Overseas asset managers
Managers considering discretionary portfolio management or advisory activity for Hong Kong clients or funds.

Hong Kong SFC licensing for overseas firms
We help overseas financial firms, asset managers and fintech businesses identify the appropriate SFC regulated activity, prepare clear application documents and navigate the licensing process with greater certainty.
Initial consultations provide general guidance only and do not guarantee SFC approval.
Who we help
If your business is outside Hong Kong and considering regulated activity in the city, we help you understand what applies before you commit time and resources.
Managers considering discretionary portfolio management or advisory activity for Hong Kong clients or funds.
Established firms assessing a Hong Kong presence, booking model and the regulated activities it may trigger.
Platforms and technology-led firms whose products may involve dealing, advising or managing assets under SFC rules.
Firms considering client-facing dealing, advising or corporate finance activity connected to Hong Kong.
What is your core activity in Hong Kong?
Will your portfolio managers or dealing staff be based in Hong Kong?
Do you already have 2 qualified Responsible Officers (ROs)?
SFC Type 9 (Asset Management) + Type 4 (Advising on Securities)
Statutory Minimum Liquid Capital: HK$100,000 (Non-holding client assets) to HK$3,000,000 (Holding assets) · Paid-up Capital: HK$0–HK$5,000,000
Results are preliminary estimates based on your parameters. Book a 20-minute scope review to confirm regulatory exemptions and licensing milestones.
Do you need an SFC licence?
Whether you need an SFC licence depends on your actual business activities, clients, products and Hong Kong operating model — not on your company name, website wording or overseas permissions alone.
Terms such as “regulated activity”, “dealing in securities” or “advising on securities” have specific meanings under Hong Kong rules. Small differences in how clients are served, where decisions are made and how products are distributed can change the answer.
Licence types
The SFC defines “regulated activities”. Most overseas applicants we speak with are considering one of the following. The correct combination always depends on the specific business model.
Type 1
Buying, selling or broking securities for clients — for example, operating a brokerage or executing client orders.
Learn moreType 4
Giving investment advice about securities — for example, recommending stocks or portfolios to clients.
Learn moreType 6
Corporate finance advice — for example, advising on listings, takeovers or fundraising as a financial adviser.
Learn moreType 9
Managing investment portfolios on a discretionary basis — for example, running a fund or managed accounts.
Learn moreThe SFC recognises ten regulated activity types in total. Explore each dedicated guide above for statutory definitions, capital thresholds, RO criteria, and application roadmaps.
What we help with
We support the preparation work that a credible SFC filing requires — from early scope decisions to documents and ongoing compliance routines.
Map your planned activities against SFC regulated activities and identify the likely licence route.
View Dedicated Service GuideDraft a clear, consistent business plan covering model, clients, products, controls and resources.
View Dedicated Service GuidePrepare compliance manuals and core policies that match your actual operating model.
View Dedicated Service GuidePlan the responsible officer, licensed representative and competence structure your application will need.
View Dedicated Service GuideAssemble the application pack, forms and supporting schedules with consistency across documents.
View Dedicated Service GuideSupport compliance routines, filings awareness and practical controls after submission or approval.
View Dedicated Service GuideOur process
A practical sequence that turns a complex licence application into clear decisions, documents and next actions.
We review your activities, clients, products and intended Hong Kong operating model.
We set out the regulated activities that may apply and the practical options for your structure.
We help draft and align the business plan, manuals, policies and supporting materials.
We help organise the submission and respond to follow-up questions and clarifications.
Timelines and outcomes depend on the SFC and the completeness of each application. We do not promise approval or fixed processing times.
About us
SFC applications are often decided long before submission — by whether the regulated activities, people, governance, financial resources and documents tell one coherent story.
HK License supports overseas firms with plain-English guidance and hands-on preparation, so your application reflects how your business will actually operate in Hong Kong.
Guidance framed for firms without an existing Hong Kong licensed presence.
Technical SFC terms translated into clear decisions and next actions.
Business plan, manuals and forms aligned so the file reads as one story.
We explain limits, dependencies and regulator discretion upfront.
Trust and credibility
Evidence-backed regulatory advisory for overseas asset managers, financial institutions, and brokerages.
"HK License delivered our dual Type 4 and Type 9 SFC licences in under 5 months. Their end-to-end guidance on our new energy and equities mandate across Mainland China, Asia, and the US made the regulatory review remarkably fast and seamless."
Managing Partner
Private Equity Firm in Wuhan (New Energy & Public Equities)
Factual recent engagements illustrating our practical licensing delivery for private equity and overseas funds.
Successfully secured both Type 4 and Type 9 SFC licences in under 5 months from initial filing with zero delays.
Successfully granted Type 4 and Type 9 licences, enabling full discretionary mandates and regional investment advisory from Hong Kong.
Successfully secured SFC approval for Type 1 licence addition and implemented ongoing post-licensing compliance routines.
We never claim guaranteed SFC approval. Any outcome depends on the SFC assessment of the specific application.
Regulatory Insights & Research Pillars
Practical analysis, licensing blueprints, and cross-border regulatory comparisons for overseas financial institutions expanding into Hong Kong.
Detailed analysis of FRR liquid capital benchmarks, independent third-party custody carve-outs, and demonstrating discretionary investment authority for overseas portfolio managers.
Head-to-head comparison between Hong Kong SFC Type 9 and Singapore MAS CMS licences: upfront capital lockups, RO staffing standards, OFC/LPF vs VCC fund vehicles, and tax regimes.
Evaluating HKSI examination exemptions, local regulatory knowledge (LRO), and structuring the 8 Manager-in-Charge (MIC) core functions to pass SFC vetting without prolonged requisition cycles.
Explore our dedicated regulatory pillar guides and comprehensive Schedule 5 licence hubs.
FAQs
Short, cautious answers. Exact requirements always depend on your specific business model and operating arrangements.
In most cases you will need an appropriate Hong Kong presence to hold an SFC licence, but the exact structure depends on your operating model, staffing and how regulated activities will be conducted. We recommend confirming the structure during an assessment before incorporating.
It depends on your services, products, clients and how activity is conducted in or targeted at Hong Kong. For example, dealing, advising and asset management fall under different regulated activities. A scope assessment of your specific model is the reliable way to identify the likely route.
Licensed corporations generally need at least two responsible officers (fit-and-proper individuals approved for the relevant regulated activities), subject to SFC requirements and any applicable exemptions. Suitability depends on qualifications, experience and the specific activities. Staffing should be planned early.
We do not quote fixed timelines because timing depends on application completeness, business complexity, SFC questions and your readiness. Preparing complete, consistent documents before submission is the most effective way to avoid delays.
Typically this includes application forms, a business plan, compliance manuals and policies, financial information, corporate documents, and fitness-and-properness materials for key individuals. The exact pack depends on the licence types sought and the applicant structure.
Yes — we can support compliance manuals, practical routines and awareness of filing and conduct expectations relevant to your licensed activities. Ongoing obligations depend on the activities actually carried on.
Share your proposed business activities with our licensing specialists. We will outline the appropriate SFC licence classes, RO requirements, and realistic timelines.
Select a 20-minute slot on our calendar. Share your proposed business activities, clients, and operating model.
Consult with senior specialists to determine exact licence classes, 2 qualified RO requirements, and capital thresholds.
Receive a structured roadmap covering statutory capital, compliance manuals, and realistic WINGS milestones.
Speak directly with our senior regulatory specialists to evaluate your firm’s licensing scope, RO staffing model, and application timeline.
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