APAC Monthly Private Wealth Legal Developments – July 2025

Australia

ASIC seeks feedback on proposed updates to conflicts management guidance

ASIC has published a consultation on proposed updates to its Regulatory Guide 181: Licensing – Managing conflicts of interest, which provides guidance on how Australian financial services (AFS) licensees should identify and manage conflicts of interest. The proposed changes are designed to bring the guidance in line with current law and policy developments and are informed by ASIC's private markets surveillance work. The updated guide explains:

• how the law applies;
• the types of conflicts AFS licensees need to identify and manage;
• the need to have arrangements that are adequate to manage conflicts; and
• how AFS licensees can effectively manage conflicts.

Feedback on the proposed updates are due by 5 September 2025. [30 Jul 2025]

Keynote address by ASIC Chair Joe Longo

ASIC Chair Joe Longo has delivered a Keynote address to the FSC Symposium, 'Shaping Advice in a Time of Change'. The address discussed misconduct in financial services, particularly superannuation, by a small number of 'bad actors' who risk 'damaging trust in the system'.

The address touched on ASIC's perceived need for greater data collection powers, a stricter managed investment scheme registration regime and encouraged regulatory reform. [30 Jul 2025]

Green Paper explores opportunities to modernise the financial advice licensing framework

FSC has released a Green Paper examining the case for reforming Australia's financial advice licensing framework. The goals of the reforms are to better protect consumers, support a diverse and professional advice sector and ensure the regulatory model remains fit for purpose in a changing environment. The examination follows concerns that risks in the framework are no longer appropriately accounted for or borne fairly amongst the varied industry participants. The paper discusses several proposals that aim to create:

• a recalibrated licensing regime that responds to firm diversity;
• balanced accountability between licensees and advisers that empowers individual practitioners; and
• financial resource and other requirements that adequately protect consumers Industry.

Feedback to the Green Paper is requested by 21 November 2025. An FSC White Paper on the Future of Advice Licensing will be released in early 2026. [28 Jul 2025]

Full Court of the Federal Court dismisses ASIC's appeal against decision finding crypto-based product was not a 'debenture'

The Full Court of the Federal Court of Australia (Full Court) has dismissed an appeal brought by ASIC against a decision of the Federal Court of Australia (primary decision), which found that Wallet Ventures Pty Ltd (Wallet Ventures) had not engaged in unlicensed financial conduct.

Facts:

Wallet Ventures, a registered digital currency exchange, operated an exchange service through which customers could buy and sell certain cryptocurrencies. Separately, it also offered a mobile application known as 'Finder', which allowed its customers to access the 'Finder Earn' product. Customers could invest in the Finder Earner product by exchanging funds in their 'Finder Wallet' account to obtain 'TrueAUD' stablecoins, the ownership of which was transferred to Wallet Ventures to enable the customers to earn a 'return' quantified in 'TrueAUD' which, upon the expiry of the term, was credited to the customer's Finder Wallet account in Australian dollars.

Primary decision:

ASIC argued before the primary judge that the Finder Earn product was a 'debenture' within the meaning of the Corporations Act because it involved an undertaking by Wallet Ventures to repay as a debt the money customers deposited with it. If it was a debenture, Wallet Ventures was required to have held an Australian financial services licence, which it did not.

The primary judge rejected the argument that the 'Finder Earner' product was a debenture on the basis that (i) there was no money' deposited with or loaned to' Wallet Ventures and (ii) if there was a deposit or loan, it was not made to Wallet Ventures as part of the company's working capital. The primary judge found that, under the particular terms of service, it was TrueAUD, not money, that was 'transferred or loaned' to Wallet Ventures. Further, the primary judge concluded that, even if there had been a loan of money, the meaning of 'debenture' under the legislation required that it be made as part of the company's 'working capital', which it was not.

Decision of the Full Court:

The Full Court dismissed ASIC's appeal against the primary decision, agreeing with the primary judge that the Finder Earner product did not 'answer the statutory requirement of "money" deposited with or lent to [Wallet Ventures]'. In light of that finding, it was unnecessary for the Full Court to consider the primary judge's separate conclusion that, if there had been a loan of money, it was not part of the company's 'working capital' as required under the legislation.

ASIC is considering the decision. [24 Jul 2025]

ASIC Chair Joe Longo addresses ABA Conference, highlights opportunities and risks of AI

The Chair of ASIC, Joe Longo, delivered a speech at the ABA Banking Conference . The address, titled 'AI: A Better Blueprint for Banking', outlined the regulator's evolving stance on the use of AI in the provision of financial services.

Mr Longo acknowledged the 'exciting' potential of AI and the potential benefits it offers in the delivery of financial services – including, for example, enhanced scam detection and assessment of customer complaints. At the same time, he cautioned that the technology comes with significant risks. He noted that Australians' trust in AI has declined, partly due to perceptions that it is being imposed on consumers and diminishing the quality of customer service.

Despite the risks AI poses, Mr Longo stated that the position of ASIC was not to 'rush into more AI regulation'. This, he argued, would not be appropriate given, first, existing financial services laws are technology-neutral and therefore already serve as important guardrails in the use of AI. Second, Mr Longo observed that the 'more specific' regulation becomes, the 'more complex' it gets. This complexity makes it 'harder to comply with' and 'harder for regulators to enforce' – while at the same time being a 'handbrake on innovation'. However, Mr Longo noted that ASIC was continually reviewing its position to assess whether further, targeted regulation is required.

In the absence of new, AI-specific regulation, Mr Longo emphasised that financial services providers should expect ASIC to be 'bolder' about how it used its existing powers. His advice for financial firms was to remember that 'good AI innovation keeps the customer front and centre', and he indicated that ASIC had no intention of holding back 'customer-centric AI innovation'. [23 Jul 2025]

ASIC issues infringement notices to two Australian financial services licensees for allowing advisers to provide advice while unregistered

Skye Money Pty Ltd and Smart Financial Capital Pty Ltd have each paid $31,300 to comply with infringement notices issued on 16 June 2025 by ASIC.

