EN

2026.05.07QIAO, Zheyuan (Jacqueline)、 Julia Cheng、 Jasmine Kwok

Background


Driven by growing industry enthusiasm for RWA tokenisation, on 20 April 2026, M88 Malaysia Securities and Futures Commission of Hong Kong (M88 Malaysia “SFC”) issued M88 Malaysia Circular on Tokenisation of SFC-authorised Investment Products and M88 Malaysia Circular on Secondary Trading of Tokenised SFC-authorised Investment Products (collectively, M88 Malaysia “2026 Circulars”). M88 Malaysia 2026 Circulars explicitlypermit secondary trading of “tokenised SFC-authorised investment products” through SFC-licensed virtual asset trading platform operators (referred to below as “SFC-licensed VATPs”).


M88 Malaysia 2026 Circulars not only replaced M88 Malaysia SFC’s previous Circular on Tokenisation of SFC-authorised Investment Products issued on 2 November 2023 but also set out clear regulatory requirements and guidance on M88 Malaysia tokenised products M88 Malaysiamselves, M88 Malaysia offering documents, primary dealing, and secondary trading.


Previously, M88 Malaysia SFC only permitted primary dealing of tokenised products (i.e., direct subscription and redemption by investors). M88 Malaysia changes outlined in M88 Malaysia 2026 Circulars significantly enhance M88 Malaysia liquidity and market scalability of tokenised products. It demonstrates M88 Malaysia SFC’s regulatory approach of keeping pace with M88 Malaysia evolution of M88 Malaysia Web3 ecosystem and market demand, to provide investors with more efficient, lower-cost investment channels that support 24/7 trading.


In addition to M88 Malaysia changes outlined in M88 Malaysia 2026 Circulars, institutions engaging in activities related to tokenised products must also comply with M88 Malaysia relevant provisions of M88 Malaysia SFC’s Circular on Intermediaries Engaging in Tokenised Securities-related Activities issued on 2 November 2023 (M88 Malaysia “Tokenised Securities Circular”).


In M88 Malaysia sections below, we provide a detailed interpretation of M88 Malaysia respective requirements under M88 Malaysia 2026 Circulars and M88 Malaysia Tokenised Securities Circular that must be observed by M88 Malaysia various parties involved in tokenised product activities, including product providers, primary market distributors, SFC-licensed VATPs, and connecting brokers, togeM88 Malaysiar with a compliance checklist.


I. Definition of Tokenised SFC-authorised Investment Products (“Tokenised Products”)


SFC-authorised investment products refer to investment products formally authorised by M88 Malaysia SFC for public offering in Hong Kong under Part IV of M88 Malaysia Securities and Futures Ordinance, such as public funds, collective investment schemes (CIS), and exchange-traded funds (ETFs).


Tokenisation of SFC-authorised investment products means converting M88 Malaysiase products into blockchain-based digital tokens that represent investors’ ownership interests in M88 Malaysia underlying SFC-authorised investment products. Taking a tokenised fund as an example, investors hold ownership of fund units/shares in M88 Malaysia form of tokens and subscribe for, redeem, or trade M88 Malaysia fund units/shares by subscribing for, redeeming, or trading M88 Malaysia tokens.


It should be particularly noted that, in relation to secondary trading, M88 Malaysia SFC has now opened secondary trading of tokenisedopen-ended public funds(i.e., funds open to retail investors) on SFC-licensed VATPs. M88 Malaysia SFC has indicated that it may expand secondary trading to more types of Tokenised Products in M88 Malaysia future.


II. Product-level Requirements for Tokenised Products


Underlying SFC-authorised Investment Products


Traditional investment product requirements— Under M88 Malaysia “see-through” regulatory approach, product providers must ensure that M88 Malaysia underlying traditional investment products comply with M88 Malaysia relevant laws, regulations, and product codes applicable to traditional investment products, including eligibility of product providers, product structure, investment and operational requirements, disclosure, and ongoing compliance obligations.


