (Roofer) HK$2.1 million for regulatory breaches relating to mishandling of client money.

Following a referral by the HKEX, the SFC conducted an investigation, which found that between 8 February 2021 and 7 July 2022, there were 12 incidents where Roofer had failed to maintain sufficient funds in its segregated client account.  On one occasion, the shortfall in the client account reached HK$15.5 million.  These incidents were the result of Roofer’s use of client money to meet margin calls made (or anticipated to be made) by the HKEX, failure to properly manage its daily online bank transfer limit, and human error on the part of its staff.

The SFC considers that the above constituted breaches of various provisions of the Securities and Futures (Client Money) Rules and the SFC’s main code of conduct.

Roofer has taken remedial actions, including enhancing its internal controls and processes and rectifying the under-segregation of client money shortly following each incident.  [29 Sep 2025]

SFC and HKMA issue joint circular on concurrent thematic review of intermediaries’ distribution of non-exchange traded investment products

The SFC and the HKMA have issued a joint circular announcing the commencement of a new round of concurrent thematic review of intermediaries’ distribution of non-exchange traded investment products, with a focus on collective investment schemes (CIS).

The 2024 SFC-HKMA joint product survey, released in September 2025, recorded significant sales growth across all major investment product types, with CIS sales rising by 76% year-on-year.  

• The upcoming review will examine selected intermediaries’ policies and procedures, systems and controls, and management oversight in the distribution of CIS.
• Key objectives include evaluating compliance with the suitability requirement under the SFC’s main code of conduct, including practices relating to product due diligence, suitability assessments, and the provision of information to clients.

HKMA commences consultation with retail banks on proposed framework for sharing responsibility in relation to losses arising from authorised payment scams

The HKMA’s Deputy Chief Executive, Mr Arthur Yuen, has published an inSight article stating that the HKMA has commenced a consultation with retail banks on a proposed framework for sharing responsibility in relation to losses arising from authorised payment scams.

Since the scam transactions are authorised by the customers, the responsibility to verify the transactions lies with the customers to avoid being scammed before giving authorisation.  At the same time, the HKMA considers that banks should also have effective anti-scam measures in place to proactively assist customers in protecting themselves from scams.  In reality, delineating responsibility for losses in authorised payment scams can be complicated.

Mr Yuen shared some preliminary thoughts regarding the considerations under the proposed framework:

• Whether banks have proactive and effective monitoring systems and control measures in place to help customers identify and prevent scams;
• What responsibility customers should bear; and
• Actual circumstances of the case and the customer’s background (for example, whether the customer is an elderly person).

Mr Yuen indicated that the HKMA will have in-depth deliberations with banks during the consultation process, but that a binary or one-size-fits-all approach should be avoided.

He also noted that some jurisdictions have begun to put in place arrangements for determining the responsibility for losses of different parties involved in a scam, but a consistent approach has yet to emerge.  Depending on local circumstances, there are various approaches:

• One that only covers unauthorised transactions resulting from phishing scams and states that banks bear no responsibility beyond providing basic reminders, with the loss primarily borne by the customers;
• One that requires banks to bear a portion of the losses resulting from authorised payment scams; and
• One that imposes fines on banks and other responsible parties that fail their scam prevention responsibilities, but does not order compensation to customers.  [26 Sep 2025]

HKMA and Mainland regulators launch cross-boundary bond repo business

The HKMA has announced the launch of the cross-boundary bond repurchase (repo) business, which it has jointly advocated with the People’s Bank of China, the China Securities Regulatory Commission and the State Administration of Foreign Exchange.  Relevant Mainland financial authorities and regulators have jointly issued the “Notice to Further Supporting Overseas Institutional Investors in Conducting Bond Repo Business in China’s Bond Market”.  This initiative was highlighted by Mr Eddie Yue (Chief Executive of the HKMA) in his keynote speech at the Treasury Markets Summit 2025.

Under the new policy measure, all overseas institutional investors already investing in the onshore bond market, including Bond Connect investors, will be allowed to participate in the onshore repo business and remit RMB liquidity obtained for offshore use.  It is expected to provide more stable liquidity support for Hong Kong’s offshore RMB market, and effectively lower the RMB funding cost.  

This measure follows the HKMA’s launch of the offshore RMB repo business in February 2025 (see our previous update regarding recent enhancements).

The cross-boundary repo and offshore RMB repo businesses will complement each other in addressing offshore investors’ needs of asset allocation and liquidity management.  It will help activate offshore investors’ onshore bond holdings and further enhance the attractiveness of onshore bonds, thereby promoting the use of RMB as an investment and funding currency in the international markets.  [26 Sep 2025]

HKEX clearing houses remind participants of payment obligations and strongly recommends review of existing procedures

The Hong Kong Securities Clearing Company Limited (HKSCC) has issued a circular to remind clearing participants of the importance of having proper risk management and robust funding arrangements in place to adequately monitor their exposures and fulfil their payment obligations on time.

As a best practice, participants should have in place established procedures and capability to assess the reports needed to project the amount of payment obligations to the HKSCC and arrange sufficient funding to meet such requirements in a timely manner.  A summary of the payment obligations and information on cash prepayment are set out in the Appendix to the circular.

Failure to adhere to settlement timelines constitutes an event of default, the consequences of which include default actions and/or disciplinary actions, which may lead to trading suspension, imposition of penalties and/or additional risk management measures.

HKSCC strongly advises clearing participants to review their existing operational and monitoring procedures and introduce enhancement measures where appropriate.  The following are some examples of the areas that should be covered in the review:

• Funding estimation and position management procedures for collateral requirements and continuous net settlement obligations;
• Funding arrangement procedures;
• Adequacy of funding and bank facilities, particularly for non-HKD;
• Money and stock settlement procedures;
• Contingency and business continuity plan, such as back up sites and system connection resilience;
• Effectiveness of exposure monitoring;
• Back-up staff and remote access arrangement; and
• Whether contact records are kept up-to-date. 

The HKFE Clearing Corporation Limited and the and the SEHK Options Clearing House Limited have issued similar circulars to remind their participants of payment obligations.  [23 & 25 Sep 2025]

SFC and HKMA unveil roadmap to advance Hong Kong’s vision to become global fixed income and currency hub

The SFC and the HKMA have jointly announced Hong Kong’s Roadmap for the Development of Fixed Income and Currency Markets to position Hong Kong strategically as a global fixed income and currency (FIC) hub by fostering demand, liquidity and innovation.