These notices, which are published on the infringement notices register, were issued as a consequence of each company allowing a financial adviser to provide advice to retail clients while unregistered. Skye Money Pty Ltd and Smart Financial Capital Pty Ltd self-reported these breaches to ASIC and each subsequently registered their financial adviser; these circumstances were mitigating factors considered by ASIC when determining its approach to enforcement action. [17 Jul 2025]

AFCA releases updated Approach to Responsible Lending

Following a consultation process with financial firms and consumer groups in February 2025, AFCA has released its updated Approach to Responsible Lending. Amongst other things, the updated Approach further clarifies how AFCA calculates the losses of complainants and the associated compensation that financial firms may be required to pay as a result of failing to meet their responsible lending obligations. [11 Jul 2025]

ASIC: Tokenised asset research project reaches new milestone

The Reserve Bank of Australia and the Digital Finance Cooperative Research Centre have announced the industry participants selected for their tokenised asset settlement research project (Project Acacia). Project Acacia aims to explore how innovations in digital money and settlement infrastructure could support the development of tokenised assets in financial markets.

To support this research, ASIC is providing regulatory relief to participants. This ensures that Project Acacia can proceed without the usual regulatory constraints, allowing for a more flexible and innovative approach.

Project Acacia is a significant step towards understanding and potentially integrating tokenised assets into the financial system. The goal is to achieve more efficient and secure settlement processes, which could revolutionize the way financial transactions are conducted.

Testing of use cases will occur over the next six months, with a report on the findings from the project expected to be published in the first quarter of 2026. [10 Jul 2025]

ASIC appeals Federal Court's finding on alleged unfair contract term

ASIC has announced that it is appealing the Federal Court's decision to dismiss part of its proceeding against HCF Life. ASIC is alleging that a 'pre-existing condition' term used in a range of insurance contracts issued by HCF Life is an unfair term under section 12BG of the Australian Securities and Investments Commission Act 2001 (Cth).

ASIC has two grounds of appeal. First, ASIC argues that the Court impermissibly considered the ameliorating effect of section 47 of the Insurance Contracts Act 1984 (Cth) in its assessment of whether the term was unfair. This ground will test whether potentially unfair terms can be cured by legislation that the ordinary and reasonable consumer would be unaware of. The second ground concerns the apparent inconsistency of the finding that the term is misleading, but not unfair.

The Federal Court has already fined HCF Life $750,000 for use of a misleading contract term earlier this year. [7 Jul 2025]

Hong Kong

HKMA publishes guidelines and explanatory notes for implementation of regime for stablecoin issuers on 1 August 2025

The HKMA has published the following ahead of the implementation of the new regulatory regime for stablecoin issuers on 1 August 2025:

• Consultation conclusions on the Guideline on Supervision of Licensed Stablecoin Issuers and the finalised guideline;
• Consultation conclusions on the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Stablecoin Issuers) and the finalised guideline;
• Explanatory Note on Licensing of Stablecoin Issuers on various aspects of the licensing regime and application process; and
• Explanatory Note on Transitional Provisions for Pre-existing Stablecoin Issuers.

The publication of the above was alluded to earlier in an inSight article by Mr Eddie Yue (HKMA Chief Executive) published on 23 July 2025 (see our previous update). The two guidelines have also been published in the Government Gazette.

Parties interested in applying for a licence are encouraged to contact the HKMA by 31 August 2025 so that the HKMA can communicate regulatory expectations and provide feedback as appropriate. While licensing will be an ongoing process, interested parties that consider themselves sufficiently ready and wish to be considered early should submit the application to the HKMA by 30 September 2025.

The HKMA reminds market participants that it is an offence under the Stablecoins Ordinance to falsely claim oneself as a licensee or an applicant. Market participants should exercise due caution in their public communications, as well as refrain from making statements that could be misinterpreted or create unrealistic expectations.

The public is reminded to stay vigilant and to refer to the HKMA's register of licensed stablecoin issuers to verify whether an issuer has been licensed. [29 Jul & 1 Aug 2025]

SFC updates Frequently Asked Questions on Guidelines for Market Soundings

The SFC has updated its Frequently Asked Questions on Guidelines for Market Soundings by adding a new Question 4A. This question confirms that the Guidelines for Market Soundings do not apply to activities relating to takeovers, mergers and share buy-backs that fall under the scope of the Codes on Takeovers and Mergers and Share Buy-backs. [31 Jul 2025]

SFST discusses recently launched Anti-Scam Consumer Protection Charter 3.0

In response to questions by the Honorary Chan Chun-ying in the Legislative Council, the Secretary for Financial Services and the Treasury (SFST), Mr Christopher Hui, discussed (among other things) the objectives and approach of the Anti-Scam Consumer Protection Charter 3.0, launched by the HKMA and other financial regulators in July 2025 (see our previous update).

Charter 3.0 expands participation to include technology and telecommunications firms, marking a new chapter of cross-sector collaboration among financial, technology and telecommunications industries in combating fraud. It aims to enhance effectiveness in four key areas:

• Reporting of suspected scams and fraud – Participating firms will put in place user reporting functions and establish direct and efficient channels for financial regulators to report and follow up on suspected scams and fraud.
• Vetting of advertisers – Participating firms will adopt a risk-based approach to verify advertisers, while developing internal policies and tools to monitor the advertisements and content on their platforms relating to financial products or services.
• Removal of fraudulent advertisements – Participating firms commit to enforcing their terms of service by detecting and removing financial scam advertisements or content that violate platform policies.
• Enhancing public awareness – Participating firms will collaborate with financial regulators and the financial industry to launch various anti-scam campaigns to raise public vigilance against scams.