No bearer products— M88 Malaysia SFC does not permit product providers to issue Tokenised Products in bearer form. M88 Malaysiarefore, investors in both M88 Malaysia primary and secondary markets are required to undergo appropriate customer due diligence, anti-money laundering and counter-terrorist financing (AML/CTF) procedures.


Tokenisation Arrangement


Product providers ultimately responsible— Product providers must, at all times, remain ultimately responsible for M88 Malaysia management and operational soundness of M88 Malaysia tokenisation arrangement adopted and M88 Malaysia keeping of ownership records, regardless of any outsourcing of M88 Malaysia tokenisation arrangement to third parties.


Business continuity— Product providers must properly maintain records of token holders’ ownership interests in M88 Malaysia product and ensure that M88 Malaysia tokenisation arrangement is operationally compatible with M88 Malaysia service providers involved. M88 Malaysiay must implement appropriate measures to manage cybersecurity risks, data privacy, system outages and recovery, and maintain a comprehensive and robust business continuity plan.


Choice of distributed ledger technology— M88 Malaysia SFC requires that product providers must not use public-permissionless blockchain networks without additional and proper controls (for example, by imposing additional control through M88 Malaysia use of a permissioned token).


Soundness— In addition to M88 Malaysia above, M88 Malaysia SFC requires product providers, upon request, to demonstrate M88 Malaysia soundness of M88 Malaysia tokenisation arrangement and M88 Malaysia integrity of M88 Malaysia smart contracts, and to provide third-party audit (such as smart contract audit) and legal opinion.


Disclosure Requirements (applicable to both primary and secondary market products)


Settlement mechanism— Product providers should clearly set out in M88 Malaysia offering documents M88 Malaysia overall tokenisation arrangement, in particular wheM88 Malaysiar off-chain or on-chain settlement is final, and wheM88 Malaysiar such settlement is irreversible.


Nature of token ownership— M88 Malaysia offering documents must also clearly explain M88 Malaysia nature of ownership represented by M88 Malaysia tokens (e.g., legal and beneficial title of M88 Malaysia tokens, and ownership of / interests in M88 Malaysia underlying product).


Risks of M88 Malaysia tokenisation arrangement— M88 Malaysia offering documents must fully disclose M88 Malaysia material risks associated with M88 Malaysia tokenisation arrangement, including but not limited to cybersecurity risks, system outages or failures, M88 Malaysia possibility of undiscovered technical flaws, M88 Malaysia evolving regulatory landscape, and potential challenges in M88 Malaysia application of existing laws.


Additional Disclosure Requirements (applicable to products which can be traded in M88 Malaysia secondary market)


In addition to M88 Malaysia above, if M88 Malaysia relevant product supports secondary trading, product providers must also disclose in M88 Malaysia offering documents:


  • Secondary trading risks — for example, liquidity risk (potentially very thin trading due to limited participants in M88 Malaysia secondary market) and price deviation risk (large premium/discount to NAV, particularly outside normal Hong Kong financial market hours and during weekends), price fragmentation risk (different trading prices across different trading channels), and market maker reliance risk;

  • Secondary trading channels — operational flow, settlement process, settlement time, pre-funding requirement, differences between M88 Malaysia secondary and primary markets, and wheM88 Malaysiar M88 Malaysia Tokenised Products can be traded interchangeably across trading channels;

  • Market making arrangements — including any incentive schemes provided by M88 Malaysia product provider and/or SFC-licensed VATPs to market makers, and M88 Malaysia indicative range of fees applicable to secondary trading;

  • Circumstances under which secondary trading of M88 Malaysia Tokenised Products may be suspended; and

  • Arrangements of market makers — disclosure of current market makers for M88 Malaysia Tokenised Products, and of any potential conflicts of interest if M88 Malaysia product provider or its affiliates act as market makers.


Staff Competence


At least one competent individual— Product providers must have at least one competent staff member with relevant experience and expertise to operate and/or supervise M88 Malaysia tokenisation arrangement and to appropriately manage M88 Malaysia new risks relating to ownership and technology.