The roadmap has been formulated in close consultation with industry stakeholders and will guide the policy making and implementation of the SFC and the HKMA to support the growth of Hong Kong’s capital markets.  It outlines 10 key initiatives across the four pillars:

Pillar 1: Boosting issuance in primary market

• Lead by example through Government bond issuance
• Promote Hong Kong’s strengths to issuers and investors in target markets
• Expand investor base including family offices, funds and corporate treasury centres

Pillar 2: Enhancing liquidity in secondary market

• Finalise implementation of over-the-counter FIC derivatives regime
• Facilitate development of a repo central counterparty

Pillar 3: Expand offshore RMB business

• Broaden offshore RMB usage
• Enhance Connect schemes to increase offshore RMB liquidity and RMB-related product offerings

Pillar 4: Next-generation infrastructure

• Future-proof FIC financial market infrastructure
• Support development of next-generation electronic trading platforms
• Facilitate market innovation and implementation of use cases for tokenised FIC products.

Ms Julia Leung (SFC CEO), Dr Kelvin Wong (SFC Chairman) and Mr Eddie Yue (HKMA Chief Executive) have offered their thoughts on the roadmap and Hong Kong's vision to become a global FIC hub.  [25 Sep 2025]

HKEX signs MOU with leading carbon exchanges in GBA to advance carbon market ecosystem

The HKEX has signed a memorandum of understanding (MOU) with the Guangzhou Emissions Exchange, the Shenzhen Green Exchange, and the Macao International Carbon Emission Exchange to cooperate in accelerating the carbon markets and green finance ecosystem development across the Greater Bay Area (GBA).

This collaboration aims to foster deeper dialogues and facilitate the exchange of expertise among the exchanges and markets participants, supporting the development of a robust and vibrant green finance ecosystem across Hong Kong and the GBA.  It also aims to enhance the connection between the mandatory and voluntary carbon markets in the Chinese Mainland and internationally. 

The Hong Kong Government has welcomed the signing of the MOU.  Core Climate, the HKEX's international carbon trading platform, is the only voluntary carbon credit trading platform in the world offering settlement in HKD and RMB.  In addition to deepening co-operation with the GBA carbon market, the Chief Executive's 2025 Policy Address also announced that the Government will work with relevant Mainland regulatory departments and authorities to study issues surrounding the country's participation in the international carbon market.  [23 Sep 2025]

SFC launches consultation on proposal to implement HKIDR at trading level for exchange-traded derivatives market, seeking feedback by 22 December 2025

The SFC has published a consultation paper on the proposal to implement an investor identification regime (HKIDR) at trading level for the exchange-traded derivatives market in Hong Kong.  Feedback on the proposal is required to be submitted by 22 December 2025.

This proposal builds upon the successful implementation of the HKIDR for the securities market in March 2023 (see our previous update), and will further enhance the SFC's capacity to monitor trading activities and detect market misconduct effectively.

• The proposed HKIDR for the exchange-traded derivatives market will cover on-exchange orders for futures contracts, options contracts and stock options traded through the Hong Kong Futures Exchange Limited (HKFE)’s trading system.
• The requirements under the proposed regime are similar to those currently set out in the HKIDR for the securities market.  Relevant regulated intermediaries (RRIs) will be required to assign a unique "Broker-to-Client Assigned Number" (BCAN) to relevant clients placing or intending to place orders for futures contracts, options contracts and stock options on the HKFE's trading system.  RRIs must collect and submit up-to-date client identification data alongside the BCAN in a file to a central data repository maintained by the HKEX within the prescribed timeframe.  Additionally, RRIs must include the BCAN in order submissions to the HKFE's trading system and implement stringent data privacy and security measures to safeguard the collection, transmission, and storage of data.

The proposed regime is expected to be implemented in the first quarter of 2028.  [22 Sep 2025]

HKEX adds LPR 1Y as reference rate under Northbound Swap Connect, and OTC Clear extends maximum tenor for clearing CNY NDIRS to 11 years

The HKEX has announced the addition of the 1-year Loan Prime Rate (LPR 1Y) into the floating reference rate options under Northbound Swap Connect, made possible by the collaboration between OTC Clearing Hong Kong Limited (OTC Clear), the China Foreign Exchange Trade System and the Shanghai Clearing House.

This is the latest enhancement in a series of initiatives to expand Swap Connect, which was launched in May 2023.  The Loan Prime Rate (LPR) has been widely used to price loans to businesses in Mainland China.  Introducing LPR interest rate swap contracts in Swap Connect will provide more tools for international investors to manage the interest rate risk of their RMB-denominated portfolio, and enhance Hong Kong's role in supporting the internationalisation of the RMB.

Separately, OTC Clear has begun extending the maximum tenor for clearing CNY non-deliverable interest rate swaps (CNY NDIRS) from 5.5 years to 11 years, offering international investors greater flexibility in managing RMB interest rate risk.  [22 Sep 2025]

Government welcomes LME's approval of three additional warehouses in Hong Kong and indicates intention to expedite other measures proposed in the 2025 Policy Address to develop commodity trading

The Government has welcomed the approval by the London Metal Exchange (LME, a subsidiary of the HKEX) of the applications to designate three warehouses in Yuen Long (ready for immediate operation) as approved warehouses.

The recent approval increases the total number of LME-approved warehouses from eight to 11, following Hong Kong's inclusion in the LME's global warehousing network in January 2025 (see our previous update),  This demonstrates the strong industry support for the policy direction to promote commodity trading as announced in the Chief Executive's 2025 Policy Address on 17 September 2025 (see our previous update), further enhancing Hong Kong's commodity trading ecosystem and consolidating its status as an international financial, shipping and trading centre.

The Secretary for Financial Services and the Treasury, Mr Christopher Hui, also made reference to other measures proposed in the 2025 Policy Address to develop commodity trading, including the establishment of the Strategic Committee on Commodities led by the Financial Secretary, deepening of the HKEX's connections with the Guangzhou Futures Exchange and other commodity markets on the Mainland, and the Government's plan to amend legislation in the first half of 2026 to provide half-rate tax concessions for commodity traders to set up businesses in Hong Kong.  [22 Sep 2025]

HKEX reminds exchange and clearing participants to prepare for severe weather trading

The Stock Exchange of Hong Kong Limited (circulars one and two), Hong Kong Futures Exchange Limited, HKFE Clearing Corporation Limited, Hong Kong Securities Clearing Company Limited, and The SEHK Options Clearing House Limited have issued circulars to remind exchange and clearing participants to prepare for severe weather trading. 

The severe weather trading arrangement has been in effect since 23 September 2024 (see our previous update).  Details of the arrangement are set out on a dedicated HKEX webpage, including FAQs and the consultation conclusions (see paragraphs 146-149 of the consultation conclusions in relation to recommended personnel arrangements during Typhoon Signal No. 8 or above).

