APAC Monthly Private Wealth Legal Developments – November 2025 - Industry Updates & Analysis

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Australia

ASIC consults on stamp duty and portfolio holdings disclosure requirements for super funds

ASIC has launched a consultation on proposed changes to stamp duty and portfolio holdings disclosure requirements. The consultation follows on from a targeted review of superannuation investment disclosure requirements which was announced in August 2025.

With regard to stamp duty disclosure changes, ASIC is proposing that stamp duty be disclosed as an average amount over seven years, rather than an annual sum, in fees and costs summaries. The proposal would require a change to ASIC Corporations (Disclosure of Fees and Costs) Instrument 2019/1070 (Instrument 2019/1070). While on private debt transparency, ASIC is proposing class order relief for superannuation trustees, aligning portfolio holdings disclosure obligations for internally-managed private debt with externally-managed private debt.

Feedback is requested by 20 February 2026.

ASIC plans to conduct a broader review of Regulatory Guide 97 Disclosing fees and costs in product disclosure statements (PDS) and periodic statements (RG 97) in the 2026-27 financial year to ensure guidance remains robust and relevant for industry and consumers. [28 Nov 2025]

ASIC consults on updates to RG 234 Advertising financial products and services (including credit): Good practice guidance

ASIC has set out proposedupdates to Regulatory Guide 234 Advertising financial products and services (including credit): Good practice guidance (RG 234).

The updates are intended to ensure that ASIC's regulatory approach to advertising financial products and services remains current and clear by:

providing guidance reflecting ASIC enforcement and regulatory action relevant to advertising conduct undertaken since the publication of RG 234 in 2012;
incorporating guidance from RG 53The use of past performance in promotional material to ensure all of ASIC's advertising guidance is in one location; and
simplifying and streamlining the existing guidance.

ASIC proposes to withdraw RG 53 after the updated RG 234 is published.

Feedback is requested by 22 January 2026. [27 Nov 2025]

ASIC Commissioner Kate O'Rourke – Balancing consumer protections and consumer demands in the fast-moving world of payments

ASIC Commissioner, Kate O'Rourke, gave a speech at the Women in Payments Gala Evening on 19 November 2025. The key points of her speech were:

The structural changes experienced by the payments landscape are enhanced by technology.
ASIC has described the interaction between regulators and industry as a 'symbiotic relationship' in which regulators are seen as 'enablers' and industry as 'accelerators' of innovation.
ASIC provides that it is important to ensure regulatory settings in relation to payment products are responsive and can evolve as required.
Payments licencing reforms are designed in a way where different participants are given an appropriate degree of regulation based on the level of risk their activities pose to consumers and the payments system. Risk-based regulation can assist in achieving fairness without unduly stifling business and innovation. [20 Nov 2025]

ASIC extends disclosure and reporting relief for super trustees

ASIC announced that it has extended existing relief granted to superannuation trustees from disclosure and reporting consistency obligations which require that information given to the public be calculated in the same manner that information is reported to APRA under an APRA reporting standard.

The extension will be delivered through ASIC Superannuation (Amendment) Instrument 2025/449, ensuring that trustees are exempt from requirements under s 29QC(1) of the Superannuation Industry (Supervision) Act 1993 (Cth). The relief will expire on 1 January 2029.

The decision follows a consultation with superannuation industry representatives where stakeholders supported the extension by a further three years. The rationale behind the extension is due to the uncertainty around how to achieve disclosure requirements. [20 Nov 2025]

ASIC announces 2026 enforcement priorities

ASIC has published its 2026 enforcement priorities. ASIC's new enforcement priorities include:

misleading pricing practices impacting cost of living;
poor private credit practices;
financial reporting misconduct (including failure to lodge financial reports);
claims and complaint handling failures by insurers; and
continuing to work on the Shield and Guardian Master Funds.

ASIC's continuing enforcement priorities include:

strengthening investigation and prosecution of insider trading conduct;
misconduct exploiting consumers facing financial difficulty (including unethical credit practices);
unlawful practices seeking to evade small business creditors;
a focus on super trustee accountability for member services failures; and
auditor misconduct.

ASIC Deputy Chair, Ms Court, stated that the 2026 enforcement priorities aim to protect consumers from financial harm and maintain ethical standards in financial markets. [13 Nov 2025]

ASIC takes legal action against MWL Financial Services, its former director, and Imperial Capital Group Australia alleging provision of inappropriate financial advice in relation to the Shield Master Fund (Shield)

ASIC announced that it has sought leave to commence proceedings against MWL Financial Services Pty Ltd (MWL), its former director, and Imperial Capital Group Australia Pty Ltd (Imperial) in the Federal Court. ASIC is alleging failings in relation to Imperial's referral of clients to MWL and the financial advice given by MWL advisers. Chief amongst its proposed allegations include:

between May 2022 and February 2023, MWL representatives advised at least 556 clients to make initial investments of approximately $114 million of their superannuation into Shield;
MWL failed to take reasonable steps to ensure its representatives acted in clients' best interests and provided appropriate advice about investing in Shield;
MWL failed to ensure its financial services were provided efficiently, honestly and fairly and failed to have in place adequate arrangements to manage conflicts of interest;
as the lead generator, Imperial made misleading representations to prospective clients about the standard, quality and benefits of MWL's financial services;
MWL's director was involved in MWL's alleged contraventions in relation to general licensee obligations and taking reasonable steps to ensure its representatives were complaint with best interests duties;
MWL received advice fees charged to clients where it prepared Statements of Advice recommending investment in Shield; and
Imperial received approximately $12.8 million in payments from entities associated with Shield for client referrals.