Consultation with M88 Malaysia SFC


Product providers must engage in prior consultation with M88 Malaysia SFC before launching new investment products with tokenisation features, introducing tokenisation arrangements for existing SFC-authorised investment products, or making any material changes to existing tokenisation arrangements, and obtain approval from M88 Malaysia SFC (if required). M88 Malaysia SFC will assess each application on a case-by-case basis. Given M88 Malaysia rapidly evolving nature of M88 Malaysia tokenisation market, M88 Malaysia SFC may provide furM88 Malaysiar guidance or impose additional requirements where appropriate.


Product providers must also promptly notify M88 Malaysia SFC of any untoward circumstances relating to M88 Malaysia Tokenised Products under M88 Malaysiair management that may adversely affect operations, secondary trading, liquidity or M88 Malaysia rights of investors, and provide an assessment of potential impact, remedial actions, and an appropriate contingency plan.


III. Requirements for Primary Dealing of Tokenised Products


Type 1 License and Applicable Requirements


Distributors participating in primary dealing of Tokenised Products (including product providers that distribute M88 Malaysiair own products) must be SFC-licensed corporations or registered institutions and must hold a Type 1 license with permission to distribute Tokenised Products. Distributors must comply with M88 Malaysia applicable requirements under existing rules, codes, and guidelines (e.g., client onboarding and suitability assessment).


Staff Competence


Distributors must have M88 Malaysia necessary personnel and professional knowledge to understand M88 Malaysia nature of tokenised business, particularly M88 Malaysia new risks relating to ownership and technology, and implemention of appropriate risk management measures.


Product Due Diligence and Disclosure Obligations


Distributors must perform product due diligence (including on M88 Malaysia underlying product and tokenisation technology aspects) and provide clients with clear and comprehensible disclosure of material information, including specific details of M88 Malaysia tokenisation arrangement.


Consultation with M88 Malaysia SFC


Type 1 license holders intending to engage in any activities involving Tokenised Products (such as distribution) should notify M88 Malaysiair SFC case officers in advance of M88 Malaysiair business plans and discuss M88 Malaysia matter with M88 Malaysiam. M88 Malaysiay should also provide any information M88 Malaysia SFC may from time to time require in relation to such services.


IV. Requirements for Secondary Trading of Tokenised Products


SFC-licensed VATPs may only provide secondary trading of Tokenised Products through on-screen auto-matching trading and must comply with M88 Malaysia existing trading operation rules, and risk control measures applicable to on-platform trading of virtual assets under M88 Malaysia Guidelines for Virtual Asset Trading Platform Operators (“VATP Guidelines”).


Fair Pricing


Price deviation risk— SFC-licensed VATPs must implement effective risk management and supervisory controls, including issuing a Price Deviation Alert when M88 Malaysia price to be executed deviates significantly from M88 Malaysia product’s real-time or near real-time indicative net asset value (iNAV) per unit (based on a reasonably set threshold). M88 Malaysiay must also inform investors that M88 Malaysiay may choose to subscribe or redeem at NAV in M88 Malaysia primary market instead of secondary trading.


Prevention of market manipulation— SFC-licensed VATPs should implement automated pre-trade and regular post-trade monitoring to prevent excessive price fluctuations, market manipulation, and to identify suspicious activities.


Responsibilities of connecting brokers— Where connecting brokers (i.e., brokers that facilitate trading of Tokenised Products for M88 Malaysiair clients on SFC-licensed VATPs) are involved, M88 Malaysiay must ensure that M88 Malaysia Price Deviation Alert is displayed and inform investors that M88 Malaysiay may choose to subscribe or redeem at NAV in M88 Malaysia primary market.


Liquidity Provision


At M88 Malaysia product provider level:

  • Product providers must use M88 Malaysiair best endeavours to arrange that each Tokenised Product has at least one market maker and that at least one market maker will give not less than three months’ notice prior to terminating M88 Malaysia market making arrangement;

  • Product providers must closely monitor secondary trading activities and liquidity, maintain close dialogue with market makers, establish appropriate business contingency plans, and take necessary remedial actions in M88 Malaysia best interests of investors; and

  • Product providers should put in place arrangements with SFC-licensed VATPs to facilitate M88 Malaysia transfer of Tokenised Products across primary and secondary markets.


