# Hong Kong SFC

> Hong Kong SFC (Securities and Futures Commission): Retail exclusion achieved without naming anonymity. Region: Asia-Pacific. Confidential 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.

Part of the Soda Labs Privacy Hub regulation map, which reads the instruments
themselves rather than summarising the summaries: https://www.sodalabs.xyz/privacy-hub/regulation

## Key facts

- Entry type: Regulator or standard-setter
- Region: Asia-Pacific
- Subject: Retail exclusion achieved without naming anonymity
- Authority: Securities and Futures Commission
- Stance on on-chain confidentiality: Confidential 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.
- Tags: large-cap gate, no anonymity language, index test, retail perimeter
- Canonical page: https://www.sodalabs.xyz/privacy-hub/regulation/reg-hk-sfc

## What it 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

## Sources

- [SFC virtual asset trading platform operators](https://www.sfc.hk/en/Rules-and-standards/Virtual-assets/Virtual-asset-trading-platforms-operators)

## Related entries

- [Hong Kong SAR](https://www.sodalabs.xyz/privacy-hub/regulation/jur-hong-kong): Retail exclusion by liquidity gate, not by anonymity rule
- [Monetary Authority of Singapore](https://www.sodalabs.xyz/privacy-hub/regulation/reg-mas): The regulator that priced the risk instead of banning it
- [APG](https://www.sodalabs.xyz/privacy-hub/regulation/reg-apg): How the global standards actually reach Asia
- [Australia](https://www.sodalabs.xyz/privacy-hub/regulation/jur-australia): Travel rule without a threshold, no coin ban
- [Japan FSA and JVCEA](https://www.sodalabs.xyz/privacy-hub/regulation/reg-japan-fsa): A traceability test, applied by the industry body
- [Kazakhstan](https://www.sodalabs.xyz/privacy-hub/regulation/jur-kazakhstan): Surveillance tooling required of operators, not run by the state