ASIC will seek to allege that MWL contravened ss 912A(1)(a) and (aa), 961K(2) and 961L of the Corporations Act and that the director was involved in MWL's contraventions under ss 912A(1)(a) and (aa) and 961L. ASIC will further seek that Imperial was involved in MWL's contravention of s 912A(1)(a), as well as contravening s 12DB of the Australian Securities and Investments Commission Act 2001 (Cth) (ASIC Act). [13 Nov 2025]

ASIC alleges SQM Research prepared misleading reports related to Shield

ASIC announced that it has commenced proceedings in the Federal Court against SQM Research Pty Ltd, alleging that SQM prepared research reports which allegedly contained misleading representations.

ASIC maintains that SQM's processes fell short of expected standards when it published ‘favourable' ratings for Shield. The allegations pertain to research reports published by SQM in October 2021, March 2022 and October 2022 where it rated different classes of Shield shares as ‘3¾ stars, Favourable'. The research reports were provided to financial advisers and superannuation trustees who recommended Shield to members.

ASIC's further allegations include that in preparing the reports, SQM:

failed to obtain necessary information to properly assess Shield;
failed to consider inconsistencies in the information it received;
misrepresented that it had a reasonable basis for giving Shield a ‘favourable' rating and that it had exercised reasonable care and skill as part of that exercise; and
made representations that understated the percentage of funds managed by Shield and its asset allocation.

This is the first time ASIC has taken action against a research house, with ASIC Deputy Chair Sarah Court highlighting the level of dependence on information from research houses.

ASIC will allege that SQM contravened s 912A(1)(a) of the Corporations Act and ss 12DB(1)(a) and 12DB(1)(e) of the ASIC Act. ASIC is seeking declarations and civil penalties. [13 Nov 2025]

ASIC alleges Interprac failed to ensure its authorised representatives complied with best interests obligations

ASIC announced that it has commenced civil penalty proceedings in the Federal Court against Interprac in relation to the Shield and First Guardian Master (First Guardian) funds. ASIC alleges Interprac failed to ensure that its former authorised representatives, Venture Egg and Rhys Reilly Pty Ltd, complied with best interests obligations and failed to have adequate risk management systems in place.

The representatives advised approximately 6,843 clients to invest around $677 million in superannuation funds into Shield and First Guardian. More specifically, ASIC further alleges that Interprac failed to:

implement an adequate process for approving financial products that it allowed into its approved product list, relying solely on external research;
respond appropriately to the use of lead generators;
respond adequately to news that payments were made to entities associated with Shield and First Guardian;
enforce or maintain a hold on new investments into Shield and First Guardian after Interprac's Managing Director and Responsible Manager acknowledged the issues with Shield and First Guardian;
prevent the use of clients' superannuation being invested in Shield and/or First Guardian without their express consent;
respond adequately to significant inflows of investment into Shield and First Guardian;
provide adequate responses to client complaints and responding with a template response; and
respond adequately to impose consequences in response to compliance issues.

ASIC will seek declarations, civil penalties and orders to restrain Interprac from carrying on a financial services business. [13 Nov 2025]

APRA Executive Director Carmen Beverley-Smith – Speech to the Association of Superannuation Funds of Australia Conference 2025

APRA Executive Director, Carmen Beverley-Smith, delivered a speech at the Superannuation Funds of Australia Conference 2025. The key points of her speech were:

Strong collaboration between industry bodies and leaders is required to support cohesive responses to threats and strengthen member confidence.
Leadership within funds is critical and APRA's focus remains in analysing the quality and capability of trustee boards.
APRA is engaging with the industry with respect to uplifting board governance standards and expects to release draft governance standards and guidance in the second quarter of 2026.
APRA's last review of platform trustee's identified gaps in areas including due diligence, onboarding practices, ongoing monitoring of investment options and remedial action.
Cyber resilience remains a high priority area for APRA, and after cyber incidents, APRA expects multi-factor authentication as a bare minimum expectation in relation to cyber controls.
APRA remains focused on fund expenditure work and is engaging with trustees to ascertain more information such as documents relating to discretionary expenditure. [12 Nov 2025]

ASIC releases report on key licensing and professional registration activities

ASIC has published Report 825 – Licensing and professional registration activities: 2025 update (REP 825), which aims to update Australian financial services and credit licensees and prospective applicants on the current licensing regime and any upcoming reforms.

The Report focuses on new licensing application systems and processes that support efficient regulation and provides information on licensing and registration applications from the 2024–2025 financial year. The Report provides insight into current and emerging licensing issues in relation to the regulation of digital crypto assets, as well as proposed reforms to the Australian financial services licensing (AFSL) regime.

