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GDF & W3H Response to the Hong Kong SFC Consultation Paper on the Legislative Proposal to Regulate Virtual Asset Advisory Service

Providers and Virtual Asset Management Service Providers.

W3H and GDF convened their joint APAC Policy and Regulatory Working Group to analyse the Consultation Paper on the Legislative Proposal to Regulate Virtual Asset Advisory Service Providers and Virtual Asset Management Service Providers.

Please note that, as this response was developed in collaboration with W3H and GDF members,
as well as community partners, portions of our response may be similar or verbatim to responses
that the SFC may receive from individual firms. However, noting as well that this response reflects a consensus-based submission across a diverse membership.

We appreciate the opportunity to engage on the proposals, and our response to the consultation aims to support the SFC and FSTB in further developing an overarching framework for virtual assets. In collaboration with our members, we have aimed to provide feedback and suggested key themes that would be beneficial for consideration as the SFC continues to build out its proposals. We also aimed to consider requirements in other jurisdictions that impact our members.

Submitted: 23/01/26

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