title: Hong Kong — Conduct, Safeguarding & Promotions | World Payments Monitor canonical: https://payments.gi/jurisdictions/hong-kong/w1b/ publisher: Asymmetric Intelligence ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-06-23 Conduct and safeguarding of SVF licensees are governed by HKMA guidelines issued under s.54 PSSVFO. SVF licensees must maintain AML/CFT systems and meet supervisory expectations set out in the Guideline on Supervision of SVF Licensees. There is no single statutory 'safeguarding' instrument modelled on UK CASS; protection of the float is delivered through SVF minimum criteria and supervisory oversight. The MA holds pecuniary-penalty powers under s.33Q, and an appeals route exists via the PSSVF Appeals Tribunal. Standing sub-brief · as of 4 July 2026 192 words · last cycle 2026-06-28 #### Conduct, Safeguarding & Financial Promotions Conduct and float protection for SVF licensees is delivered via HKMA guidelines under s.54 PSSVFO (the Guideline on Supervision of SVF Licensees) and the SVF minimum criteria, rather than through a single CASS-style safeguarding statute. Float protection is supervisory and criteria-based: there is no discrete statutory safeguarding instrument, and protection of holders' funds is delivered through the SVF minimum criteria and ongoing HKMA supervisory oversight. The Monetary Authority holds pecuniary-penalty powers under s.33Q, with appeals routed via the PSSVF Appeals Tribunal, whose current membership runs 4 November 2025 to 3 November 2028. This is a non-bank-focused module: SVF operators (the non-bank PI/EMI-equivalent population) must meet ongoing supervisory expectations and AML/CFT control standards, with enforcement risk arising through s.33Q penalties. The mechanism is materially distinct from the UK's May 2026 safeguarding rules — Hong Kong does not operate a single statutory safeguarding regime but instead embeds float protection in supervisory criteria. #### Outlook The conduct and float-protection framework is established and supervisory in character. The live distinction to monitor is the gap between Hong Kong's criteria-based model and statutory safeguarding regimes elsewhere; no single safeguarding statute is in prospect. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stored-value-facilities-and-retail-payment-systems/regulatory-regime-for-stored-value-facilities/](https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stored-value-facilities-and-retail-payment-systems/regulatory-regime-for-stored-value-facilities/) retrieved 2026-06-23 2. T1 [https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stored-value-facilities-and-retail-payment-systems/](https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stored-value-facilities-and-retail-payment-systems/) retrieved 2026-06-23 3. T1 [https://www.fstb.gov.hk/fsb/en/topical/pssvfat.html](https://www.fstb.gov.hk/fsb/en/topical/pssvfat.html) retrieved 2026-06-23