Further, ASIC provided key statistics on the AFSL regime, stating that between 1 July 2024 and 30 June 2025:

1,531 licensing and registration applications were received;
1,176 applications for new and varied AFS and credit licences were finalised;
290 new AFS licences and 104 new credit licences were granted;
450 AFS and credit licence variation applications were approved;
109 company auditors, 37 self-managed superannuation fund auditors and 27 liquidators were registered;
registered 109 company auditors, 37 self-managed superannuation fund auditors and 27 liquidators;
77% of new AFS licence applications and 76% of AFS licence variation applications were decided within 150 days; and
215 AFS licences and 253 credit licences were cancelled or suspended.

ASIC Commissioner, Mr Kirkland, commented that the report provides essential information to stakeholders at a time where the industry expects to see more digital asset providers apply for an AFSL. [10 Nov 2025]

ASIC issues new RG 282 on exchange-traded products

ASIC announced that it has issued Regulatory Guide 282 – Exchange Traded Products (RG 282), which provides guidance on the treatment of exchange-traded products (ETPs), including exchange traded funds (ETFs).

RG 282 incorporates Information Sheet 230 – Exchange traded products: Admission Guidelines (INFO 230) and aims to explain key legislative instruments, regulatory relief and other information, including:

general obligations applicable to ETP issuers, such as responsible entities of registered management investment schemes;
specific obligations under market operator rules which govern the admission and quotation of ETPs; and
general obligations applicable to market operators that admit ETPs, including those approving ETP issuers.

RG 282 is comprised of two key limbs:

the first part is relevant to issuers of interests or shares in ETFs that are responsible entities, providing guidance on how ETF issuers can comply with their obligations under the Corporations Act 2001 (Cth) (Corporations Act); and
the second part focuses on Australian market operators that admit ETPs, setting out best practice in relation to admission and monitoring standards for ETPs (based on current market practice).

RG 282 was released following a consultation with industry stakeholders where support was expressed for a consolidated regulatory guide on ETPs. [7 Nov 2025]

ASIC releases roadmap for capital markets

ASIC has published REP823, which aims to provide a roadmap to manage and advance Australia's evolving capital markets. As explained by ASIC Chair Joe Longo, the report is intended to, '[lay] out the choices and future of Australia's markets. We want our markets – private and public – to grow. That growth means stronger businesses, more jobs and a boost to our economy.' The report comes as a direct product of the feedback received following ASIC's publication of a discussion paper on the shifting dynamics between public and private markets in February 2025.

The roadmap advocates for modernising public markets through new listing frameworks, streamlined IPO processes and stable trading platforms to attract foreign listings and innovative businesses. It also calls on market operators to consider director responsibilities and strategies to increase global competitiveness. For private markets, ASIC proposes the creation of better governmental tools to facilitate ASIC's supervision of funds more effectively.

A key focus of the report is the rapid growth of private credit within Australia's financial system, with ASIC identifying corresponding risks such as limited transparency and inconsistent valuation practices. To address these, the roadmap sets out principles for responsible lending and risk management, aiming to lift practices and promote confident and informed participation by investors and borrowers. ASIC signals its readiness to take enforcement action against poor practices, particularly in valuation and disclosure.

Separately, the report also explores the significance of superannuation as a market shaping force, with ASIC Commissioner Simone Constant stressing the expectation that the importance of superannuation trustees in public investment and private credit will likely grow as they expand into more diversified areas. As such, the roadmap also aims to set out a 'future where private credit grows from strong foundations'. [5 Nov 2025]

Independent review of the Enhanced Regulatory Sandbox

The Treasury has announced that in mid-November 2025, it will undertake an independent review of the Enhanced Regulatory Sandbox (ERS). The review will evaluate not only the effectiveness of the ERS through consultation with stakeholders but will also develop recommendations for the government to better facilitate financial innovation within Australia. [Nov 2025]

Hong Kong

Additional day-end trade files for Hong Kong securities market and Northbound trading under Stock Connect launched on 1 December 2025

The Stock Exchange of Hong Kong Limited has announced the launch of additional day-end trade files containing supplementary information for both the Hong Kong securities market and Northbound trading under Stock Connect (see our previous update).

From 1 December 2025, the additional files were available daily on the Electronic Communication Platform for download. [29 Nov 2025]

SFC further streamlines measures for authorised EU-regulated retail funds to implement changes efficiently

The SFC has issued a circular announcing a series of streamlined post-authorisation measures for UCITS funds (i.e. Undertakings for Collective Investment in Transferable Securities domiciled in France, Luxembourg, Ireland and the Netherlands, and collective investment schemes domiciled in the United Kingdom authorised as UK UCITS) to facilitate their implementation of changes that are in compliance with their home jurisdiction regulation.

The key streamlined measures cover the following post-authorisation matters:

Change of key operators – Removing the SFC's requirement on prior approval for change of depository and investment delegates which are under the home regulator's supervision.
Material changes in investment objectives, policies and restrictions – Removing the SFC's requirement on prior approval for material changes in investment objectives, policies and restrictions which comply with the fund's home jurisdiction requirements, except for changes that involve novel or complex product features and/or which may have local policy implications.
Post-authorisation notifications – To align the SFC's notification requirements with the fund's home jurisdiction requirements, including the notice periods and content requirements.

