Pin and benchmark
Pin the jurisdiction you are leaning towards, then line up to 5 rivals against it. Every unlocked figure shows where a peer beats it or loses to it on capital, timeline, cost and difficulty, so one screen tells you whether your first choice actually holds up.
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| Dimension |
Pinned 🇭🇰 Hong Kong partly open Verified 2026-07-03
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🇰🇷 South Korea
partly open
Verified 2026-07-03
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|---|---|---|
| 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 locked. Unlock with the £349 pass. | South Korea capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Hong Kong timeline to authorisation is locked. Unlock with the £349 pass. | South Korea timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Hong Kong local substance is locked. Unlock with the £349 pass. | South Korea local substance is locked. Unlock with the £349 pass. |
| Application cost | Hong Kong application cost is locked. Unlock with the £349 pass. | South Korea application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is locked. Unlock with the £349 pass. | South Korea ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Hong Kong passporting is locked. Unlock with the £349 pass. | South Korea passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Hong Kong mica casps approved is locked. Unlock with the £349 pass. | South Korea mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Hong Kong key restrictions is locked. Unlock with the £349 pass. | South Korea key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | SFC 'ASPIRe' roadmap (19 Feb 2025); VATP staking guidance (7 Apr 2025); HKMA Stablecoins Ordinance commenced 1 Aug 2025 with the first two issuer licences (HSBC, Anchorpoint) granted 10 Apr 2026; VA dealing (OTC) and custody licensing consultation conclusions 24 Dec 2025 (legislation targeted 2026). ~13 VATPs licensed by mid-2026 - confirm live count on the SFC list. | 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). |
| Difficulty rating | Hong Kong difficulty rating is locked. Unlock with the £349 pass. | South Korea difficulty rating is locked. Unlock with 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.