Soda Labs

Hong Kong SFC

Retail exclusion achieved without naming anonymity

Regulator or standard-setterAsia-PacificConfidential with disclosure

Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.

What Hong Kong SFC actually says

A useful case study in how a market gets closed without a rule that mentions the thing being closed out. The Hong Kong regime bars retail access to any asset that is not an eligible large-cap virtual asset, defined by presence in two acceptable indices from separate providers. Monero and Zcash fail that liquidity test, so they never reach retail investors, and yet the guidelines contain no reference to anonymity, privacy coins or mixers anywhere in the text. Anyone citing Hong Kong as having banned privacy assets is describing an effect rather than an instrument. The distinction matters when arguing about what regulators have actually decided.

The instruments that matter

Trading platform guidelines, paragraph 7.8
retail clients may only be offered eligible large-cap virtual assets, meaning assets included in at least two acceptable indices from two different providers, one of them IOSCO-compliant
The guidelines never mention anonymity
read in full, the text contains no reference to privacy coins, anonymity or mixers; the exclusion is a consequence of the liquidity test
Case-by-case appeal
paragraph 7.8 leaves room for a platform to make the case for an asset directly to the regulator

What this means for confidential transactions

Bubble is built for exactly this shape of obligation: amounts and balances live on chain as ciphertexts, computation happens without decryption, and the only disclosure path is an on-chain access list through which an authorized party - an auditor, a supervisor, a counterparty - can request scoped decryption. That is confidentiality from the public, not from the regulator.

Compliant by default.

See how selective disclosure satisfies a supervisor without publishing your book to the world.