The following documents regarding the streamlined measures for UCITS funds have been updated:

HKMA designates FINEST and ICLNet as platforms for AI-to-AI information sharing for detection or prevention of crime

On 7 November 2025, the HKMA gazetted its Guideline on AI-to-AI Information Sharing for the Detection or Prevention of Crime (see our previous update), which followed the enactment of the Banking (Amendment) Ordinance 2025.

The amendment ordinance introduces a voluntary mechanism for authorised institutions (AIs) and relevant law enforcement agencies to share information of corporate and individual accounts with each other via secure platforms designated by the HKMA, when AIs become aware of suspected prohibited conduct (ie, money laundering, terrorist financing or financing of proliferation of weapons of mass destruction). It also provides legal protection for AIs that disclose relevant information.

The HKMA has now gazetted the following two designated platforms for the purpose of the amendment ordinance:

Financial Intelligence Evaluation Sharing Tool operated by the Hong Kong Police Force; and
HKICL Network operated by HKICL Services Limited.

The notice (Notice no. 7424) can be accessed from the Government Notice page for 28 November 2025 (No. 48, Vol. 29) on the e-Gazette portal. [28 Nov 2025]

HKMA issues revised SPM modules, code of practice, disclosure templates and tables, and banking returns in relation to cryptoassets standard

The HKMA has finalised (i) the new SPM module CRP-1 'Classification of Cryptoassets' and (ii) the revisions to the following set of SPM modules and a code of practice, which will take effect on 1 January 2026:

CA-D-1 'Guideline on the Application of the Banking (Disclosure) Rules';
CA-G-1 'Overview of Capital Adequacy Regime for Locally Incorporated Authorized Institutions';
CA-G-5 'Supervisory Review Process';
CR-G-8 'Large Exposures and Risk Concentrations';
CR-G-9 'Exposures to Connected Parties';
CR-L-5 'Major Acquisitions and Investments: BELR Part 3';
LM-1 'Regulatory Framework for Supervision of Liquidity Risk';
MR-1 'Market Risk Capital Charge';
MR-2 'CVA Risk Capital Charge'; and
Banking (Exposure Limits) Code.

The HKMA has issued a revised package of standard disclosure templates and tables (see clean / marked-up versions), which is intended to be used by authorized institutions (AIs) for making disclosures under the BDR. The revised package mainly reflects the capital standards and disclosure requirements for cryptoasset exposures, featuring a new Part XII, as well as revisions to the existing templates and tables.

The reporting templates, completion instructions and XML files for the following banking returns are scheduled for AIs to download in December 2025:

Liquidity Position (MA(BS)1E);
Certificate of Compliance (MA(BS)1F(a) and (b));
Capital Adequacy Ratio (MA(BS)3);
Return of Market Risk and CVA Risk Capital Charge (MA(BS)3A);
Return of Stable Funding Position of an Authorized Institution (MA(BS)26);
Return of Leverage Ratio (MA(BS)27); and
Return of Large Exposures (MA(BS)28).

Apart from some textual changes, formatting adjustments as well as changes agreed with the industry, there will be no material revisions to the consultative versions of the reporting templates and the completion instructions. [28 Nov 2025]

SFC Chief Executive Officer outlines regulatory measures for private credit, AI, digital assets and regional connectivity at ASEAN+3 Economic Cooperation and Financial Stability Forum

Ms Julia Leung, the SFC's Chief Executive Officer, delivered a keynote speech at the Fourth ASEAN+3 Economic Cooperation and Financial Stability Forum, setting out the SFC's regulatory approach to address structural changes in financial markets.

Ms Leung highlighted the following four transformative forces in financial markets and regulators' adapted measures:

Rapid growth of private credit market – the SFC has enhanced surveillance of the over-the-counter (OTC) derivatives market, introducing mandatory reporting requirements for delta positions and supporting international efforts to standardise disclosure for non-bank financial institutions.
Technology in financial services sector – Licensed firms are required to maintain robust governance and risk management frameworks for artificial intelligence (AI) and generative (GenAI), including mandatory human oversight for high-risk use cases. Hong Kong regulators are also developing the cybersecurity framework and quantum-safe infrastructure.
Rise of distributed ledger technology (DLT) and new asset classes – the SFC is advancing a comprehensive regulatory framework for digital assets, with regimes for exchanges, advisors, asset managers and products already in place. The SFC also supports tokenisation pilots and live transactions under Project Ensemble, focusing on interoperability and investor protection. With Hong Kong's stablecoin legislation coming into effect in August 2025 (see our previous update), the HKMA has required reserve assets backing authorised stablecoins to be properly managed and independently audited.
Geo-economics and new pivots in financial linkages – Fragmented liquidity and diverging regulatory approaches require regulatory collaboration in Asia for a more resilient and synergistic Asian market.

In his opening remarks at the same forum, Eddie Yue, the HKMA's Chief Executive, also highlighted the significance of deepening regional cooperation. [25 Nov 2025]

HKMA outlines regulatory philosophy for GenAI and four-level anti-fraud ecosystem

In his keynote speech (in Chinese) at the 2025 Cross-Strait and Hong Kong-Macao Banking Wealth Management Forum, Mr Alan Au, the HKMA's Executive Director (Banking Conduct), highlighted the HKMA's regulatory philosophy for generative AI (GenAI) and set out a four-level anti-fraud ecosystem. A summary of the speech is set out in the attached presentation slides.