Participants are required to support trading, clearing and settlement activities during severe conditions as they normally do on a regular trading day.  A summary of operational arrangements is provided in Attachment 1 to the respective circulars.

To ensure safety, remote working and the use of online services are strongly encouraged on severe weather trading days.  Participants are advised to perform the necessary checks to ensure their operational and system readiness, including the matters set out in Attachment 2 to the respective circulars.  [22 Sep 2025]

HKIMR releases report on long-term investing in digital economy and highlights key areas for fostering robust and competitive long-term investing landscape

The Hong Kong Institute for Monetary and Financial Research (HKIMR) has released an applied research report titled "Long-term Investing in Hong Kong: Developments and Opportunities in a Digital Economy".

The report builds upon the HKIMR's prior research on demographic changes and long-term asset markets and provides a comprehensive and updated analysis of Hong Kong’s long-term investing landscape and opportunities within the context of an evolving digital economy, based on two surveys.  Among other things, the report notes that:

• 67% of the surveyed market participants saw the crucial need to increase the supply of decumulation product options to accommodate their customers' demand for long-term financial planning.
• 72% of surveyed residents reported using digital financial services in the past year, and about 70% of the surveyed market participants reported they are currently adopting or plan to adopt mobile and web platforms to distribute long-term financial products.

Drawing on international experiences and the insights gathered from the surveys and interviews, the report highlights four key areas that are important to foster a robust and competitive long-term investing landscape in Hong Kong.  These include:

• Encouraging product development – Promoting innovative products, establishing partnerships to optimise products and services, and encouraging the participation of international reinsurance;
• Enhancing distribution channels – Further enhancing information disclosure, considering the  development of an independent financial advisory model, and expanding product distribution to meet diverse demands;
• Promoting marketing and financial education – Strengthening decumulation needs and planning awareness, increasing efforts to promote long-term products, and developing targeted financial education and investment tools; and
• Facilitating technology adoption – Enhancing scalability and reducing costs, establishing clear regulatory guidelines and policy certainty, and continuing support for regulatory sandboxes.  [22 Sep 2025]

HKMA Executive Director shares thoughts on holistic approach to protecting integrity of banking system from fraud amid continued digitalisation

The HKMA has published a keynote speech by Mr Raymond Chan, Executive Director (Enforcement and AML) of the HKMA, at the International Symposium on Digital Fraud Prevention and Detection, where he shared his thoughts on a more holistic approach to protecting the integrity of the banking system from fraud amid continued digitalisation.  

Mr Chan noted that the HKMA has made significant progress in delivering various key commitments aimed at early detection and intervention, and that there are positive signs from these measures.   Nonetheless, the HKMA fully appreciates that the number of deception cases is still rising and it will continue to work closely with the Police and the banks to further strengthen the banking sector’s ability to detect and prevent fraud:

• As a follow-up to its December 2024 circular requiring banks to put in place a dynamic fraud monitoring system (see our previous update), the HKMA has started a round of thematic reviews to test how effectively these measures have been implemented and to ensure that they are delivering the maximum possible value.  The HKMA also monitors the effectiveness of these measures by analysing the supervisory data it collects and has established regular communication with the banks to quickly share trends and good practices.  
• Throughout the next two years, the HKMA will work with a consultant to further support the use of AI by the banking industry and help banks accelerate deployment across various use cases, in particular to enhance the early identification of risks to improve outcomes of intervention.
• The Legislative Council passed amendments to the Banking Ordinance in June 2025 to allow banks to share information on personal accounts where there are indications that the accounts, customers or transactions may be involved in money laundering or other financial crimes (see our previous update).  The HKMA is working with the Police and the banking sector on preparations, including systems and safeguards, with a view to rolling out the new mechanism to monitor suspicious activity later this year.  [18 Sep 2025]

Insurance Authority and HKMA issue joint circular on naming requirements for insurance products with savings features

The Insurance Authority and the HKMA have issued a joint circular setting out the supervisory expectations for the naming of insurance products with savings features, following concerns that some of these products marketed in Hong Kong may be confused with bank deposits.

Under the joint circular, insurance products that meet one or more of the following criteria are required to include the word 'insurance' in their English product names and the word '保險' in their Chinese product names:

• Products designed to meet customers’ savings needs; or
• Products marketed or promoted as having a 'savings' feature in product brochures or any marketing materials, regardless of whether the term 'savings' or similar descriptions are used.

This requirement applies to the basic plan only and not to riders.  In addition, investment-linked assurance scheme products and qualifying deferred annuity policies, which are widely recognised as insurance products, are exempt from this requirement.

The requirement will be implemented in two phases:

• Phase 1: Effective from 1 January 2026, for all new in-scope products launched on or after this date.
• Phase 2: Effective from 1 January 2027, for all existing in-scope products that will continue to be sold on or after this date (insurers must ensure that all relevant policy documents, marketing documents, and communications are updated accordingly.

Insurers and insurance intermediaries are expected to ensure that their staff are fully informed of the requirement and to strengthen internal controls and governance frameworks to support compliance with this circular, in order to uphold the principles of treating customers fairly and acting in their best interests.  [19 Sep 2025]

SFC and UAE’s SCA sign MoU to deepen fund distribution collaboration under first Hong Kong-Middle East MRF arrangement

The SFC and the Securities and Commodities Authority (SCA) of the United Arab Emirates (UAE) have signed a memorandum of understanding (MoU) to establish a mutual recognition of funds (MRF) arrangement, enabling cross-border market access for public funds and marking a significant step in Hong Kong-UAE financial cooperation.

The MoU allows the direct offering of unlisted foreign funds to retail investors in the UAE for the first time, being the UAE’s first MRF arrangement with a jurisdiction outside the region, as well as Hong Kong’s first such arrangement with a Middle East market.  Details of the MRF arrangement are set out in the SFC's circular and the SCA's circular (attached to the MoU).

The signing took place during the Investopia Global event in Hong Kong, and follows a high-level bilateral meeting on 16 September 2025 where the two regulators reaffirmed their shared vision to enhance mutual market access and investor protection as well as to foster financial innovation.  [18 Sep 2025]

Hong Kong Chief Executive sets out initiatives to deepen reforms and expedite development of new growth areas in 2025 Policy Address

The Chief Executive of Hong Kong, Mr John Lee, has delivered his 2025 Policy Address (main address and supplement) to set out initiatives to deepen reforms and expedite development of new growth areas.  The SFC and the Insurance Authority, among others, have welcomed the initiatives.