Charter 3.0 covers major overseas and Mainland information technology platforms operating in Hong Kong (including instant messaging apps, social media, video streaming and search engine) as well as nearly all major telecommunications service providers (including fixed network operators, mobile network operators and internet service providers). Given the diversity of platforms and services, participating firms may adopt proportionate measures, based on their business scope and model, to comply with the Charter 3.0 principles. This approach allows them to leverage their tools and strengths to prevent scams and safeguard their users, and provide them with the flexibility to adapt to evolving tactics and patterns of scams, with a view to enhancing the capacity and effectiveness of Hong Kong's overall anti-scam ecosystem. [30 Jul 2025]

HKMA publishes Issue 26 of Complaints Watch

The HKMA has published the 26th issue of its Complaints Watch, which is published half-yearly by its Banking

Complaints Unit. The Complaints Watch highlights the latest complaint trends, emerging topical issues, and areas that authorised institutions (AIs) should take note of. Through this publication, the HKMA aims to promote proper standards of conduct and prudent business practices among AIs and to enhance public understanding of banking products.

In addition to complaint statistics, the HKMA highlights two issues:

• Handling complaints concerning operation of banking accounts – Given the increasingly challenging fraud landscape, there is a need for AIs to take proactive measures to detect illicit activities to offer better protection to their customers. That said, it is equally important for AIs to maintain effective communication with the affected customers to minimise inconvenience to them where the circumstances do not warrant it.
• Designing banking products from the customer's perspective – The HKMA receives from time to time complaints about banking products containing terms and conditions considered to be unfair to bank customers. These complaints might have been avoided if the AIs had designed their products more from the customer's perspective rather than their own. There may well be good justifications for introducing product features to protect the AIs' interests or facilitate administration, but these justifications have to be weighed against the possibility of subsequent disputes with customers. [28 Jul 2025

HKMA to publish finalised guidelines on supervision of stablecoin issuers and on AML/CFT requirements by end of July 2025 and an explanatory note on licensing of stablecoin issuers around the same time

The Chief Executive of the HKMA, Mr Eddie Yue, has published an inSight article in which he elaborates on the regulatory perspectives and next steps for implementing the Stablecoins Ordinance, which will come into effect on 1 August 2025.

Mr Yue cautions against undue speculation surrounding stablecoins, noting that a few dozen institutions have already proactively reached out to the HKMA, with some clearly expressing their intention to apply for a stablecoin issuer licence, and others simply looking for a sounding board. Many of such proposals remain conceptual and lack practical use cases. The institutions also fail to put together viable and concrete plans as well as implementation roadmaps. Mr Yue reiterated that the HKMA will at most grant a handful of stablecoin issuer licences at the initial stage.

The hype surrounding stablecoins has also led to excessive exuberance. For example, a mere announcement of intention to explore stablecoin-related business would send stock prices and trading volumes soaring. Moreover, fraudulent activities have recently been observed under the guise of promoting digital assets and stablecoins, resulting in public losses. A key concern lies in ways to prevent stablecoins from being used by criminals as a tool for money laundering, especially in cross-border use cases. The Bank for International Settlements emphasised at great length in their latest Annual Economic Report the importance of preventing money laundering risks associated with stablecoins.

Looking ahead:

• The HKMA is currently refining the draft guidelines on supervision of stablecoin issuers and on anti-money laundering (AML) and counter-financing of terrorism (CFT) requirements (see our previous update for the consultations), based on the consultation feedback received. The target is to publish the guidelines by the end of July 2025, and it is expected that the final version will not differ significantly from the consultation drafts. However, in light of shared international regulatory concerns, more stringent requirements will be imposed in respect of AML to minimise the risks of stablecoins being used as a money laundering tool.
• The HKMA will release its 'Explanatory Note on Licensing of Stablecoin Issuers' in the week commencing 28 July 2025, which will outline the HKMA's arrangements for accepting and processing licence applications. [23 Jul 2025]

Court-appointed administrators successfully distribute HK$19 million in assets as compensation to clients of licensed corporation

The SFC has announced that court-appointed administrators have successfully distributed approximately HK$19 million in assets as compensation to affected clients of Hong Kong Wan Kiu Investment Company Limited (HKWK), following the approval of the Court of First Instance in January 2025.

This came after the Court granted final reliefs in November 2022 in legal proceedings brought by the SFC under section 213 of the Securities and Futures Ordinance. They included a restoration order in favour of the affected clients of HKWK and an order appointing administrators to recover and administer HKWK's assets (see our previous update).

An SFC investigation had revealed that HKWK and its sole director and shareholder, Ms Connie Sham Khi Rose, had sold securities of HKWK's clients without their authorisation, misappropriated the sales proceeds, and falsified client statements to conceal the unauthorised transactions. Ms Sham was also the responsible officer and manager-in-charge of anti-money laundering and counter-terrorist financing, compliance, key business line, operational control and review, overall management oversight and risk management of HKWK at the material times. HKWK's SFC licence was revoked in March 2024.

The SFC subsequently referred the matter to the Police for further investigation which resulted in the criminal prosecution of Ms Sham by the Department of Justice. Ms Sham pleaded guilty to misappropriating around HK$58 million worth of HKWK's client assets between 2011 and 2019, and was sentenced to 160 hours of community service on 3 July 2025. [23 July 2025]

SFC updates FAQs relating to Structured Investment Products under the Code on Unlisted Structured Investment Products

The SFC has updated its Frequently Asked Questions relating to Structured Investment Products under the Code on Unlisted Structured Investment Products:

The following questions are obsolete and have been removed:

• Section 1 Question 2 – Whether there is a new set of procedures for application for authorisation under Part IV of the Securities and Futures Ordinance in respect of structured investment products (SIPs) (and/or their relevant documents, invitations and advertisements) upon the coming into effect of the Code on Unlisted Structured Investment Products (SIP Code);
• Section 1 Question 3 – To which applications the application procedures in the FAQs apply;
• Section 1 Question 13 – Whether the 6-month period referred to in Section 1 Question 9 applies to applications that were received by the SFC before 1 January 2014 but authorisations in respect of which have not been granted before 1 January 2014, and how the 4-month period referred to in Section 1 Question 9 will apply.