The HKMA shared its regulatory philosophy for GenAI from the following four key aspects:

The HKMA engages proactively and maintains a balanced approach by initiating early and ongoing dialogue with banks, ensuring that industry feedback is incorporated into regulatory requirements.
A risk-based and technology-neutral stance is adopted, with high-level, flexible standards that prioritise responsible innovation and ethical use, rather than imposing prescriptive rules.
The HKMA aligns its approach with international standards and draws on global best practices, including those of the OECD, FSB and FinCoNet.
Banks are required to embed consumer protection as a core consideration at the product and service design stage.

In response to the rising financial crime, the HKMA, together with the banking industry and enforcement agencies, introduced a fraud prevention ecosystem across the following four levels:

At the bank level, banks are required to implement dynamic fraud transaction monitoring systems to detect suspicious activity.
At the bank-to-bank level, the HKMA promotes enhanced information sharing to block fraudulent transactions (see our previous update).
At the bank-to-customer level, the HKMA requires banks to offer customer empowerment tools, such as the Safe Deposit Box and e-banking security measures.
At the customer level, the HKMA leads public education campaigns, with a focus on seniors and students, and encourages cross-sector collaboration to raise scam awareness. [21 Nov 2025]

FSTB Secretary highlights future digital asset and fintech initiatives at Fintech Forward Forum cum 01 Fintech Excellence Awards 2025

The Secretary for the FSTB, Mr Christopher Hui, delivered a speech (in Chinese) at the Fintech Forward Forum cum 01 Fintech Excellence Awards 2025. He reviewed Hong Kong's recent fintech achievements and outlined the following key upcoming initiatives (among other things):

The FSTB and the HKMA are jointly studying the applicability of existing laws to tokenised bonds, with details to be announced in the first half of 2026. This aims to facilitate wider adoption of tokenisation in Hong Kong's bond market.
The HKMA's Project Ensemble has entered its pilot phase as Ensemble^TX, focusing on real-value transactions using tokenised deposits in the money market (see our previous update). Ensemble^TX will continue through 2026, with progressive upgrades to support broader tokenisation use cases. The SFC and HKMA will work closely to advance practical applications of tokenisation technology in the financial sector.
The FSTB and Shenzhen Municipal Financial Regulatory Bureau have promulgated a 2025-2027 action plan for jointly building Hong Kong-Shenzhen global fintech hub (see our previous update). The goal is to implement over 20 cross-border data validation platform use cases in the financial sector by the end of 2027.
The FSTB plans to introduce a licensing regime for digital asset trading and custody service providers, aiming to submit the relevant bill to the Legislative Council in 2026. Once enacted, Hong Kong's regulatory framework will comprehensively cover key nodes of the digital asset industry.

Mr Hui also noted that the FSTB will continue to balance innovation, risk management, and investor protection, and will further refine the digital asset regulatory framework in line with international standards. [21 Nov 2025]

HKMA issues guidance on risk-based AML/CFT controls for PEPs

The HKMA has issued a circular to authorised institutions (AIs) and stored value facility (SVF) licensees to provide guidance on anti-money laundering and counter-financing of terrorism (AML/CFT) controls for politically exposed persons (PEPs). Following amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) in 2023, which aligned Hong Kong's regime with the latest Financial Action Task Force standards, Als and SVF are expected to ensure that controls are proportionate, balanced and in line with the risk-based approach.

The HKMA has undertaken a review of the implementation of PEP-related controls by AIs and SVF licensees:

In general, AIs and SVF licensees understand and apply PEP requirements effectively, and many of them have adjusted their approach to balance risk, proportionality and customer experience.
However, the HKMA has also observed cases where AIs and SVF licensees have applied overly cautious or non-proportionate AML/CFT controls, deviating from the risk-based approach, such as requesting excessive information on source of wealth and interpreting the definition of PEP too broadly.

To provide more practical guidance on the effective implementation of a risk-based approach in AML/CFT controls, the HKMA has developed the Smart Tips on the Treatment of Politically Exposed Persons to provide clarification and additional guidance in the following key areas:

Definition of PEPs;
Family members and close associates of PEPs and entities with PEP risks;
Identification of PEPs, their family members and close associates;
Application of enhanced due diligence measures;
Good practices for handling Hong Kong PEPs; and
Treatment of former PEPs.

AIs and SVF licensees are advised to review the guidance alongside the AMLO, the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism, and other relevant guidance, and to consider adopting the recommended practices to improve their risk-based AML/CFT policies, procedures, and controls. The HKMA will monitor implementation of the guidance as part of its AML/CFT supervision. [21 Nov 2025]

HKMA issues circular regarding the support it will provide on artificial intelligence adoption in AML/CFT

The HKMA has issued a circular to provide an update to authorised institutions (AIs) regarding the support it will provide on the use of artificial intelligence to monitor suspicious activities and other aspects of anti-money laundering and counter financing of terrorism (AML/CFT).

