1. [Legal business authority and commercial linkage mechanism] of SFC No. 1
Core securities brokerage business
Buy and sell stocks on behalf of clients in accordance with the law、bond、Options and Exchange Traded Funds (ETFs)；Serve as lead underwriter or placement agent in an IPO or refinancing of a listed company；Distribution of various investment funds。
Statutory collateral immunity rules
If Category 4 (advising on securities)、Category 6 or 9 (asset management) services entirely incidental to securities trading business，There is no need to obtain additional licenses according to law；Margin financing can be provided with tens of millions of paid-in capital without applying for No. 8 license plate。
Virtual asset core access
Distributing virtual asset funds must hold a No. 1 license。VATPs that provide security token transactions must apply for both Type 1 and Type 7 licenses。1Number plates also serve as legal qualifications for tokenized assets (RWA) transactions。
1+4+9Number plate business closed loop
Institutions pass "proprietary trading" in accordance with the law(1Number)→Investment advisory services(4Number)→Asset management products(9Number)"Form a closed business loop。Approved to meet FRR and operational requirements through shared responsible officer (RO) and compliance systems。
2. Industry information：Chinese-funded and technology enterprise SFC No. 1 [Statutory approval case]
virtual bank background：Fulong Bank
Virtual banks funded by Tencent and others。2022Obtained Type 1 and Type 4 licenses in November，Business expanded from deposit foreign exchange to wealth management field in accordance with the law，Approved to provide fund product trading services on the App。
Internet brokerage：Futu/Tiger/Oriental Fortune
Futu (Cheetah Trading)、Tiger International (YAX) and Oriental Fortune (Hafu Securities) have both completed the No. 1 license upgrade approval，Permitted to provide customers with “securities” type virtual asset trading services in accordance with the law。
Leading Chinese securities firm：Guotai Junan/Tianfeng/Caitong
Guotai Junan International completes No. 1 license plate upgrade，Open up the whole chain of virtual asset services；Tianfeng International is approved to “provide virtual asset transactions through comprehensive accounts”；Caitong International relies on license plates No. 1 and 4 to carry out direct sales and brokerage business。
Overseas branches of public funds：Harvest International
Founded in 2008。Hold Category 1、Class 4 and Class 9 licenses。Pass the linkage of No. 1 and No. 9 plates in accordance with the law，Providing rights and interests to global investors、Fixed income、Index and multi-strategy asset management and trading services。
3. [Statutory Financial Resources Rules of SFC No. 1] (FRR) standard】
| Legal business model categories | Statutory minimum paid-in share capital (Paid-up Capital) | Legal minimum liquid capital (Liquid Capital) |
|---|---|---|
| Providing securities margin financing (Margin) or any open-end fund (OFC) custodian |
1,000 10,000 Hong Kong dollars | 300 10,000 Hong Kong dollars |
| Hold client assets (Absolutely no margin financing available) |
500 10,000 Hong Kong dollars | 300 10,000 Hong Kong dollars |
| Approved introducing agent or dealer (Absolutely no client assets are held) |
No mandatory minimum requirements | 50 10,000 Hong Kong dollars |
Legal Notes：Licensed corporations must maintain the above funds at all times。As a new applicant，SFC requires corporations to retain additional 6 Fund reserves for monthly operating expenses。If virtual asset services are involved，The corporation must at all times maintain at least the equivalent of 12 Additional quick buffer of monthly actual operating expenses。
4. [Fit and proper person] as stipulated by SFC (Fit & Proper) Legal executive structure]
Responsible person (RO)：Each type of regulated activity must appoint at least 2 Name RO。At least 1 Must be an executive director，And there are at least 1 The RO must be in Hong Kong at all times to supervise daily operations。
RO Competencies：need to be in the past 6 Have at least 3 years of practical experience and 2 Years of management experience。Must hold a degree in finance/law etc.，And pass the HKSI Local Regulatory Framework Examination (Paper 1) in accordance with the law、7、8）。
Core Function Manager (MIC) accountability：The corporation must appoint a dedicated person to be responsible for 8 core functions。The MIC responsible for “overall management oversight” and “principal operations” must also serve as the RO for that activity。
Effective segregation of functions (Segregation of Duties)：Front-office trading functions and middle- and back-office settlement、Compliance、Risk management must be effectively separated (for example, the RO cannot concurrently serve as the compliance officer according to law)。
Hong Kong local content：The corporation must be a company registered in Hong Kong，Have specialized、Safety、Commercial office spaces that can be locked independently and meet physical isolation requirements。The use of pure virtual offices or mailbox addresses is strictly prohibited。
5. [Statutory File Review Checklist] submitted through WINGS electronic platform
| File category | Submission details for statutory requirements |
|---|---|
| Basic corporate and financial evidence | Company registration certificate、Shareholding structure chart that penetrates to the ultimate beneficial owner、Office Lease Agreement。forward 6 Monthly financial budget forecast、Proof of capital injection and recent bank statements。 |
| Business and internal control planning documents | Business Plan。Compliance Manual and Operational Flow Chart。Anti-Money Laundering (AML) Policy。Business Continuity and Disaster Recovery Plan (BCP/DRP)。 |