The following questions have been revised:

• Section 1 Question 9 – Whether an application will lapse after a certain period of time, and if so, what the time period is; what to do if an application has lapsed; whether the SFC will give prior notice to an applicant in respect of the impending lapse of an application;
• Section 3 Question 1 – Whether stocks listed on a US stock exchange can be used as reference assets for SFC-authorised SIPs, and if so, whether there are requirements regarding the selection of such US listed stocks;
• Section 3 Question 4 – The additional risks associated with investing in SIPs linked to US stocks. [21 Jul 2025]

SEHK issues circular on post release test and launch of phase 1 of minimum spreads reduction targeted for 4 August 2025

The Stock Exchange of Hong Kong Limited (SEHK) has announced 4 August 2025 as the target launch date for phase 1 of the minimum spreads reduction in the Hong Kong securities market, following the successful completion of a market rehearsal, confirmation of readiness by exchange participants (EPs), and relevant regulatory approval.

With reference to the client notice, the spread table codes in HKEX Orion Market Data Platform – Securities Market (OMD-C) and Mainland Market Data Hub – Securities Market (OMD-C MMDH) will be updated upon the launch of phase 1.

To prepare for the launch of phase 1, an optional post release test will be held on 2 August 2025 from 9:00am to 12:10pm. This test will focus on changes to spread tables and quotation rules under phase 1. EPs are strongly encouraged to participate and must submit a registration form by 31 July 2025 to request turning on all production trading devices for simulation of normal trading activities, and to designate contact persons for the test.

EPs should coordinate with their information vendors for market data support during the test and follow the activity rundown provided in the information package.

After the completion of the test, the SEHK will confirm the rollout of phase 1 by 3:00pm on the same day (2 August 2025) via the reduction of minimum spreads web corner. EPs are requested to check the web corner and take the necessary actions (such as checking the update of the full list of securities if required).

The SFC has approved amendments to the Rules of the Exchange (clean and marked-up versions), which will come into effect upon the launch of minimum spreads reduction on 4 August 2025. [21 Jul 2025]

SFC bans former RO of licensed corporation for nine years and fines him HK$350,000 for misconduct in relation to management of fund and related conflicts of interest

The SFC has prohibited Mr Tong Ho Yin, a former responsible officer (RO) of HF Asset Management Limited

(HFAM), from returning to the industry for nine years, and fined him HK$350,000.

The disciplinary action follows the SFC's investigation which revealed that during Mr Tong's tenure as RO, HFAM had failed to act in the best interests of a fund under its management and to properly manage conflicts of interest when entering into loan and stock lending agreements for the fund on three separate occasions between May 2017 and December 2018. HFAM's misconduct was evident in its repeated failures regarding these arrangements, all of which ultimately defaulted, resulting in significant financial losses of HK$25.6 million for the fund (amounting to 86% of its net asset value).

On 7 October 2021, the SFC issued a restriction notice to HFAM, prohibiting it from carrying on any regulated activities (see our previous update). HFAM subsequently ceased business on 4 August 2022, and its licence with the SFC was revoked on 7 July 2023.

The SFC considers that HFAM's recurrent failures were attributable to Mr Tong's failure to discharge his duties as an RO and a member of the senior management of HFAM. In considering the sanction, the SFC noted that but for Mr Tong's financial position, it would have imposed a HK$700,000 fine against him. [16 Jul 2025]

HKEX publishes discussion paper on accelerated settlement for Hong Kong cash market, seeking feedback by 1 September 2025

The HKEX has published a discussion paper to examine accelerated settlement for the Hong Kong cash market.

The HKEX proposes shortening the current settlement cycle for the cash market from T+2 (settlement occurring two business days after trading), which has been operating since 1992, to T+1 (settlement occurring one business day after trading). Feedback to the proposals is required to be submitted by 1 September 2025.

The proposed T+1 settlement cycle will apply to secondary transactions in the cash market, which are:

• Equities;
• Exchange traded products (ETPs), which include exchange traded funds and leveraged & inverse products of different asset classes;
• Structured products;
• Real estate investment trusts;
• Debt securities traded on The Stock Exchange of Hong Kong Limited and settled in CCASS;
• The physical settlement of equities upon stock options exercise.

Primary transactions in the cash market (including initial public offerings, ETP primary creation and redemption, and structured products issuance and expiry) and Mainland China A-shares traded via Hong Kong are excluded.

The discussion paper outlines the potential benefits and challenges of shortening the current T+2 settlement cycle in Hong Kong, referencing the experience of other jurisdictions. Potential benefits include enhanced market efficiency, reduced systemic risk, and closer alignment with global markets. A transition also presents challenges, particularly for market participants navigating time zone differences, foreign exchange transactions, and shorter post-trade timelines. Market participants would need to upgrade systems, automate processes and coordinate across the market ecosystem to maintain efficiency and stability.

The transition to T+1 is expected to include a series of steps, and is therefore expected to be a multi-year journey. The HKEX will be engaging with the industry on a viable operating model on T+1 and its implementation details. Industry-wide testing will be conducted to ensure the preparedness of the broad range of market participants in our market. With overall industry readiness, the HKEX will seek regulatory approvals.

Any shortening of the settlement cycle is expected to impact the whole value chain in the cash market and its existing infrastructure. The HKEX considers that any T+1 implementation approach should prioritise market stability and operational readiness.

The HKEX will consider the timing of existing initiatives in the Hong Kong market and the progress of T+1 transition in other global markets, as well as industry capacity for infrastructural changes, in deciding on any transition timing. [16 Jul 2025]

SFC enhances arrangements for visiting professionals by extending time period for conducting regulated activities and providing VA services in Hong Kong to 45 days per calendar year

The SFC has issued a circular on its enhanced measure to facilitate visiting professionals to conduct regulated activities or provide virtual asset (VA) services in Hong Kong.