The HKMA notes that 48 AIs have, in response to its letter of 9 September 2024 regarding the use of artificial intelligence to monitor suspicious activities (see our previous update), assessed the feasibility of deploying artificial intelligence to strengthen the effectiveness of transaction monitoring. The vast majority agree with the HKMA on the usefulness of artificial intelligence in making money laundering and terrorist financing (ML/TF) monitoring systems more effective and risk-based.

Some AIs have replaced reliance on rules-based transaction monitoring systems by transitioning to a more holistic approach. Other AIs are implementing artificial intelligence as part of a phased approach, adopting certain use cases as building blocks to make existing processes more effective and efficient. Use cases are largely focused on risk detection and transaction monitoring alert prioritisation.

To support AIs' efforts, the HKMA plans to:

Roll out a series of workshops covering analysis of the different approaches to innovating monitoring systems, as well as use cases involving artificial intelligence in risk detection, alert prioritisation and the use of generative artificial intelligence to compile suspicious transaction reports; and
Organise an additional workshop focused on ML/TF risk management with respect to crypto asset-related services.

These workshops will be accompanied by follow-up support and publications providing advice and recommendations. The first workshop analysing the relative merits of adopting a holistic approach vis-à-vis a building block approach to innovating systems was held on 19 November 2025.

The HKMA will continue to track the progress of adoption and the effectiveness of AIs' transaction monitoring systems. [19 Nov 2025]

HKMA shares key observations and good practices from review on premium financing activities by AIs and lays out expected standards

The HKMA has issued a circular to share with authorised institutions (AIs) key observations and good practices from a recent review, which focused on the practices of AIs and their subsidiaries in handling customers who had entered into premium financing facilities and expressed financial distress.

In addition to AIs with a dual capacity as licensed insurance intermediary and premium financing facility provider, this circular is also applicable to AIs and their subsidiaries that solely provide premium financing facilities.

The circular will apply to new premium financing facilities entered into between AIs and their customers on or after 1 January 2026.

The review found that AIs had generally put in place operational procedures and/or protocols to handle customers who had expressed distress or made complaints, or had indicated that they were unable to repay the interest and/or principal of a premium financing loan. However, there were areas for improvement in several aspects, including providing clearer explanations of the features and operation of premium financing loans, and enhancing the disclosure of potential risks associated with premium financing arrangements.

The HKMA identified some good practices adopted by AIs in assisting customers who had expressed financial distress in respect of the premium financing loans. These include offering alternative solutions to alleviate customers' interest burden and providing grace periods for overdue repayments.

AIs are reminded to take note of the observations from the review and the corresponding expected standards. They are also reminded to exercise due care towards customers, particularly with regard to the increased risks associated with the use of premium financing, and to take prompt remedial action when deficiencies are identified. Details of the observations, expected standards and good practices are set out in the Annex to the circular.

The circular also reminds AIs to act in line with suitability requirements when offering premium financing facilities. [19 Nov 2025]

FSTB and Shenzhen Municipal Financial Regulatory Bureau promulgate 2025-2027 action plan for jointly building Hong Kong-Shenzhen global fintech hub

The FSTB and the Shenzhen Municipal Financial Regulatory Bureau have promulgated the Action Plan for Jointly Building Hong Kong-Shenzhen Global Fintech Hub (2025-2027) (in Chinese), aimed at leveraging the strengths of Shenzhen and Hong Kong in fintech and working together to establish a global fintech centre.

Key initiatives under the action plan include:

Facilitating the establishment of fintech subsidiaries in Hong Kong by Shenzhen financial institutions;
Supporting the two places in jointly developing fintech incubators;
Encouraging Shenzhen technology companies to leverage Hong Kong's facilitation measures to raise funds in Hong Kong, including the Biotech Companies Listing Channel, the Specialist Technology Companies Listing Channel and the Technology Enterprises Channel;
Encouraging Shenzhen companies to issue offshore RMB sustainable bonds in Hong Kong;
Promoting the continued innovation of e-CNY application scenarios; and
Supporting the joint participation by the two places in the research and application of Project mBridge.

In addition, the action plan will promote the cultivation of fintech talent in Hong Kong and Shenzhen and strengthen connections and co-operation with the industry, including facilitating the Shenzhen-Hong Kong-Macau FinTech Professional Programme, encouraging industry associations and financial institutions in Hong Kong and Shenzhen to co-organise fintech events, and enhancing co-ordination of large-scale fintech events across the two places. [19 Nov 2025]

HKMA and DFSA publish report on potential of labelled debt for facilitating sustainable development in emerging markets

The HKMA and the Dubai Financial Services Authority (DFSA) have published a joint research report, titled 'Scaling Sustainable Debt in Emerging Markets', with BloombergNEF as knowledge partner. The report explores the potential for labelled debt to facilitate sustainable development in emerging markets across the Middle East and North Africa (MENA) and Asia Pacific (APAC).

Labelled sustainable debt markets in MENA and emerging APAC have significant growth potential, with many issuers and borrowers currently financing sustainable projects with unlabelled instruments.
Government support to offset labelling costs and provide guidance can help ease challenges faced by issuers when going to the market.
Growth opportunities exist in encouraging greater corporate issuance and expanding beyond green labels and conventional structures.