The following are some of the areas relevant to the financial services sector:

• The Government will actively invite the Asian Infrastructure Investment Bank to set up an office in Hong Kong and the HKEX will deepen co-operation with Southeast Asian exchanges.
• Measures to further develop the Greater Bay Area (GBA) include enhancing cross-boundary credit referencing and Payment Connect, working with GBA exchanges to develop commodity trading, carbon trading and other businesses, and promoting digital finance and integration of technology and finance between Shenzhen and Hong Kong.
• The Government will continue to strengthen the stock market, including leveraging the Technology Enterprises Channel to assist Mainland technology enterprises to raise funds in Hong Kong, optimising Main Board listing and structured product regimes, considering enhancements to listing requirements for companies with weighted voting right structures, encouraging more overseas enterprises to seek secondary listing in Hong Kong, and supporting China Concept Stock companies to return from overseas markets.
• The Government will consolidate Hong Kong’s position as a bond market hub by enhancing financial infrastructure (including cross‑collateralisation of assets), considering the feasibility of an innovative electronic bond‑trading platform, developing a commercial repo market and central counterparty regime, expanding the scope of Swap Connect, and exploring cross‑boundary RMB repo business.  Details will be set out in an upcoming Fixed Income and Currency Roadmap.
• The HKMA will introduce an RMB Business Facility to provide longer‑term RMB financing, exploring diversified channels for cross-boundary capital acquisition and measures to facilitate foreign exchange quotations and transactions between RMB and other regional currencies in Hong Kong.
• The Government will implement measures to develop an international gold trading market, including building large‑scale gold storage facilities, establishing a central clearing system, offering a greater variety of gold investment vehicles and supporting the development of new investment products such as tokenised gold.
• The Government will amend legislation in 2026 to lower capital requirements for insurance infrastructure investment, promote the development of exclusive captive and reinsurance business in Hong Kong, and encourage the offering of insurance products such as those relating to cross‑boundary elderly care, cross-boundary driving and low‑altitude economy.
• The Government will enhance tax regimes for funds, single‑family offices and carried interest, promote inclusion of real estate investment trusts under mutual market access, enhance the Qualified Foreign Limited Partnerships mechanism, and adjust the New Capital Investment Entrant Scheme thresholds.
• The HKMA will advance Project Ensemble to promote tokenised deposits and assets and regularise tokenised bond issuance.  The SFC is studying the possibility of offering a wider range of digital asset products and services to professional investors with the prerequisite of sufficient investor protection in place, and plans to build a line of defence against risks associated with digital assets in Hong Kong.
• The HKEX launched an international carbon trading platform, Core Climate, in 2022. The Government will deepen co‑operation with the GBA carbon market, testing the means of cross-border trade settlement, and jointly building a regional carbon market ecosystem.  It will also study issues surrounding the country's participation in the international carbon market.
• The Government will continue the direction set out in the 2024 Policy Address to foster the development of a commodity trading ecosystem in Hong Kong.  It will set up the Strategic Committee on Commodities, led by the Financial Secretary, to bring together industry representatives with the aim of strengthening the top-down design and long-term strategy of Hong Kong's commodity policy.
• The application period for the 80% Guarantee Product under the SME Financing Guarantee Scheme will be extended for two years to the end of March 2028.  The total loan guarantee commitment under the scheme will be further increased by HK$20 billion to HK$310 billion, and the principal moratorium arrangement will be extended for one year (see the HKMA's announcement and our previous update).  [17 Sep 2025]

SFC executive director discusses balanced regulatory approach for Hong Kong's derivatives market and highlights challenges and opportunities for Asian markets

Mr Rico Leung, the SFC's Executive Director (Supervision of Markets), delivered a keynote speech at FOW Trading Asia 2025, outlining the SFC’s strategy to foster sustainable growth in Hong Kong’s derivatives market while maintaining market integrity, resilience and investor protection.

The SFC is currently exploring the extension of measures similar to the Hong Kong Investor Identification Regime for the securities market (introduced in 2023) to the exchange-traded derivatives market, which will provide more effective tools to safeguard investor interests.

Apart from market resilience, another strategic priority of the SFC is to facilitate development to enhance the global competitiveness and appeal of Hong Kong's capital market.  The two priorities work hand in hand in attracting global investors with both the reliability of the capital market and growth opportunities.  The initiatives introduced recently on this front include:

• Relaxing position limits for major index futures and options by around 40% to over 100%, allowing market participants to manage positions more flexibly, and promoting the liquidity and efficiency of both the derivatives and broader markets;
• Increasing the interest payments on cash collateral and reducing the accommodation charges on non-cash collateral from 2 October 2025 (see our previous update), which will significantly lower the cost of trading and bolster Hong Kong’s competitiveness as an international financial centre;
• Expanding margin collateral to Chinese Government Bonds since March 2025 (see our previous update), allowing market participants to make better use of RMB fixed income assets on hand to reduce their funding costs;
• Enhancing Swap Connect, including extending the maximum tenor of northbound swaps from 10 years to 30 years, providing a useful hedging tool for international investors to manage the risks of holding long-term RMB Government bonds.

Mr Leung noted persistent challenges such as Asia’s fragmented regulatory landscape, which creates complexity for cross‑border investors, and slower product innovation compared to US and European markets.  However, he sees abundant potential for innovation in Asia’s derivatives market, noting as an example that a significant amount of trading in the Chicago Mercantile Exchange’s crypto futures contracts comes from the Asia Pacific region.

Mr Leung stressed that market development and stability are no trade-off but are mutually reinforcing, and that In today’s globally competitive derivatives markets, maintaining this balance is crucial.  [17 Sep 2025]

SFC bans former RO and MIC of licensed corporation for five years over serious management failures relating to IOIs and facilitation trades

The SFC has banned an individual – a former responsible officer (RO), manager-in-charge (MIC) of a key business line, board member, and Head of Pan-Asia Equities of a licensed corporation – from re-entering the industry for five years.

This disciplinary action follows the SFC’s earlier sanctions against the licensed corporation for serious regulatory breaches and internal control failures, including the dissemination of mislabelled indications of interest (IOIs) and misrepresentations to institutional clients when executing facilitation trades over a 10-year period from 2008 to 2018 (see our previous update).

The SFC is of the view that the individual had failed to discharge his duties as an RO, an MIC, a board member and a member of the senior management of the licensed corporation, and the licensed corporation's misconduct was attributable to neglect on his part.  He is guilty of misconduct and his fitness and properness as a regulated person has been called into question.  [16 Sep 2025]

HKSCC reminds participants to maintain valid designated bank accounts in FINI for EIPO money settlement obligation

The Hong Kong Securities Clearing Company Limited (HKSCC) has issued a circular to remind participants to maintain valid designated bank accounts in the Fast Interface for New Issuance (FINI) platform for electronic IPO (EIPO) money settlement obligations.

