Global Trustee and Fiduciary Services Bite-Sized Issue 6 2026

2 AIFMD CRYPTOASSETS FINTECH FSB IOSCO MIFID II/MIFIR MONEY MARKET FUNDS OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 6 | 2026 Quick LInks CRYPTOASSETS Circular on SFC-authorised Funds with Exposure to Virtual Assets On 27 May 2026, the Securities and Futures Commission (SFC) published a circular setting out the requirements under which the SFC would consider authorising investment funds with exposure to virtual assets (VA) of more than 10% of their net asset value (NAV) for public offerings in Hong Kong (SFC-authorised VA Funds) under sections 104 and 105 of the Securities and Futures Ordinance, and the VA-related activities in which SFC-authorised VA Funds may engage. These requirements do not apply to SFC-authorised funds’ exposure to fiat-referenced stablecoins (the issue of which is authorised by a licence granted under the Stablecoins Ordinance) and tokenised deposits. The circular sets out the requirements for SFC-authorised funds to: i. Invest directly in the same spot VA tokens accessible to the Hong Kong public for trading on SFC-licensed virtual asset trading platforms (i.e., direct exposure); and/or ii. Acquire indirect investment exposure to such VA (i.e., indirect exposure), for example, through futures traded on conventional regulated futures exchanges and other exchange-traded products. This revised circular supersedes the Circular on SFC-authorised funds with exposure to virtual assets issued on 7 April 2025. Link to the Circular here FSTB and SFC Conclude Consultations on Virtual Asset Advisory and Management Regimes On 26 May 2026, the Financial Services and the Treasury Bureau (FSTB) and the SFC published consultation conclusions on the legislative proposal to regulate virtual asset (VA) advisory and management service providers in Hong Kong. The proposal for the VA advisory and management regimes received broad market support during the consultation. Adhering to the “same business, same risks, same rules” principle, the scope of these regimes will be aligned with those for Type 4 (advising on securities) and Type 9 (asset management) regulated activities under the Securities and Futures Ordinance, respectively. The FSTB and the SFC say that they will now proceed to finalise the legislative proposals for the new regimes under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), aiming to introduce a bill into the Legislative Council in 2026. Alongside the two other recent proposals for VA dealing and VA custody regimes, the FSTB and the SFC say this suite of new regimes aim to increase participation in Hong Kong’s digital asset market while fostering a robust and secure ecosystem under the SFC’s ASPIRe roadmap. The FSTB and the SFC say existing and prospective VA advisory and management service providers are strongly encouraged to engage with the SFC early to initiate pre-application discussions. This will allow entities to better understand the proposed regimes, facilitate more efficient licensing processes, and ensure their regulatory compliance under the new regimes. Link to Consultation Conclusions here Commission Seeks Feedback on the Functioning of EU Crypto-assets Rules On 20 May 2026, the European Commission (Commission) launched a consultation to gather feedback from stakeholders and the wider public on the functioning of the EU’s regulatory framework on crypto assets, the Markets in Crypto Assets Regulation (MiCA). The Commission says it is assessing whether the current framework remains fit for purpose, as crypto-asset markets and the broader policy landscape continue to expand, The Commission says that since the MiCA regulation was developed, digital asset markets have continued to evolve, with the global policy and regulatory landscape also changing significantly. The Commission says it is therefore assessing whether the EU framework needs to be updated considering market and international developments.