The most significant breakthrough of the new regulations is the implementation of full license closed-loop management for the core business of virtual assets, clearly covering the four core areas of trading, custody, consulting, and asset management, completely breaking the previous situation of some business regulatory gaps and incomplete license systems. This means that institutions engaged in virtual asset related businesses in the future need to apply for corresponding licenses based on their own business scope, and are not allowed to engage in related business activities without permission, in order to regulate the behavior of market entities from the source. The construction of a fully licensed closed-loop system can effectively curb chaos such as unlicensed operations and illegal practices, and provide a clear development path for compliance agencies, promoting the concentration of industry resources towards compliant entities and promoting healthy market competition.
Risk grading control is the core highlight of this new regulation and an important manifestation of regulatory refinement. According to the risk characteristics of virtual assets, the new regulations divide them into two categories: low-risk and high-risk, and implement differentiated risk weight management, which echoes the global trend of virtual asset regulation. Among them, compliant stablecoins and RWA (Real World Asset tokenization) are included in the low-risk group, with risk weights consistent with traditional financial assets. This arrangement not only recognizes the value anchoring attribute of compliant stablecoins, but also highlights the low-risk advantage supported by real assets behind RWA - RWA, as a digital asset that maps real assets such as real estate and bonds onto the chain, has clear property rights and controllable risks, and has become one of the low-risk virtual asset types recognized by regulators.
Correspondingly, virtual assets issued by unlicensed public chains such as Bitcoin and Ethereum are classified as high-risk groups, with a risk weight set at 1250%. This strict risk weighting setting means that banks and other financial institutions will be strictly limited in their risk exposure to such high-risk virtual assets. According to regulatory requirements, banks are required to hold capital in a 1:1 ratio for related risk exposure. The high regulatory costs will encourage many banks to actively avoid such assets and prevent the transmission of fluctuations in high-risk virtual assets from a financial perspective. Analysts point out that this differentiated risk classification not only respects the diversity of virtual assets, but also accurately matches the risk levels of different assets, achieving the core regulatory goal of "risk and regulatory equivalence".
At the level of market access, the new regulations clarify the minimum capital threshold for different types of institutions, while enforcing the principle of "separation of trading and custody" to strengthen the bottom line of industry risk prevention and control. According to the new regulations, virtual asset traders are required to pay a minimum of HKD 5 million in share capital, while custodians are required to pay a minimum of HKD 10 million in share capital. The difference of HKD 5 million between the two thresholds reflects higher regulatory requirements for the security of custody business - custody business directly involves user asset security, and higher capital thresholds can enhance the risk resistance ability of custody institutions and reduce risks such as asset loss and misappropriation.
The mandatory requirement of "separation of trading and custody" is a key measure to prevent risks in this new regulation. Its core purpose is to achieve mutual independence and supervision between the trading and asset custody processes, and to prevent user asset damage caused by institutional operational problems. This is highly in line with the global trend of strengthening the protection of virtual asset users. The painful lessons learned from the bankruptcy of exchanges such as FTX have highlighted the enormous risks of mixed operation of trading and custody. The new regulations mandate the separation of the two businesses, which can effectively isolate risks, ensure the safety of users' virtual assets, and enhance the confidence of market participants.
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