FINI was launched in November 2023 and enhancements were implemented on 13 April 2025 (see our previous update) to enrich system functionalities and improve the overall user experience.  The FINI platform now provides flexibility to participants to designate a separate bank account dedicated exclusively for EIPO money settlement.

HKSCC strongly encourages participants intending to engage in IPOs in HKD, RMB and USD to conduct a comprehensive review of their existing designated bank account arrangements:

• Participants who currently maintain a designated bank account in FINI for EIPO money settlement are advised to verify that their respective banks are recognised FINI banks for the particular currency and are adequately equipped to facilitate EIPO settlements in HKD, RMB and USD.
• Participants who have not maintained a valid designated bank account in FINI for RMB and USD are advised to establish such accounts at the earliest opportunity to ensure operational readiness for future IPO activities involving these currencies

A list of FINI banks that support EIPO money settlement can be found in FAQ E33 of the FINI information pack, as well as in the appendix to the circular.

Participants that wish to update their respective FINI designated bank account to be different from their designated bank account maintained for money settlement in CCASS should submit a request by completing the 'FINI Designated Bank Account Maintenance Form' (see User Guide for HKSCC Participants).  [15 Sep 2025]

SFC and ADGM FSRA co-host roundtable in Hong Kong on opportunities for Hong Kong asset managers within ADGM

The SFC and the Financial Services Regulatory Authority (FSRA) of the Abu Dhabi Global Market (ADGM) have co-hosted a high-level roundtable in Hong Kong to discuss opportunities for Hong Kong asset managers within the ADGM.  The event builds on a memorandum of understanding signed between the two regulators in May 2025 (see our previous update).

More than 20 senior executives of Hong Kong asset managers attended the roundtable, with discussions led by Ms Julia Leung (SFC CEO) and Mr Emmanuel Givanakis (ADGM FSRA CEO).  A range of topics were discussed, including opportunities for Hong Kong asset managers to access investors in the ADGM and in the wider United Arab Emirates (UAE) through the UAE fund passporting regime.

Following the roundtable, an industry seminar was held where the FSRA provided insights into regulatory requirements for cross-border fund distributions for asset managers, with more than 30 attendees from the industry.  [11 Sep 2025]

SFC and DFSA sign MoU to enhance collaboration on supervision of cross-border investment management

The SFC and the Dubai Financial Services Authority (DFSA) have signed a memorandum of understanding (MoU) to strengthen cooperation on the regulatory oversight and supervision of collective investment scheme managers in each other’s markets to ensure compliance, governance, and cross-border regulatory alignment.

The MoU establishes a collaborative framework for consultation, cooperation and the exchange of information to enhance the regulators’ supervision and oversight of regulated entities engaging in cross-border investment management or advisory activities.  It is a result of joint collaborative efforts by the two regulators over the past year, including a high-level meeting (see our previous update) and a co-hosted roundtable with leading asset managers in Hong Kong (see our previous update) in 2024.

The MoU was presented as part of the MoU presentation ceremony officiated by the Chief Executive of Hong Kong, Mr John KC Lee, at the 10th Belt and Road Summit in Hong Kong, underscoring the significance of cross-border regulatory collaboration and Hong Kong’s growing ties with Belt and Road jurisdictions.  [10 Sep 2025]

HKEX hosts Climate Finance forum on accelerating transition to net-zero, launching 'Carbon Credits: A Buyer’s Guide'

The HKEX has hosted the Climate Finance Forum – themed on the journey to achieving net zero – during the Hong Kong Green Week, bringing together over 200 local and international participants. 

The forum, to be certified as a carbon offset event, explored the role of environmental attribute certificates, the rapidly evolving landscape of low-carbon investing, and other key themes shaping climate-focused investment strategies.

The HKEX launched the Carbon Credits: A Buyer’s Guide at the forum, which details the concept and mechanism of carbon credits.  From comparing project types, locations and co-benefits to navigating the intricacies of carbon crediting standards and vintages, the guide is intended to help companies make more informed decisions when selecting carbon credits that align with their corporate values and sustainability objectives.  [10 Sep 2025]

SFC and ADBI advance development of sustainable-related thematic instruments at Hong Kong roundtable

The SFC and the Asian Development Bank Institute (ADBI) have co-hosted a roundtable during the Hong Kong Green Week to exchange views on the development of sustainable finance in Asia-Pacific capital markets.

This is the fifth roundtable under the Asian Climate Finance Dialogue Project, a collaborative initiative launched by ADBI in collaboration with the Asia Development Bank (ADB) to drive policy actions that enhance climate-related disclosures and expand climate finance across the region.

The roundtable brought together senior officials from regulatory bodies in 12 Asia-Pacific jurisdictions, who shared insights on the latest trends and innovations in sustainable-related thematic instruments, including green bonds, blue bonds, and environmental, social and governance (ESG) funds.  Participants also engaged in discussions with experts from the ADB, the ADBI and the private sector on frameworks and mechanisms to facilitate the utilisation of these investment instruments as well as the mobilisation of transition finance.  [9 Sep 2025]

SFC reprimands and fines licensed corporation HK$8 million for failing to report cross trades to SEHK

The SFC has reprimanded and fined Instinet Pacific Limited (Instinet) HK$8 million for failing to report direct business transactions (ie, cross trades) to The Stock Exchange of Hong Kong Limited (SEHK).

• Between December 2012 and March 2018, Instinet failed to report 8,817 pairs of cross trades involving transactions worth around HK$25.9 billion between its clients and affiliated company to the SEHK in accordance with the reporting requirements. 
• In addition, during the relevant period, Instinet had no internal policy and procedure requiring, governing, or monitoring the reporting of cross trades to the SEHK, and did not conduct any review on its trade reporting process.

The above constituted breaches of various provisions under the Rules of the Exchange and the SFC's main code of conduct.  [8 Sep 2025]

Commencement date of 3 November 2025 appointed for voluntary mechanism for banks to request or disclose information for detection or prevention of crimes under Banking (Amendment) Ordinance

The Government has published in the Gazette a notice to appoint 3 November 2025 as the commencement date for the Banking (Amendment) Ordinance 2025.  The notice will be tabled before the Legislative Council on 10 September 2025 for negative vetting.