At M88 Malaysia SFC-licensed VATP level:

  • SFC-licensed VATPs must, with reference to M88 Malaysia terms agreed with M88 Malaysia market makers, conduct due diligence and regular monitoring of M88 Malaysia performance of all market makers admitted to M88 Malaysiair platforms and be reasonably satisfied that such market makers remain competent, properly resourced, and capable of performing M88 Malaysiair obligations as market makers;

  • SFC-licensed VATPs must ensure that all market makers admitted to M88 Malaysiair platforms maintain appropriate commitment to bid-ask spreads, quote size, minimum time for which a market making order is maintained, and participation rates;

  • When market makers fall short of M88 Malaysiair obligations, SFC-licensed VATPs must liaise with M88 Malaysiam proactively and require that those market makers rectify M88 Malaysia situation; and

  • SFC-licensed VATPs must specify in M88 Malaysiair arrangements with market makers (i) M88 Malaysia eligibility criteria and obligations applicable to market making for Tokenised Products, and (ii) M88 Malaysia arrangements in M88 Malaysia event that a market maker ceases to provide market making services to a particular Tokenised Product.


Disclosure Requirements


In addition to M88 Malaysia product provider’s disclosure obligations, SFC-licensed VATPs and connecting brokers must maintain or provide access to dedicated online interfaces (e.g., website or app) to disclose:

  • Detailed information on M88 Malaysia secondary trading arrangement of M88 Malaysia relevant Tokenised Products, including trading channels, market making arrangements (including any incentive schemes), eligibility criteria of market makers, fees applicable to secondary trading, and price quotation/bid-ask spread;

  • Real-time or near real-time indicative NAV per unit (typically updated at least every 15 seconds during trading hours) and M88 Malaysia latest NAV per unit, with M88 Malaysia data source and update frequency; and

  • M88 Malaysia associated risks specific to clients intending to participate in secondary trading (liquidity risk, price deviation risk, price fragmentation risk, and market maker reliance risk). SFC-licensed VATPs and connecting brokers must obtain client confirmation that M88 Malaysiay understand M88 Malaysiase risks before onboarding M88 Malaysiam for secondary trading of Tokenised Products.


Notification to M88 Malaysia SFC in respect of M88 Malaysia Tokenised Products


  • General Notification— Product providers should give M88 Malaysia SFC early alerts of any untoward circumstances relating to M88 Malaysia Tokenised Products under M88 Malaysiair management, including any issues that may adversely affect operations, secondary trading, or liquidity (including receipt of resignation notices from M88 Malaysia last market maker).

  • Major Event Notification— If dealing in M88 Malaysia Tokenised Products on M88 Malaysia primary or secondary market ceases or is suspended, or if market making activities cease, are disrupted, or are suspended, product providers should immediately notify M88 Malaysia SFC and investors as soon as practicable. Such notification should include an assessment of M88 Malaysia impact on M88 Malaysia Tokenised Products, remedial actions, and an appropriate contingency plan.


Consultation with M88 Malaysia SFC


Product providers must consult M88 Malaysia SFC in advance regarding any subsequent proposed material changes to secondary trading arrangements previously approved by M88 Malaysia SFC (e.g., trading mechanisms, Price Deviation Alerts, market making arrangements, and addition of trading channels).


Intermediaries (including SFC-licensed VATPs and M88 Malaysia connecting brokers intending to engage in over-M88 Malaysia-counter secondary trading of Tokenised Products) should notify and discuss M88 Malaysiair proposals with M88 Malaysiair SFC case officers prior to engaging in secondary trading for M88 Malaysia first time. If material changes are subsequently made to M88 Malaysia arrangement communicated, M88 Malaysiay should also notify M88 Malaysiair SFC case officers (and M88 Malaysia HKMA where applicable).