The report features three case studies on innovative sustainable finance transactions, including a blue bond from DP World, a sustainability-linked loan bond from Emirates NBD, and a long-tenor green bond and loan from MTR Corporation Limited.

The report will be discussed at the DFSA–HKMA Joint Climate Finance Conference in Dubai on 26 November 2025. [18 Nov 2025]

SFC urges licensed firms to detect and prevent potential layering activities in money laundering

The SFC has issued a circular urging licensed corporations and virtual asset trading platforms (collectively known as licensed firms) to stay vigilant against suspicious fund flows showing signs of layering activities in money laundering.

The SFC highlighted a rising trend in which bad actors exploit licensed firms for layering activities, with some attempting to launder illicit proceeds from deception and scam cases by obscuring the source and destination of the illicit proceeds. A common red flag of layering is a series of suspicious activities involving frequent, swift and structured fund deposits in client accounts, followed by immediate withdrawals in the form of funds or virtual assets.

The SFC noted that some licensed firms have failed to detect the apparent red flags. It has therefore conducted a detailed analysis of the potential layering activities to identify the red flags exhibited in the transactions. Most of the red flags identified are already incorporated in the lists of non-exhaustive illustrative indicators of suspicious transactions and activities in the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Corporations and SFC-licensed Virtual Asset Service Providers) (AML/CFT Guideline).

Licensed firms are reminded of their anti-money laundering and counter-financing of terrorism (AML/CFT) obligations and the importance of upholding essential safeguards to detect and prevent layering activities. They must ensure the implementation of robust and effective transaction monitoring systems and processes, and exercise heightened vigilance when processing deposits and withdrawals for their clients, as set out in detail in the circular.

The senior management of licensed firms (including responsible officers, managers-in-charge of overall management oversight and AML/CFT, compliance officers, money laundering reporting officers, and boards of directors) are expected to be vigilant in fulfilling their responsibilities to implement effective AML/CFT policies, procedures and controls that can adequately address and manage the risks identified.

The SFC will not hesitate to exercise its powers under the Securities and Futures Ordinance and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance to take appropriate regulatory actions against licensed firms and their senior management for failing to discharge their AML/CFT obligations.

To address the risks of increasing exploitation of licensed firms, the SFC has stepped up its collaborative efforts with the Hong Kong Police Force (including the Anti-Deception Coordination Centre (ADCC) and the Joint Financial Intelligence Unit) and industry stakeholders. In particular, some licensed firms have agreed to facilitate the ADCC's 24/7 stop payment mechanism to expedite the interception of crime proceeds and recovery of funds since September 2025. Around a third of the known deception and scam-related crime proceeds that flowed to licensed firms have been successfully intercepted so far. [17 Nov 2025]

SFC reprimands and fines licensed corporation HK$900,000 for failing to safeguard client assets

The SFC has reprimanded and fined Tung Tai Securities Company Limited (Tung Tai) HK$900,000 for failures relating to unauthorised sales of client securities and transfers of client funds.

The SFC found that Tung Tai had, in breach of various provisions of the SFC's main code of conduct and guidelines relating to internal control, failed to:

Ensure that client assets were adequately safeguarded; and
Establish effective internal control procedures to protect client assets from theft, fraud and other acts of misappropriation.

Between 6 September 2019 and 18 February 2020, Tung Tai, acting on instructions from a bogus email address similar to that of an overseas client, sold shares in the client's account and transferred the sale proceeds totalling US$3,301,740 to three overseas bank accounts that were not designated by the client.

Apart from the incorrect email address, there were other signs of potential irregularities, including telegraphic transfer rejections by multiple banks, but Tung Tai did not act on these red flags and continued to process the fund transfers.

Tung Tai has since compensated the client, taken remedial measures to enhance order placing and trading execution procedures, and engaged a firm of independent reviewers to review its internal controls in respect of safeguarding of client assets. [13 Nov 2025]

SFC announces enhancements to facilitate client interaction under Cross-boundary Wealth Management Connect

The SFC has announced enhancements to the Cross-boundary Wealth Management Connect Pilot Scheme to foster closer communication between participating licensed corporations (LCs) and their clients under the scheme.

The SFC has set out in a circular the implementation details for the enhancements (following its earlier circular of 24 January 2024 on revisions to implementation arrangements – see our previous update). Among others:

Participating LCs can now obtain one-off written consent (valid for up to one year) from Southbound scheme clients who are not physically present in Hong Kong, enabling the LCs to explain product information based on each client's needs and selected product categories.
Upon the request of Southbound scheme clients, Mainland partner brokers within the same corporate groups as the participating LCs can arrange online three-party dialogues with the participating LCs at their respective places of business, where the participating LCs can explain product information to their clients.
With one-off written consent from Southbound scheme clients, participating LCs can provide their clients with research reports on individual investment products prepared by their partner brokers. The research reports should contain prominent and adequate disclosures of conflicts of interest and warning statements (some illustrative examples of such disclosures are set out in the Appendix to the circular).

The above arrangements also apply to the Northbound scheme.

The circular also reminds LCs to comply with the relevant provisions of the SFC's main code of conduct when providing services under the schemes.