Visiting professionals from an overseas group company of a licensed corporation or licensed VA service provider can choose to apply for a representative licence to be an itinerant professional (ITP) for conducting regulated activities or providing VA services in Hong Kong for a short period of time (up to 30 days per calendar year). ITPs are required to be chaperoned by a licensed person at all times, unless they only provide services to professional investors.

To facilitate and provide more flexibility to visiting professionals to conduct these activities in Hong Kong, the SFC is now extending the period to 45 days per calendar year. The extended period is also applicable to existing licensed ITPs. The SFC will arrange for these licensed ITPs to replace their existing ITP licence condition with one that has a 45-day period. Further details will be provided to them separately.

Except for the above, the application process, other requirements, features and exemptions for ITPs remain unchanged. Details of the ITP arrangements are set out in the Licensing Handbook and the Licensing Handbook for Virtual Asset Trading Platform Operators. [15 Jul 2025]

SFC concludes 2017 consultation and launches further consultation on changes to FRR and related guidelines to foster market development for OTC derivatives and other products, seeking feedback by 13 October 2025

The SFC has published a combined consultation paper and conclusions paper to (i) consult on draft amendments to the Securities and Futures (Financial Resources) Rules (FRR) and related guidelines for implementing a set of internationally comparable capital requirements for licensed corporations (LCs) engaging in over-the-counter (OTC) derivative activities, as well as other changes to facilitate market development, and to (ii) conclude on certain FRR changes it consulted on in 2017 (see our previous update). Feedback on the proposals is required to be submitted by 13 October 2025.

• The OTC derivatives capital requirements previously proposed in the 2017 consultation have been fine-tuned with reference to recent changes to Hong Kong's Banking (Capital) Rules and the Basel framework. The capital requirements for inter-dealer brokers will also be significantly lowered and transfer pricing treatments for LCs will be simplified to reflect the comments received during the 2017 consultation.
• Other FRR changes to support LCs' business development and diversification have also been proposed. These include measures to facilitate LCs' trading of stocks in Mainland China and emerging markets, commodities and carbon products, as well as digital asset futures and options on licensed virtual asset trading platforms.
• To drive Hong Kong's development as a regional fixed income and currency hub, the SFC has proposed to exempt the capital requirements for centrally-cleared repurchase transactions (repos) to promote their central clearing in Hong Kong and the development of the city's inter-dealer repo market. [14 Jul 2025]

SEHK publishes circular regarding publication of Northbound Program Trading Reporting Guidelines by SSE and SZE, to take effect on 12 January 2026

The Stock Exchange of Hong Kong Limited (SEHK) has issued a circular to inform China Connect exchange participants (CCEPs) and trade-through exchange participants (TTEPs) that the Shanghai Stock Exchange (SSE) and the Shenzhen Stock Exchange (SZSE) have published the following (in Chinese only):

• Northbound Program Trading Reporting Guidelines (Guidelines) – SSE and SZSE;
• Northbound Program Trading Fill-in Instructions – SSE and SZSE;
• Points to Note for Northbound Program Trading Fill-in and Reporting – SSE and SZSE; and
• Northbound Program Trading Reporting Template – SSE and SZSE.

The Guidelines will take effect on 12 January 2026 with a three-month transition period. CCEPs and TTEPs should refer to the announcements by SSE and SZSE and assess the impact of such changes to their operations and systems.

There will be no system change to the Orion Trading Platform – China Stock Connect (OTP-CSC) in relation to the above. The submission of Northbound Program Trading Reporting will be via the Electronic Communication Platform. Details (including testing arrangements) will be announced in due course. [11 Jul 2025]

Financial authorities jointly launch Anti-Scam Consumer Protection Charter 3.0

The HKMA, the SFC, the Insurance Authority, and the MPFA have jointly announced the launch of the Anti-Scam Consumer Protection Charter 3.0.

Charter 3.0 builds on the success of Charter 1.0 (see our previous update) and Charter 2.0 (see our previous update), and represents a significant step forward in anti-scam efforts by establishing a collaborative framework between financial regulators, technology firms, and telecommunications firms. It introduces six key principles focused on the reporting of suspected financial frauds and scams, checking of advertisers, internal monitoring processes, enforcement of terms of service, and collaboration on public education and awareness.

At the launch event, executives from financial regulators, technology firms and telecommunications firms discussed the latest trends of financial frauds and scams as well as their collaborative efforts in combatting such frauds and scams.

Executives from the participating authorities, including Ms Julia Leung (SFC CEO), Mr Eddie Yue (HKMA Chief Executive), Mr Clement Cheung (Insurance Authority CEO) and Mr Cheng Yan-chee (MPFA Managing Director), emphasised the importance of a united front and collaboration to combat financial frauds and scams. They also highlighted the Charter's role in strengthening public education and safeguarding the public.

This joint initiative is supported by the Consumer Council, the Hong Kong Association of Banks, the Hong Kong Police Force, and the Office of the Communications Authority. [9 Jul 2025]

First active ETF cross-listing in Hong Kong underscores city's unique role as gateway for international asset managers seeking access to Asia-Pacific's dynamic investor base

The SFC has welcomed the first cross-listing of an actively managed exchange-traded fund (ETF) in Hong Kong.

The cross-listing was achieved by way of a master-feeder structure and was facilitated by the streamlined requirements for eligible ETFs (see SFC circular of 16 May 2024 in our previous update). With an Irish master ETF, the new feeder ETF is another testament to the market connectivity between Hong Kong and Ireland, further to the two markets' Memorandum of Understanding on Mutual Recognition of Funds in May 2025 (see our previous update).

The SFC's Executive Director of Investment Products, Ms Christina Choi, considers that the cross-listing of this ETF has underscored Hong Kong's unique role as a gateway for international asset managers seeking access to Asia-Pacific's dynamic investor base, as well as the SFC's commitment in fostering international collaboration in asset management. [9 Jul 2025]

OTC Clear adopts ISDA's Revised Annex A to 1998 FX and Currency Option Definitions from 9 July 2025

OTC Clearing Hong Kong Limited (OTC Clear) has announced that with effect from 9 July 2025, it has adopted in its entirety the Revised Annex A to the 1998 FX and Currency Option Definitions published by the International Swaps and Derivatives Association (ISDA) for the purposes of interpreting or implementing the contract terms of each contract registered with OTC Clear.