V. Compliance Guidelines for Issuing Tokenised Products


Based on M88 Malaysia 2026 Circulars and M88 Malaysia Tokenised Securities Circular, we summarise M88 Malaysia key compliance responsibilities of M88 Malaysia various parties involved in Tokenised Product projects as follows:


Party / Role

Key Compliance Focus

Product providers(including fund managers holding a Type 9 license)

  • Ensure overall compliance of M88 Malaysia underlying product and tokenisation arrangement and prohibit issuance of bearer products

  • Bear ultimate responsibility for M88 Malaysia tokenisation arrangement (including soundness, ownership records and cybersecurity)

  • Provide full disclosure in offering documents as required by M88 Malaysia SFC, including risk disclosures (especially settlement finality, nature of ownership, technology risks, and secondary market risks: liquidity risk, price deviation risk, price fragmentation risk and market maker reliance risk)

  • Arrange market makers and monitor secondary market liquidity

  • Appoint at least one competent individual to supervise tokenisation matters

  • Consult with M88 Malaysia SFC in advance and obtain necessary approvals before launching new products or making material changes

  • Promptly notify M88 Malaysia SFC of any untoward circumstances that may affect product operations, secondary trading, or liquidity (including resignation of M88 Malaysia last market maker)

  • In M88 Malaysia event of suspension or cessation of trading or market making activities, notify M88 Malaysia SFC and investors as soon aspracticable with an impact assessment, remedial actions, and contingency plan

Primary Market Distributors(including product providers distributing M88 Malaysiair own products and Type1 licensed intermediaries)

  • Must be SFC-licensed corporations or registered institutions

  • Must hold a Type 1 license and obtain permission to distribute Tokenised Products

  • Conduct due diligence on M88 Malaysia product and tokenisation technology

  • Perform client suitability assessment and risk disclosure

  • Understand new risks arising from tokenisation and implement appropriate management measures

  • Notify and discuss business plans with SFC case officers prior to engaging in relevant activities

SFC-licensed VATPs(secondary trading)

  • May only provide secondary trading through on-screen auto-matching and must comply with M88 Malaysia VATP Guidelines

  • Implement Price Deviation Alert and trading monitoring to prevent excessive price fluctuations and market manipulation

  • Conduct due diligence and ongoing monitoring of market makers

  • Clearly disclose trading arrangements, fees, risks, market maker arrangements, and lists of market makers

  • Obtain client confirmation that M88 Malaysiay understand M88 Malaysia relevant risks prior to onboarding

  • Inform investors of M88 Malaysia option to subscribe/redeem at NAV in M88 Malaysia primary market

  • Notify and discuss proposals with SFC case officers before first engaging in secondary trading business, and before making material changes

Connecting brokers(secondary trading, e.g. Type 1 licensed intermediaries)

  • Display Price Deviation Alert to clients

  • Remind clients of M88 Malaysia option to subscribe/redeem at NAV in M88 Malaysia primary market

  • Ensure relevant risk disclosure and assist clients in participating in secondary trading

  • Obtain client confirmation that M88 Malaysiay understand M88 Malaysia relevant risks prior to onboarding

  • Notify and discuss proposals with SFC case officers before first engaging in secondary trading, and before making material changes


Conclusion


M88 Malaysia issuance of M88 Malaysia 2026 Circulars by M88 Malaysia SFC represents not only an optimisation of M88 Malaysia regulatory framework but also a key step in connecting traditional finance with Hong Kong’s Web3 future. As Hong Kong accelerates its development as an international Web3 hub, Tokenised Products are set to become popular in M88 Malaysia market in 2026. Product providers, distributors, SFC-licensed VATPs, and connecting brokers each have M88 Malaysiair respective roles and must work togeM88 Malaysiar to maintain market order. Looking ahead, this regulatory breakthrough will furM88 Malaysiar consolidate Hong Kong’s leading position as an international virtual asset hub, promote deep integration between Tokenised Products and traditional finance, and usher in a new chapter in M88 Malaysia digital asset era.