| Executive suitability due diligence documents | Proposed RO and Licensed Representative (LR) proof of identity、Academic certificate、Work history、SFC exam pass certificate、Statement of no criminal record。Resolution of the board of directors appointed by MIC。 |
6. [Statutory Application and SFC Review Procedure] for Hong Kong No. 1 Plate
first stage：Corporate establishment and preparation (about 3-4 week)
Register a Hong Kong Company，Open a business bank account。Identify and hire compliance ROs and MICs。Lease physical office。Write business plan and compliance manual。
second stage：WINGS system online submission
Complete the application form via the SFC WINGS electronic platform，Upload supporting documents，Pay according to type of regulated activity 4,740 Hong Kong dollars (corporate) and corresponding individual application fee。
The third stage：Written inquiry and reply (Requisitions)
SFC versus business model、Substantive review of financial resources and personnel qualifications，issue 3 to 6 Round of in-depth written inquiries。Applicants are required to submit a clarifying response。
Stage 4：Approved in principle (AIP)
AIP letter is issued after SFC review and approval。Applicants usually have 3 Months to implement remaining conditions (such as completion of capital injection、Confirm bank account、Take out professional liability insurance)。
The fifth stage：Formal licensing and ongoing compliance (total cycle 4-8 months)
SFC official processing target time is 15 week，The practical processing cycle is 4 to 6 months。If it involves complex businesses such as virtual assets，The approval cycle may be extended to 8 to 12 months。
7. Hong Kong Huitong's legal agency service for Hong Kong SFC No. 1 plate case
Corporate establishment and personnel matching
Register a legal entity in Hong Kong。Match legally meets SFC’s “fit and proper person” criteria、Local resident responsible officer (RO) and core functional manager (MIC) holding HKSI qualifications。
Core legal documents and compliance infrastructure
write content 6 Business plan (BP) with monthly operating budget。Preparation covers segregation of duties、Anti-Money Laundering (AML/CTF) Policy and Business Continuity Plan (BCP) Compliance Control Manual。
WINGS Application and Defense Agent
Agent for FRR capital verification audit and bank account opening。Responsible for submitting case files through WINGS system，Respond fully to SFC’s multiple rounds of written inquiries (Requisitions)，Agency to in-principle approval and formal licensing。
8. Hong Kong SFC No. 1 License Core Legal Questions and Answers (FAQ)
Type 1 (securities trading) licenses are issued by the Hong Kong Securities and Futures Commission (SFC) in accordance with the Securities and Futures Ordinance (SFO) implemented in 2003.。
Category 1 (securities trading) can be linked with Category 4 (Investment Consulting) and Category 9 (Asset Management)，Realize the business closed loop of “proprietary trading→investment advisory services→asset management products”，Shared Responsible Officers (ROs) to optimize statutory compliance costs。
Existing license 1 corporations must apply to the SFC for modification of license conditions。Currently, according to law, you can only cooperate with the approved SFC Virtual Asset Trading Platform (VATP) in the "integrated account" mode.，Customer virtual assets are not allowed to be held directly。
Provide margin financing with minimum paid-up equity 1,000 10,000 Hong Kong dollars，Liquid capital 300 10,000 Hong Kong dollars；Holds paid-up capital of client assets 500 10,000 Hong Kong dollars；There is no paid-up share capital requirement for pure introducing agents.，Liquid capital 50 10,000 Hong Kong dollars。
Absolutely not。A corporation must establish a specialized agency in Hong Kong、Safety、Lockable physical office space。Corporations must prove that core business decision-making and management control exist in Hong Kong。
Each type of business must appoint at least two ROs，At least one executive director shall be resident in Hong Kong。ask to go 6 Have at least 3 years of practical experience and 2 Years of management experience，Pass the HKSI local regulatory examination。
Corporations must designate personnel to manage 8 core functions。The MIC for “Overall Management Supervision” and “Major Business Lines” must also serve as RO。MIC can be located overseas，But it must have decision-making power within the corporation，Bear legal accountability。
Must cover business scope、Profit model、target customers，and forecast operating expenses for the first six months after licensing。If liquid funds are insufficient to cover expenses，Proof of backup capital injection plan must be provided。
The official processing time target is 15 week。In practice, SFC will issue 3 to 6 In-depth inquiry，The approval cycle is usually 4 to 6 months；Complex models involving VA and other matters are legally extended to 6 to 12 months。
Corporations holding client assets must submit a monthly Financial Resources Return (FRR) to the SFC。Once liquid capital falls below the legal requirement 120%，Must report immediately and suspend new business in accordance with the law。
Must be within one month after the anniversary date of license approval，Submit annual return and pay annual fee via WINGS。Overdue fees will trigger 10% to 50% surcharges，overdue 4 The license will be revoked within months。
The acquisition of a licensed shell company requires a comprehensive investigation of historical transactions and compliance penalties。According to the Securities and Futures Ordinance，Before changing the major shareholder, you must first apply to the China Securities Regulatory Commission and obtain approval in accordance with the law.，Buying without approval is a serious criminal offense。