The amendment ordinance was published on 13 June 2025 (see our previous update) and introduces a voluntary mechanism for banks and relevant law enforcement agencies to share information of corporate and individual accounts with each other via secure platforms designated by the HKMA, when banks become aware of suspected prohibited conduct (ie money laundering, terrorist financing or financing of proliferation of weapons of mass destruction).  It also provides legal protection for banks that disclose relevant information.  [5 Sep 2025]

SFC suspends former RO and MIC of dissolved licensed corporation for 12 months over fund management failures

The SFC has suspended the licence of a former responsible officer (RO) and manager-in-charge (MIC) of various core functions of the now dissolved Agg. Asset Management Limited (Agg), Mr Chow Tsz Lam, for 12 months over fund management failures.

The disciplinary action is partly related to the SFC’s earlier sanction in December 2024 against Mr Ng Ka Shun, a sole shareholder, director and the other RO of Agg, who was banned for life and fined HK$1.7 million for window-dressing Agg’s financial resources and mismanaging two funds (see our previous update).

The SFC found that Agg, in its management of a Cayman-incorporated fund:

• failed to prevent, manage and minimise actual or potential conflicts arising from the transactions regarding 5 debentures issued by companies wholly owned and controlled by  Mr Ng, and take measures to ensure that the fund and its investors would be treated fairly;
• failed to ensure that it had sufficient risk management measures in place to properly protect investors’ interests; and
• caused the fund to invest in 2 debentures which appeared to have been constructed for the purpose of inflating the fund’s net asset value.

The SFC found that Mr Chow had failed to discharge his duties as an RO and a member of the senior management of Agg to ensure that the firm acted in the best interests of the above fund and its investors and complied with the applicable regulatory requirements.  The SFC considered a number of mitigating factors, including the fact that Mr Chow had made a report to the SFC which triggered the SFC’s investigation.  [4 Sep 2025]

SFC bans former relevant individual of registered institution for life following convictions for money laundering and contempt of court

The SFC has banned a former relevant individual and associate director of a registered institution from re-entering the industry for life in light of his criminal convictions for money laundering and committal for contempt of court.

The case involved the relevant individual’s arrangement to facilitate cross-border fund transfers for two clients who held a joint account with the registered institution and faced difficulties in remitting RMB from Mainland China to Hong Kong.  The clients transferred over RMB132 million into Mainland bank accounts designated by the individual between November 2016 and February 2018, expecting the funds to be remitted and deposited into their joint account.  The individual provided transaction confirmations and bank statements, but the clients subsequently discovered that a significant portion of the funds was missing.

Subsequent investigations revealed that deposits totalling over HK$134 million were diverted into two Hong Kong bank accounts belonging to the individual.  The Court found that:

• the diverted deposits were proceeds of crime, being funds that were defrauded or stolen from the two clients; and
• the individual had spent the stolen proceeds on luxury vehicles and multiple properties in the UK and Mainland China.

On 21 June 2024, the Court of First Instance sentenced the individual to 10 years’ imprisonment following his guilty pleas to two counts of dealing with property known or believed to represent proceeds of indictable offence.

In July 2018, the two clients had secured a worldwide freezing injunction against the individual, prohibiting him from disposing of or dealing with any of his assets up to HK$130 million.  However, the former AD breached the injunction by assigning multiple UK properties to a BVI company he owned, resulting in a separate six-month prison sentence in December 2023 for contempt of court.  [2 Sep 2025]

HKEX enhancements to margin collateral arrangements at HKSCC, HKCC and SEOCH to take effect on 2 October 2025

The HKEX has announced that it will implement enhancements to margin collateral arrangements at its securities and derivatives clearing houses with effect from 2 October 2025.

The new arrangements include a revised approach to calculating interest paid on cash margin collateral, and lowering accommodation charges for non-cash margin collateral posted at HKEX’s clearing houses.  They are part of the HKEX’s ongoing commitment to boost market efficiency and lower costs for market participants.

• Cash collateral:  Interest payments and charges will be calculated daily based on an approach that aligns with international peers, paying an overnight reference rate, less a handling fee.  This approach will align across Hong Kong Securities Clearing Company Limited (HKSCC), HKFE Clearing Corporation Limited (HKCC) and The SEHK Options Clearing House Limited (SEOCH), and across all currencies that are accepted as collateral. The handling fee will initially start at 0.8% between October 2025 and December 2026, and decline 10 basis points each year until reaching 0.5% by the end of 2028.
• Non-cash collateral:  The annual accommodation charge will be reduced to 0.25% from 0.5%.

Further details of the enhancements are set out in circulars issued by the HKSCC, the HKCC and the SEOCH.  Rule amendments have also been published:

• HKSCC Operational Procedures (see clean / marked-up versions);
• Rules and Procedures of HKCC (see clean / marked-up versions);
• Options Clearing Rules of SEOCH (see clean / marked-up versions);
• Operational Clearing Procedures for Options Trading Exchange Participants of SEOCH (see clean / marked-up versions).  [1 Sep 2025]

Singapore

MAS: Response to PQ on fund managers appointed under the Equity Market Development Programme

MAS has published the response to a Parliamentary question (PQ) regarding the key performance indicators (KPIs) set for fund managers under the Equity Market Development Programme (EQDP), and the timeline over which their performance will be evaluated.

In response, MAS confirmed that asset managers appointed under the EQDP will be assessed regularly for at least three years against how well they have met commitments in three areas. These relate to their ability to: mobilise capital from other commercial investors into the relevant strategies; deliver investment returns; and meet developmental commitments to deepen their presence in Singapore and contribute to the development of the equity market ecosystem.  [26 Sep 2025]

MAS: Response to PQ on banks' verification of account details

MAS has published the reply to a PQ on whether banks are required to verify both account number and account holder name when receiving or transmitting funds. MAS confirmed that it is examining how several countries have implemented account number and name matching, and is reviewing potential approaches and solutions with the banking industry.  [26 Sep 2025]

MAS: Response to PQ on investment-linked policies

MAS has published the response to a PQ regarding claims brought by the public against investment-linked policies (ILPs), particularly the number of such claims, the total quantum of consumer financial losses from resolved claims, and the median quantum for each claim. In its response, MAS stated that it works closely with the Financial Industry Disputes Resolution Centre (FIDReC) to monitor the trend of cases filed against financial institutions on all financial products, including those relating to ILPs.

MAS disclosed that the average annual number of ILP-related cases handled by FIDREC from 2017 to 2024 was 83. There were 60 ILP-related cases in H1 2025, compared with 122 for the same period in 2024. Median quantum sought by claimants was $11,300 in 2017 and $7,200 in 2024.