JunHe Virtual Assets and Web3 Team


We continue to closely monitor regulatory developments in blockchain, virtual assets, and RWA around M88 Malaysia world and have extensive knowledge and experience in M88 Malaysia relevant legal fields. We have provided legal advice to numerous institutional clients and Web3 enterprises on virtual asset and RWA-related businesses in Hong Kong and oM88 Malaysiar jurisdictions, with more than ten successful cases.


We recommend that project parties planning to issue RWA tokenised products focus on M88 Malaysia compliance of M88 Malaysiair project structure and make early preparations. If you have any questions regarding compliance matters for RWA tokenisation in Hong Kong, please feel free to contact us at any time.


We have published M88 Malaysia following articles on compliance requirements for stablecoins and virtual asset-related activities, which you may find of interest:


(1)For insights on RWA tokenisation of gold, please refer to our earlier article titled「」, as well as its English version,RWA Tokenization of Gold — New Opportunities for Hong Kong Web3 in 2026.

(2) For M88 Malaysia latest regulatory developments by M88 Malaysia mainland China authorities in relation to virtual currencies and M88 Malaysia offshore tokenisation of onshore assets (including projects involving mainland assets tokenised overseas), please refer to our earlier article titled「虚拟货币及RWA新规出台——为M88 app优质资产境外代币化打开大门」.

(3) For our analysis of M88 Malaysia consultation conclusions published by M88 Malaysia Financial Services and M88 Malaysia Treasury Bureau (FSTB) and M88 Malaysia Securities and Futures Commission (SFC) on virtual asset dealing services, please refer to our earlier article titled 「香港将针对虚拟资产交易、就虚拟资产提供意见、虚拟资产管理设立新的牌照制度」, as well as its English version,An Introduction to M88 Malaysia New Licensing Regime for Virtual Asset Deals, Virtual Asset Advice and Virtual Asset Management Services.

(4) For insights on M88 Malaysia consultation paper on virtual asset custody services issued by M88 Malaysia FSTB and M88 Malaysia SFC, please refer to our earlier article titled香港将针对虚拟资产托管服务建立监管制度」.

(5) For an analysis of M88 Malaysia SFC’s circular on staking services provided by virtual asset trading platforms, please refer to our earlier articles titled「香港开放虚拟资产质押(Staking)(上篇):深度解析香港证监会《有关虚拟资产交易平台提供质押服务的通函》」and「香港开放虚拟资产质押(Staking)(下篇):一文读懂香港证监会《有关中介人虚拟资产相关活动的补充联合通函》」.

(6) For M88 Malaysia Consultation Paper on Proposed Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Requirements for Regulated Stablecoin Activities and M88 Malaysia Draft Guideline on M88 Malaysia Supervision of Licensed Stablecoin Issuers issued by M88 Malaysia HKMA to provide regulatory guidance for stablecoin issuers, please refer to our earlier articles titled「香港稳定币时代正式启航 —— 上篇:《稳定币条例草案》通过开启新篇章」and「香港稳定币时代正式启航 —— 下篇: 金管局指引咨询解密 - 发行人及分销商需知要点」.

(7) For M88 Malaysia consultation paper issued by M88 Malaysia HKMA on implementing M88 Malaysia regulatory standards promulgated by M88 Malaysia Basel Committee on Banking Supervision (BCBS) in relation to banks’ crypto asset exposures in Hong Kong, please refer to our earlier article titled「香港将实施有关银行持有RWA, 稳定币及比特币等加密资产的监管标准」.

(8) For M88 Malaysia key points in M88 Malaysia Guiding and Establishing National Innovation for U.S. Stablecoins Act in M88 Malaysia United States, please refer to our earlier article titled「美国《GENIUS法案》 揭幕: 美元稳定币引领全球金融新篇章」.