The revised Annex A includes updates on (amongst others) the definition of the 'INR01' Settlement Rate Option.

Contracts registered with OTC Clear prior to 9 July 2025 should be amended pursuant to the revised Annex A, with the amendments taking effect from 9 July 2025. [9 Jul 2025]

HKMA announces enhancements to offshore RMB bond repo business

The HKMA has announced enhancements to the offshore RMB bond repurchase (repo) business (see our previous update regarding the announcement of the launch in early 2025) to facilitate the participation of Northbound Bond Connect investors in such business.

The enhancement measures, to be launched on 25 August 2025, aim to adopt international market best practices and enhance operational efficiency, as well as expand the depth and breadth of the offshore repo market, among others:

• Supporting the rehypothecation of bond collaterals during the repo period – In particular, bond collaterals can be re-used during the repo period in four specific cases: (i) for re-use in offshore repo transactions; (ii) as collateral for the HKMA's RMB Liquidity Facility; (iii) as margin collateral at OTC Clearing Hong Kong Limited; and (iv) for cash bond trading through Northbound Bond Connect.
• Supporting cross-currency repo (including HKD, USD and EUR) beyond RMB – This is aimed at facilitating participating institutions' multi-currency funding activities by collateralising onshore RMB bond holdings, enriching their liquidity management tools, and hence increasing the attractiveness of onshore bonds.

The HKMA has also outlined the latest arrangements for offshore RMB repo transactions (including repo transactions conducted using bond collateral acquired through a repo transaction), including in relation to participating institutions, eligible bonds, market maker arrangements, transaction and settlement arrangements, and data reporting. [8 Jul 2025]

HKMA Chief Executive and SFC CEO discuss enhancement of Bond Connect and further development of Hong Kong as offshore RMB center at Bond Connect Anniversary Summit

At the Bond Connect Anniversary Summit on 8 July 2025, Mr Eddie Yue (HKMA Chief Executive) and Ms Julia Leung (SFC CEO) discussed macro trends, enhancements to the Bond Connect, as well as the strategy for further developing Hong Kong as an offshore RMB center.

Mr Yue highlighted that against the backdrop of global diversification and Mainland China's wealth accumulation (particularly in institutional capital) – which underscores Bond Connect's role as a gateway to facilitate cross-border capital flows between the Mainland and global financial markets – the HKMA has been working closely with Mainland authorities (in particular the People's Bank of China), to step up efforts to enhance the Bond Connect and its ecosystem.

• Under the Northbound channel, investors can already use Bond Connect bonds as collateral for the HKMA's RMB Liquidity Facility, margin collateral for OTC Clearing Hong Kong Limited derivative transactions, and for conducting offshore RMB bond repurchase (repo) transactions. The offshore RMB repo business is being expanded to also support re-hypothecation and cross-currency repo, to be implemented in late August 2025 (see 'HKMA announces enhancements to offshore RMB bond repo business' above).
• The Southbound Bond Connect investor scope has been expanded to include securities firms, fund companies, insurance companies and wealth management companies with effect from 8 July 2025. This will open up more channels to meet the growing demand from Mainland investors, bolster the development of Hong Kong's bond market by widening the investor base and enhancing market liquidity, and thereby increase Hong Kong's attractiveness to bond issuers and global investors.
• Following the announcement in May 2025, 30-year interest rate swaps (IRS) contracts had gone live on 30 June 2025 under the Swap Connect (see our previous updates here and here), and IRS contracts using the loan prime rate as reference rate will be launched in the coming months.

Ms Leung stated that one of the SFC's priorities this year is to develop the fixed income and money markets, in particular the RMB fixed income market. The SFC is progressing in three strategic directions:

• Increasing the issuance of fixed income products in the primary market and enriching the supply of RMB products;
• Enhancing the liquidity of the secondary bond market; and
• Studying the establishment and optimisation of supporting infrastructure related to offshore RMB products, including front-end trading systems and middle and back office supporting systems. [8 Jul 2025]

SFC convenes second Digital Asset Consultative Panel meeting with licensed VATPs

The SFC has held the second meeting of its Digital Asset Consultative Panel (see our previous update for the inaugural meeting), continuing its engagement with licensed virtual asset trading platforms (VATPs).

The meeting covered a broad range of issues relating to market and regulatory developments in the digital asset realm, particularly initiatives in Pillars A (Access) and P (Products) of the SFC's ASPIRe roadmap issued in February 2025 (see our previous update), including:

• Proposals to introduce regulatory regimes for virtual asset dealing and custodian providers (see our previous update); and
• Market accessibility and product offerings

The panel, formerly known as the Virtual Asset Consultative Panel, has been renamed to align with the term used in the Government's Policy Statement 2.0 on the Development of Digital Assets in Hong Kong issued on 26 June 2025 (see our previous update).

Dr Eric Yip, the SFC's Executive Director of Intermediaries and chair of the panel, stated that the SFC remains committed to maintaining global competitiveness while ensuring robust investor protection and local safeguards within the digital asset sector.

The SFC will continue to proactively collaborate with licensed VATPs via the panel as part of the initiative in Pillar Re (Relationships) of the ASPIRe roadmap. [7 Jul 2025]

HKEX launches Order Routing Service on Integrated Fund Platform to enhance fund order placement process

The HKEX has announced the launch of the Order Routing Service on its Integrated Fund Platform, marking an important step forward in connecting key participants in the fund distribution lifecycle and enhancing the efficiency of Hong Kong's fund management industry. An initial cohort of 33 distributors, transfer agents and fund houses have joined the platform (a list is available on the platform website). The SFC has welcomed the launch and the Government has acknowledged the significance of the new service.