MAS also stated its intention to categorise ILPs as complex products. Under the proposals, a complex product will have a red-coloured heading band on the product highlights sheet to alert investors to seek advice before making a purchase. In addition, sellers of complex products must provide vulnerable customers with financial advice when they invest in such products. MAS aims to finalise the proposals in early 2026.  [25 Sep 2025]

MAS: Response to PQ on impact of US GENIUS Act on Singapore's competitiveness for regulated digital assets

MAS has published its response to a Parliamentary question (PQ) on the impact of the US Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act on Singapore's competitiveness as a global hub for regulated digital assets. It was also raised whether MAS plans to pursue recognition from the US for Singapore’s stablecoin regulatory framework as an equivalent regime under the GENIUS Act.

MAS highlighted that regulatory frameworks for stablecoins in both the US and Europe remain in their early stages of development. The authority is following these developments closely and will consider appropriate regulatory cooperation aimed at ensuring safe and secure cross-border use of regulated stablecoins. MAS also confirmed that it is working on legislative amendments to formalise the stablecoins regulatory framework, which was published in 2023, and will issue a consultation later in 2025.  [24 Sep 2025] 

MAS: Response to PQ on repeated breaches of AML requirements

MAS has published its response to a PQ regarding the same firms that were penalised for violating anti-money laundering (AML) requirements in 2016/17 and 2025. Specifically, MAS was requested to clarify: how the breaches differed for each incident; whether the Government deems these firms to have adequately enhanced their AML controls since 2016/2017; and, if so, the reasons for these institutions being penalised again in 2025.

In response, MAS stated that the 2016/17 breaches were largely due to failures in transaction monitoring arising out of deficiencies in the firms' relevant systems and controls, which have since been remediated. In 2025, MAS found breaches by these firms in other areas such as customer risk assessment, establishment and corroboration of customers’ source of wealth, and post-suspicious transaction report follow-up.  [23 Sep 2025]

MAS: Singapore agencies announce measures to restrict access to facilities for scam mules

MAS, the Singapore Police Force (SPF), the Infocomm Media Development Authority (IMDA) and the Government Technology Agency of Singapore have jointly announced that they are working with industry partners to implement new measures against scam mules. The measures will restrict scam mules' access to facilities which could be exploited to facilitate scams, such as financial, telecommunications and Singpass/Corppass services.

The restrictions may be imposed on the following groups:

• persons who have been warned, issued with composition sums, prosecuted, or convicted of mule-related offences; and
• persons under investigation for mule-related offences and are assessed to be at risk of further facilitating scams.

Mule bank accounts are used to electronically move proceeds of scams between different banks and out of the country, and make it difficult for authorities to trace them. Beyond these restrictions, sentencing advisory guidelines that recommend enhanced penalties for offenders who commit scam-related offences have been issued. Mules will face more severe penalties, including imprisonment.  [17 Sep 2025]

SGX RegCo issues proposals to streamline ETF market-maker requirements

SGX RegCo has issued proposals to streamline the requirements of designated market-makers (DMMs) for exchange-traded funds (ETFs).  SGX RegCo intends to remove administrative requirements for notification and announcement when ETF DMMs cease, or resume, bid and offer quotations.

The proposals result from a review of the regulatory framework around the trading of ETFs, and follow MAS' enhancement in July 2025 of the Grant for Equities Market Singapore Scheme for ETFs to facilitate more ETF listings.

Feedback to the consultation is requested by 26 September 2025.  [5 Sep 2025]

Malaysia

SCM: Guidelines on Social Exchange Platforms

The SCM has published a set of Guidelines on Social Exchange Platforms, paving the way for the establishment of Malaysia’s first social exchange to facilitate fundraising for social impact projects. The social exchange will provide a transparent fundraising avenue for non-profit organisations (NPOs) to raise funds for eligible social impact projects, in line with Malaysia’s sustainability and inclusion agenda. The Guidelines set out requirements for social exchange platform operators and NPOs, including eligibility, disclosure and mandatory reporting to assure donors on how funds are utilised and the outcomes achieved.  [19 Sep 2025]

Thailand

SECT amends regulations for reporting significant events by debt securities issuers

The SECT has amended its regulations for reporting significant events of debt securities issuers. The amendments aim to clarify reporting responsibilities and align them with the context of each type of debt securities, thereby reducing the burden of potentially redundant reporting. 

The amendments became effective on 16 September 2025.  [17 Sep 2025]

SECT consults on draft amendments to Sustainability-Linked Bond regulations

The SECT has launched a public consultation on draft amendments to the regulations for the issuance and offering of Sustainability-Linked Bonds (SLB) to increase flexibility and align with international developments in SLB issuance and offerings, while maintaining appropriate investor protection. The proposed amendments include:

• allowing SLBs to specify financial return features that link to the achievement of sustainability-related key performance indicators (KPIs) of the bond issuer or its affiliates (this goes beyond the existing features for coupon adjustments and structural characteristics to support other mechanisms of financial returns);
• revising the regulations to accommodate the issuance and offering of SLBs in the form of zero-coupon bonds; and
• revising the Registration Statement for Debt Offerings (Filing Form) and the Factsheet to reflect the changes outlined above.

Feedback is requested by 14 October 2025.  [15 Sep 2025]

India

RBI: Scheme for facilitating accelerated payout – inoperative accounts and unclaimed deposits

The RBI has launched a scheme to encourage banks to actively pursue customers about reactivating inoperative accounts and returning unclaimed funds from the Depositors Education Awareness (DEA) Fund. The scheme aims to reduce both the stock of existing unclaimed deposits and fresh accretion of flows to the DEA Fund. It will run for one year from 1 October 2025 to 30 September 2026.  [30 Sep 2025]

RBI renews commitment to FX Global Code

The RBI has announced that it has renewed its statement of commitment to the FX Global Code. The Code is a set of global principles of good practice in the foreign exchange (FX) market, developed to provide a common set of guidelines to promote the integrity and effective functioning of the wholesale FX market.  [24 Sep 2025]

SEBI consults on review of framework to address ‘technical glitches’ in stock brokers’ electronic trading systems

SEBI has published a consultation on proposed amendments to the framework for technical glitches in stock brokers’ online trading systems. The consultation follows representations from  various stakeholders and industry regarding the need to review the present framework. Responses are requested by 12 October 2025.  [22 Sep 2025]

IFSCA consults on internet banking services

The IFSCA has published a consultation on proposed compliance requirements with respect to various types of internet banking services – namely information service, interactive information exchange service and transactional service. Responses to the consultation are requested by 13 October 2025.  [22 Sep 2025]

SEBI: Amendments to framework on Social Stock Exchange

SEBI has issued a circular to confirm amendments to the Issue of Capital and Disclosure Requirement Regulations and the Listing Obligations and Disclosure Requirements Regulations based on the recommendations of the Social Stock Exchange Advisory Committee and  the consultation feedback.  [19 Sep 2025]

