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| Dimension |
Pinned 🇭🇰 Hong Kong partly open Verified 2026-08-15
|
🇰🇷 South Korea
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | SFC Virtual Asset Trading Platform (VATP) licence on a dual basis: under the AMLO and, for tokens that are securities, under the SFO (Type 1 dealing + Type 7 automated trading). Stablecoin issuance is separately licensed by the HKMA under the Stablecoins Ordinance (Cap. 656). | VASP registration (not a discretionary licence) under the Act on Reporting and Using Specified Financial Transaction Information (the 'FTRA'/AML Reporting Act, amended effective 25 Mar 2021), which requires: (1) ISMS certification from KISA (Korea Internet & Security Agency); (2) for KRW fiat on/off-ramp services, a bank-issued real-name verified account; plus fit-and-proper/AML program requirements. Layered on top since 19 July 2024 is the Act on the Protection of Virtual Asset Users (VAUPA), which adds customer-asset segregation, insurance/reserve, and market-abuse rules but does not replace the underlying FTRA registration. |
| Regulator | SFC regulates VATPs and security-token activity; HKMA regulates stablecoin issuers and banks' VA activities. Staking and intermediary VA activity are covered by joint SFC-HKMA circulars. | Financial Services Commission (FSC), Korea's top financial policymaker; Korea Financial Intelligence Unit (KoFIU, also referred to as FIU), an FSC-subordinate unit established 2001 under the FTRA that receives and processes VASP registrations and AML reporting; day-to-day supervision/inspection is delegated to the Financial Supervisory Service (FSS), which set up dedicated Virtual Asset Supervision/Investigation bureaus (announced 29 Nov 2023). FSC retains final sanctioning authority. |
| Capital requirement | Hong Kong capital requirement is included in the £349 pass. | South Korea capital requirement is included in the £349 pass. |
| Timeline to authorisation | Hong Kong timeline to authorisation is included in the £349 pass. | South Korea timeline to authorisation is included in the £349 pass. |
| Local substance | Hong Kong local substance is included in the £349 pass. | South Korea local substance is included in the £349 pass. |
| Application cost | Hong Kong application cost is included in the £349 pass. | South Korea application cost is included in the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is included in the £349 pass. | South Korea ongoing cost is included in the £349 pass. |
| Passporting | Hong Kong passporting is included in the £349 pass. | South Korea passporting is included in the £349 pass. |
| MiCA CASPs approved | Hong Kong mica casps approved is included in the £349 pass. | South Korea mica casps approved is included in the £349 pass. |
| Key restrictions | Hong Kong key restrictions is included in the £349 pass. | South Korea key restrictions is included in the £349 pass. |
| Recent changes | SFC ASPIRe roadmap (19 Feb 2025); VATP staking guidance (7 Apr 2025); HKMA Stablecoins Ordinance in force 1 August 2025, with the first two issuer licences (HSBC, Anchorpoint) granted 10 April 2026; the HKMA register lists only these two issuers as of 23 April 2026. FSTB and SFC published consultation conclusions on virtual asset dealing and custodian licensing on 24 December 2025, then published consultation conclusions on virtual asset advisory and management service provider licensing on 26 May 2026. All four new licensing regimes, dealing, custodian, advisory and management, have now completed consultation; FSTB and SFC are finalising the legislative proposals, with a single bill covering all four regimes still targeted for introduction into the Legislative Council within 2026 (not yet introduced). 13 VATPs are licensed by the SFC, unchanged since the last review (most recently NewBX, licensed 18 May 2026). A June 2026 Legislative Council reply confirmed the HKMA received 36 stablecoin-licence applications in the first window and expects the overall number of licences to remain very limited. | The 20 Aug 2026 tightening is now identifiable as Act No. 21358 (amendment to the FTRA/AML Reporting Act), promulgated 19 Feb 2026 and taking effect 20 Aug 2026. It removes the KRW 1,000,000 Travel Rule de minimis threshold and separately expands VASP entry screening: adds a statutory definition of major shareholders, extends fit-and-proper disqualification checks to major shareholders, adds financial condition, social credibility, organisational, staffing and IT review factors, and authorises KoFIU to attach conditions when accepting a VASP report. Existing registered VASPs must re-report under the amended Article 7 within 3 months of the effective date (by approximately 20 Nov 2026). Separately, a Foreign Exchange Transactions Act amendment creating cross-border VASP registration passed 7 May 2026 (effective date disputed, 2 Aug vs 2 Dec 2026). The FSC's implementing-decree package (public comment 30 March to 11 May 2026) adds entry screening for VASP re-reports: a debt-ratio ceiling of 200 per cent excluding customer deposits, a three-year clean default record, fit-and-proper tests for officers and major shareholders, and AML staffing requirements; it removes the KRW 1,000,000 Travel Rule de minimis entirely and treats cross-border transfers of KRW 10,000,000 or more to foreign VASPs or private wallets as automatically suspicious. |
| Difficulty rating | Hong Kong difficulty rating is included in the £349 pass. | South Korea difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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