The introduction of the Order Routing Service builds on the success of the Fund Repository (see our previous update), and will help transform the fund order placement process (which includes subscriptions and redemptions) into a seamless and integrated system. It enhances communications between fund distributors and transfer agents, addressing the longstanding operational challenges while promoting greater efficiency and collaboration across the fund distribution network.

The next phase of development for the Integrated Fund Platform includes the provision of nominee services, as well as the facilitation of payments and settlement, subject to regulatory approval. Further details will be shared in due course. [3 Jul 2025]

Singapore

ABS: Launch of EDP solutions

The Association of Banks in Singapore (ABS) has announced the launch of two new electronic deferred payment (EDP) solutions, known as EDP and EDP+ to support the transition to electronic payments. The solutions are accessible via banks' digital banking platforms and offer both individuals and companies a way to make deferred payments, or indicate an intent to pay, without the need for a physical cheque. [28 Jul 2025]

MAS appoints first EQDP asset managers; commits S$50m to boost equity research and product listings; outlines proposals to enhance investor recourse

MAS has announced the appointment of the first batch of asset managers under the S$5bn Equity Market Development Programme (EQDP). MAS and the Financial Sector Development Fund will place an initial amount of S$1.1bn for management with these appointed managers. MAS has also committed S$50m to strengthen support for local equity research and to grow a more vibrant listed product ecosystem. In addition, MAS outlined proposals to enhance investors' ability to seek recourse. [21 Jul 2025]

MAS: 10th annual UK-Singapore Financial Dialogue

MAS has published a summary of the discussions that took place at the 10th annual UK-Singapore Financial Dialogue. The discussions highlighted the strong and continued collaboration between the UK and Singapore, with a focus on several key themes, including digital finance and innovation, sustainable finance, capital markets and international regulatory developments.

Among the outcomes, the UK Financial Conduct Authority (FCA) and MAS agreed to deepen collaboration through joint work with the UK's Investment Association and the Investment Management Association of Singapore to explore the impact of asset tokenisation from the investor perspective and help drive greater adoption of tokenised assets in both markets.

The FCA and MAS also agreed to develop joint collaboration on AI, focusing on sharing innovative AI solutions and cross-border AI developments. [3 Jul 2025]

MAS speech: Resilience and adaptability in an ever-changing fund management industry

MAS has published the keynote speech by Mr Teo Kok Ming, Executive Director (Investment Intermediaries), delivered at the Investment Management Association of Singapore's 11th Regulatory Forum. Reflecting on uncertainty in the global macro landscape, Mr Teo highlighted:

• the need to foster resilience through enhanced risk management practices – specifically on upcoming changes to the liquidity risk management guidelines for open-ended funds;
• observations and supervisory expectations regarding the governance and management of variable capital companies;
• changes to MAS' supervisory approach, focusing on data collection initiatives; and
• instances where fund managers have been targeted by cyberattacks and impersonation scammers and the lessons that can be learned from those incidents. [2 Jul 2025]

MAS consults on enhancing Product Highlights Sheets and streamlining the framework for complex products

MAS has published a consultation on its proposals to enhance the requirements for Product Highlights Sheets and to streamline the framework for complex products.

Feedback is requested by 1 September 2025. [1 Jul 2025]

Thailand

SECT partners with Meta on investment scam awareness campaign

The SECT has announced that it is partnering with Meta on an investment scam awareness campaign. The aim is to educate consumers about prevalent online fraud tactics and improve digital safety. The campaign highlights four common scam types: cryptocurrency investment scams; romance scams; general investment scams; and celebrity impersonation scams. [31 Jul 2025]

SECT requests comments on proposed ICO portal regulations – knowledge and suitability tests

The SECT is seeking comments on proposed regulations regarding the criteria for investor communication and service provision by initial coin offering (ICO) portals. The proposed regulations would require ICO portals to ensure that investors who are not institutional investors, ultra-high-net-worth investors, or high-net-worth investors complete a knowledge test before investing unless they have previously passed such a test. Additionally, ICO portals would be required to conduct a suitability test for all investors in digital tokens, and this assessment must be reviewed and updated at least every two years.

Feedback is requested by 1 August 2025. [18 Jul 2025]

SECT consults on digital asset regulatory sandbox to promote tourism industry

The SECT has launched a consultation on a regulatory sandbox to allow conversion of digital assets into Thai Baht for foreign tourists' spending purposes. The initiative aims to promote the use of innovation and digital assets to boost the economy and the tourism industry in Thailand.

Under the sandbox pilot program, foreign tourists who wish to convert digital assets into Thai Baht and use the converted Thai Baht to pay for goods and services at merchants would be required to open an account and make transactions through digital asset business operators under the SECT's supervision and e-money business operators under the Bank of Thailand's supervision.

Eligible participants in the sandbox include digital asset exchanges, digital asset brokers and digital asset dealers. Participants would have to apply for approval and be ready to operate under the sandbox framework, scope, and criteria. Once approved, the service period under the sandbox would not exceed 18 months, although the SECT may consider an extension to allow greater flexibility for conducting the testing operations.

Responses are requested by 13 August 2025. [15 Jul 2025]

India

IFSCA: Framework for transition bonds

IFSCA has published a circular on the framework for transition bonds for recognised stock exchanges that intend to list transition bonds in the IFSC. IFSCA clarifies that the label 'transition bonds' refers to ESG-labelled debt securities; the framework for these covers: eligibility for issuance and listing; requirements for a transition plan; requirements for the appointment of an independent external reviewer; and initial and additional disclosure requirements. [29 Jul 2025]

IFSCA Guidelines on ascertaining KMP eligibility in accordance with Fund Management Regulations

IFSCA has published guidelines on ascertaining key managerial personnel (KMP) eligibility in accordance with Regulation 7 of the IFSCA (Fund Management) Regulations, 2025. The guidelines are intended to provide clarity on the eligibility of Principal Officers and Compliance Officers for fund management entities to assist hiring decisions. [25 Jul 2025]

SEBI and MIIs launch campaign to combat scams

SEBI, in collaboration with a number of market infrastructure institutions (MIIs), has launched a joint media campaign titled 'SEBI vs SCAM'. The initiative aims to educate investors on prevalent scams, such as fake trading apps, unregistered investment advice from finfluencers, deepfakes, intermediary impersonation, paid trading courses promising guaranteed returns, and illegal 'dabba' and 'opinion' trading. [24 Jul 2025]

RBI issues draft Master Direction on digital banking authorisation for comment

The RBI has released the draft Master Direction on 'Digital Banking Channels Authorisation' for comment. The Direction covers: prudential requirements; guidelines on technology issues; compliance; customer consent; and exemptions.