SEBI consults on reporting of value of units of AIFs to depositories

SEBI has published for consultation a draft circular on proposed guidelines with respect to the reporting of value of units of Alternative Investment Funds (AIFs) to depositories. Responses are requested by 9 October 2025.  [19 Sep 2025]

IFSCA consults on fintech sandbox framework

IFSCA has published a consultation paper on proposals to introduce a fintech sandbox framework aimed at facilitating the continued growth of fintech innovations at IFSCs from Indian and foreign jurisdictions by providing innovative facilitators like regulatory/innovation sandbox for fintech activities spanning banking, capital market, insurance and funds. Responses are requested by 10 October 2025.  [19 Sep 2025]

SEBI amends guidelines on FPIs investing in Government securities

SEBI has announced modifications to the SEBI (Foreign Portfolio Investors) Regulations, 2019 with the objective of facilitating ease of regulatory compliance for foreign portfolio investors (FPIs) investing only in Government securities. The circular will come into effect from 8 February 2026.  [10 Sep 2025]

SEBI: Revised regulatory framework for angel funds

SEBI has issued a circular which amends the SEBI (Alternative Investment Funds) Regulations, 2012 and prescribes a revised regulatory framework for angel funds. The circular has immediate effect.  [10 Sep 2025]

SEBI: Framework for AIFs to make co-investment within the AIF structure

SEBI has decided to permit Category I and Category II alternative investment funds (AIFs) to offer co-investment facility to accredited investors by launching a separate co-investment scheme within AIF Regulations. The circular has immediate effect.  [9 Sep 2025]

SEBI updates disclosure document for portfolio managers

SEBI has published an updated version of the disclosure document portfolio managers are required to provide to clients under Regulation 22(3) of SEBI (Portfolio Managers) Regulations,  2020. The update replaces Schedule V of the Regulation concerning the format of the disclosure document. All other requirements, terms and conditions will remain unchanged.  [9 Sep 2025]

SEBI streamlines process for surrender of KRA registration

SEBI has issued a circular which sets out how the process for surrender of a Know Your Client Registration Agency (KRA) registration has been streamlined so that critical operations and services of a KRA are wound down in orderly manner.  [5 Sep 2025]

Philippines

BSP issues regulations on large value cash transactions

The BSP has issued new regulations on large value cash transactions to reduce money laundering and other risks linked to the use of cash. Under Circular No. 1218 series of 2025, large value transactions above ₱500,000 (or its equivalent in foreign currency) must be conducted through traceable channels such as cheques, online fund transfers, direct credit to deposit accounts, or digital payments. The limit may be reached in a single transaction or series of transactions within one banking day.

For withdrawals beyond this limit, BSP-supervised financial institutions (BSFIs) must conduct enhanced due diligence (EDD) and, if warranted, file a suspicious transaction report. After completing EDD, BSFIs may still allow the larger payout if the customer provides additional documents or proof of a legitimate business purpose.  [18 Sep 2025]

SECP issues guidelines on exempt transactions under the Securities Regulation Code

The SECP has issued a memorandum circular which contains guidelines on exempt transactions under Section 10 the Securities Regulation Code (SRC). Section 10.1 of the SRC provides a list of certain securities that are exempt from the general registration requirement for securities that are to be sold or offered for sale or distribution in the country. Section 10.2 grants the SECP power to exempt transactions other than those listed in Section 10.1, subject to the payment of appropriate fees. The guidance outlines how companies can secure or confirm exemptions based on the aforementioned provisions.  [15 Sep 2025]

Indonesia

OJK introduces draft regulation that formalises its authority to file lawsuits as part of consumer protection mandate

The OJK has published a draft regulation formalising its authority to file lawsuits against financial services institutions and/or other parties acting in bad faith causing material losses to consumers in financial services sectors. The objective of such lawsuit is to (i) recover assets of the consumers; and/or (ii) obtain compensation for the consumer from the party responsible for the loss. This authority is part of OJK’s strengthened consumer protection mandate under Law No.21 of 2011 on OJK (as amended).

Based on the draft regulation, lawsuits may be initiated based on OJK's independent assessment on unlawful acts in financial services sectors that result in material losses to the consumers, and not at the request of the consumers. Importantly, OJK acts under the principles of institutional legal standing, which means it files the lawsuits in its capacity as a regulator and does not represent any specific party or group.

Key provisions include:

• Consumers will not bear any legal or administrative costs associated with the lawsuits.
• Verified consumers with an interest in the case will be publicly announced and may opt out within 30 working days of the announcement.

The public was invited to submit feedback on the draft regulation to OJK by 17 September 2025.  [17 Sep 2025]

OJK issues new OJK regulation on consumers complaint handling publication and reporting

OJK has issued SEOJK 20/SEOJK.08/2025 on Publication of Complaint Handling and Complaint Services Report (SEOJK 20/2025), which once effective will revoke SEOJK 17/SEOJK.07/2018.

Under this new SEOJK 20/2025 the financial services institutions must also publish their complaint handling procedures on their official website, in addition to publishing information on the handling of consumer complaints received. SEOJK 20/2025 also introduces more comprehensive guidelines for publishing and reporting consumers complaint handling applicable for financial institutions.

In addition to the publication requirement, SEOJK 20/2025 also requires financial institutions to submit reports on consumer complaints to OJK every six months. Previously, financial services institutions were required to report such complaints quarterly. SEOJK 20/2025 also expands the reporting details and introduces standardised reporting templates.

The SEOJK 20/2025 was enacted on 8 September 2025, to be effective on 1 January 2027.  [8 Sep 2025]

OJK finalising draft regulation on investment management business activities

OJK is finalising draft regulation on the conduct of investment management business activities. This new OJK Regulation will replace the existing regulation No. V.5.3 (KEP-479/BL/2009, as amended by KEP-26/BL/2010), which governs licensing of securities companies acting as investment managers.

One key highlight of this draft regulation is that OJK plans to introduce a classification of investment management companies based on their business activities (Investment Manager Business Activities or Manajer Investasi Kegiatan Usaha (MIKU)): 

MIKU 1: must have paid up capital of at least IDR25 billion and permitted to manage: 

• individual customers portfolios securities  
• money market funds that only invest in domestic money market instruments in the form of deposits (reksa dana pasar uang yang hanya berinvestasi pada instrumen pasar uang dalam negeri berupa deposito); 
• limited participation mutual fund; 
• asset-backed securities;  
• real estate investment trust;  
• investment infrastructure fund; and/or 
• other investment products determined by OJK.

MIKU 2: must have paid up capital of at least IDR50 billion and permitted to manage all types of investment products.