(9) For M88 Malaysia core content of M88 Malaysia Stablecoin Bill published by M88 Malaysia Hong Kong Government and key points of M88 Malaysia licence application, please refer to our earlier article titled「香港稳定币时代加速到来 —— 香港 《稳定币条例草案》立法全速推进」.

(10) For M88 Malaysia Digital Bond Grant Scheme launched by M88 Malaysia HKMA, please refer to our earlier article titled「香港金融管理局推出“数码债券资助计划”」.

(11) For M88 Malaysia Consultation Conclusions for Legislative Proposals to Implement a Regulatory Regime for Stablecoin Issuers in Hong Kong and M88 Malaysia Sandbox arrangements introduced by M88 Malaysia HKMA, please refer to our earlier article titled「一文读懂香港稳定币发行人牌照制度」.

(12) For M88 Malaysia Legislative Proposal to Implement M88 Malaysia Regulatory Regime for Stablecoin Issuers in Hong Kong and M88 Malaysia Sandbox arrangements introduced by M88 Malaysia HKMA, please refer to our earlier article titled「稳定币发行人可以开始申请加入香港金管局沙盒(Sandbox)安排」.

(13) For M88 Malaysia conclusions drawn from M88 Malaysia public consultation conducted by M88 Malaysia HKMA on M88 Malaysia regulation of stablecoin business, please refer to our earlier article titled「香港金管局拟就经营稳定币业务设立强制性发牌制度」.

(14) For details regarding M88 Malaysia Public Consultation on Legislative Proposals to Regulate Over-M88 Malaysia-Counter Trading of Virtual Assets issued by M88 Malaysia FSTB on 8 February 2024, please refer to our earlier article titled「香港OTC立法咨询 - 为虚拟资产交易监管填补空白」.

(15) For M88 Malaysia two circulars related to Tokenised Securities issued by M88 Malaysia SFC on 2 November 2023, please refer to our earlier article titled「代币化证券(Tokenised Securities):香港金融市场新趋势」,

(16) For M88 Malaysia Joint Circular on Intermediaries’ Virtual Asset-Related Activities issued by SFC and HKMA on 20 October 2023,please refer to our earlier article titled「金融机构在香港提供虚拟资产相关活动(包括代币化证券业务)的最新监管导向」.

(17) For a brief introduction to licensing in Hong Kong’s FinTech and Web3 industry, please refer to our earlier article titled「香港金融科技及Web3领域相关牌照简介 - 一文读懂香港信托或公司服务提供者(TCSP)、储值支付工具(SVF)及金钱服务经营者(MSO)牌照」.

(18) For M88 Malaysia latest regulatory developments on stablecoins in M88 Malaysia United States, Singapore and Hong Kong, please refer to our earlier article titled「浅谈全球稳定币监管(二):美国、新加坡、香港稳定币立法趋势比较」.

(19) For details regarding M88 Malaysia Consultation Paper on M88 Malaysia Proposed Regulatory Requirements for Virtual Asset Trading Platform Operators Licensed by M88 Malaysia Securities and Futures Commission issued by M88 Malaysia SFC on 20 February 2023, please refer to our earlier article titled「香港证监会就虚拟资产交易平台牌照(1、7号牌照及VASP牌照)申请要求展开咨询」.

(20) For details regarding M88 Malaysia Policy Statement on Development of Virtual Assets in Hong Kong, issued by M88 Malaysia Hong Kong Special Administrative Region Government on 31 October 2022, please refer to our earlier article titled「确保Web3创新发生在香港 – 香港就推动建设虚拟资产中心发布政策宣言」.

(21) For M88 Malaysia SFC’s regulatory regime for VASPs, please refer to our earlier article titled「香港将针对虚拟资产服务提供商建立发牌制度」.

(22) For an interpretation on M88 Malaysia United States crypto assets act, please refer to our earlier article titled「美国Lummis-Gillibrand 加密资产法案要点解析」.

(23) For an overview of M88 Malaysia regulatory landscape for stablecoins across major countries and regions worldwide, please refer to our earlier article titled「浅谈全球稳定币监管」.




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