Feedback on the draft Directions is requested by 11 August 2025. [21 Jul 2025]

SEBI consultation — Review of valuation of physical gold and silver held by gold and silver ETFs

SEBI has published a consultation on a proposal to review the valuation of physical gold and silver in cases of gold and silver exchange traded funds (ETFs). The proposed change is expected to bring uniformity to the valuation process across the industry and to more closely align valuations with domestic prices of gold and silver.

Responses are requested by 6 August 2025. [16 Jul 2025]

IFSCA consults on regulatory framework for reporting and clearing of OTC derivatives

IFSCA has published a consultation which proposes a regulatory framework for the reporting and clearing of over-the-counter (OTC) derivatives in the IFSC. The framework is restricted to the issuance of OTC derivatives which have as underlying assets:

• equities listed on the stock exchanges in the IFSC or on a regulated foreign stock exchange;
• bonds listed on the stock exchanges in the IFSC or on a regulated foreign stock exchange; or
• index derivatives, equity derivatives and bond derivatives listed on a regulated foreign stock exchange.

Responses are requested by 5 August 2025. [15 Jul 2025]

IFSCA consults on draft Master Circulars for CMIs

IFSCA has published for consultation draft Master Circulars for the following categories of capital market intermediaries (CMIs) in the IFSC:

• credit rating agencies;
• debenture trustees;
• distributors;
• ESG ratings and data products providers;
• investment advisers;
• investment bankers; and
• research entities.

The master circulars provide clarity on various operational aspects, including, among others, registration process, validity of registration, permissible activities, governance, code of conduct, know your customer, anti-money laundering and countering the financing of terrorism guidelines, outsourcing, complaint handling, change in control, periodic reporting, cyber security and cyber resilience, and surrender of registration.

Responses are requested by 21 July 2025. [11 Jul 2025]

IFSCA consults on proposed amendments to AML/CTF and KYC guidelines

The International Financial Services Centres Authority (IFSCA) has published a consultation on proposed modifications to Part-A of Annexure II of the IFSCA (Anti Money Laundering, Counter-Terrorist Financing and Know Your Customer) Guidelines, 2022.

The draft modifications aim to enable regulated entities to onboard non-resident Indians using the video-based customer identification process. Comments on the proposals are requested by 1 August 2025. [10 Jul 2025]

SEBI consults on review of permissible business activities for asset management firms

SEBI has published a consultation on proposals regarding the regulatory framework for business activities of an asset management company of a mutual fund, as specified under Regulation 24 of the SEBI (Mutual Funds) Regulations 1996. SEBI proposes certain relaxations in the current provisions of the Regulations. Feedback on the consultation is requested by 28 July 2025. [7 Jul 2025]

SEBI consults on electronic book provider for issuance on social stock exchange

SEBI has published a consultation paper on its draft circular for 'Electronic Book Provider for issuance of instruments by Not for Profit Organisations on Social Stock Exchange'.

Comments are requested by 24 July 2025. [3 Jul 2025]

SEBI: Mandatory implementation of CCN with VWAP

SEBI has announced that the Common Contract Note (CCN) with a Single Volume Weighted Average Price (VWAP) has been made mandatory with effect from June 27, 2025. The reform simplified post-trade reporting by consolidating trades executed across multiple exchanges into a single, harmonised document. [2 Jul 2025]

SEBI consults on framework for conversion of private listed InvIT into public InvIT

SEBI has issued a draft circular for comment. The circular covers the review of the framework for the conversion of private listed infrastructure investment trusts (InvIT) into public InvIT.

Feedback is requested by 22 July 2025. [1 Jul 2025]

Philippines

BSP signs MoU with BTr to strengthen financial market resilience

The BSP and the BTr have signed a memorandum of understanding (MoU) to strengthen systems for government securities trading and for large-value fund transfers. The MoU covers collaboration on the real-time gross settlement system and the National Registry of Scripless Securities along with related systems. [30 Jul 2025]

SECP issues reminder that crypto rules and guidance entering into force on 5 July

The SECP has published a reminder that its rules on cryptoasset service providers (CASP) and guidelines on the operations of CASPs officially took effect on 5 July 2025. The rules apply to all CASPs which offer or engage in one or more cryptoasset services and third-party service providers who engage in the marketing of cryptoassets and cryptoasset services. This includes entities that operate or make available digital platforms through which such cryptoasset services are provided. [16 Jul 2025]

Vietnam

SBV: Deputy Governor meets delegation from Pakistan, discusses banking cooperation and digitalisation of the banking sector

The SBV has published a summary of the meeting between Deputy Governor Pham Tien Dzung and a delegation from the Ministry of Commerce of Pakistan, led by Mr. Jam Kamal Khan, Federal Minister for Commerce.

The Deputy Governor spoke positively of the friendly relationship between Vietnam and Pakistan, highlighting that the banking cooperation between the two countries has affirmed its important role, providing a smooth and effective channel for payments and money transfer transactions, actively supporting bilateral trade and investment.

The Deputy Governor also shared information about the digitalisation of Vietnam's banking sector in the recent years, noting that: payments through digital channels have grown steadily, both in the numbers of transactions and in the transaction value; basic banking operations have been fully digitized (including savings deposits, term deposits, opening and using payment accounts, opening bank cards, e-wallets, money transfers, and approving loans); and as much as 95% of the transactions can now performed online. [14 Jul 2025]

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