The SFC will continue to work closely with the industry and regulatory authorities to further enhance the scheme and support its growth as a vital initiative for cross-boundary financial connectivity and development in the Greater Bay Area. [13 Nov 2025]

HKMA announces the Ensemble^TX to support real-value transactions in tokenised deposits and digital assets

The HKMA has announced the launch of Ensemble^TX, the commencement of the pilot phase of Project Ensemble. This is one of the initiatives announced as part of Fintech 2030 at the Hong Kong FinTech Week on 3 November 2025 (see our previous update).

Ensemble^TX builds upon the successful outcomes of the Ensemble Sandbox experimentation, which since August 2024 has allowed industry pioneers to test comprehensive end-to-end use cases for settling digital asset transactions using experimental tokenised deposits.

In the new pilot phase, the HKMA, participating banks and other industry pioneers aim to enable faster, more transparent and efficient settlement of real-value tokenised transactions. The initial focus will be on empowering market participants to utilise tokenised deposits in tokenised money market fund transactions, and to manage liquidity and treasury needs in real time.

Ensemble^TX will operate throughout 2026. Interbank settlement of tokenised deposit transactions will initially be facilitated via the HKD Real Time Gross Settlement system. The pilot environment will be progressively upgraded and enhanced to support settlement in tokenised Central Bank Money on a 24/7 basis.

The HKMA and the SFC, a key partner and member of the Ensemble Architecture Community, will continue to collaborate closely to advance the practical applications of tokenisation technology across a diverse set of asset classes, use cases, and sectors within the financial industry. [13 Nov 2025]

HKEX becomes strategic shareholder of CMU OmniClear holdings to accelerate development of Hong Kong's FIC ecosystem

The HKMA and the HKEX have announced that the HKEX will become a strategic shareholder of CMU OmniClear Holdings Limited (CMU OmniClear Holdings), the holding company of CMU OmniClear Limited, by acquiring a 20% stake through the subscription of new shares. Upon completion of the transaction, the HKEX and the Exchange Fund managed by the HKMA will hold 20% and 80% of CMU OmniClear Holdings respectively.

The strategic investment, to be funded by the HKEX's existing corporate funds, follows a memorandum of understanding signed between the HKEX and CMU OmniClear Limited in March 2025 (see our previous update). CMU OmniClear Limited has been established to carry out the operations of the Central Moneymarkets Unit (CMU) on behalf of the HKMA. The investment underscores the HKEX's commitment to cement Hong Kong's position as a leading fixed-income and currencies (FIC) centre and an international RMB hub.

The HKEX and the HKMA will harness their combined resources, technology, talent and market expertise to accelerate the development of Hong Kong's post-trade securities infrastructure into a major central securities depository (CSD) in the region. This will involve the continued commercialisation of CMU and the pursuit of business development initiatives in areas such as expansion of its investor CSD services, asset class coverage and collateral management services, with the goal of enhancing CMU's competitiveness, and the cross-asset class efficiency of CSD platforms in Hong Kong.

The strategic partnership forms part of broader efforts to develop Hong Kong's FIC ecosystem, facilitating future growth areas that include offshore bond repo, over-the-counter clearing, and interest rate derivatives, whilst enabling broader use cases for non-cash collateral, particularly RMB-denominated bonds such as Chinese Government Bonds.

The HKMA remains the owner and system operator of CMU for regulatory purposes. The legal relationships with CMU participants and other system linkages will remain with the HKMA. [12 Nov 2025]

HKMA publishes Guideline on AI-to-AI Information Sharing for the Detection or Prevention of Crime

In September 2025, the Government published a notice in the Gazette to appoint 3 November 2025 as the commencement date of the Banking (Amendment) Ordinance 2025 (see our previous update).

The HKMA has now gazetted its Guideline on AI-to-AI Information Sharing for the Detection or Prevention of Crime. The guideline (Notice no. 7019) can be accessed from the Government Notice page for 7 November 2025 (No. 45, Vol. 29) on the e-Gazette portal.

The guideline provides:

General guidance on the scope of information sharing, circumstances under which information may be shared, the types of information that may be shared, thresholds that must be met, confidentiality and record-keeping requirements, the circumstances under which the safe harbour will apply to protect information sharing, among others;
Practical guidance to assist AIs and their senior management in designing and implementing their own policies, procedures and controls relevant to the information sharing mechanism. [7 Nov 2025]

HKMA renews statement of commitment to FX Global Code

The HKMA has issued its renewed statement of commitment to the FX Global Code.

The FX Global Code is a set of global principles of good practice in the foreign exchange (FX) market, developed to provide a common set of guidelines to promote the integrity and effective functioning of the wholesale FX market. It was developed by a partnership between central banks and market participants from various jurisdictions, including Hong Kong.

The code was first published in May 2017 (see our previous update) and was updated in July 2021 (see our previous update) and December 2024 (see our previous update). The HKMA first issued a statement of commitment in May 2018 and renewed its statement in July 2022 to demonstrate its adherence to the code (see our previous update). [6 Nov 2025]

SFC imposes lifetime ban on former relevant individual of registered institution following conviction for stealing client assets

The SFC has banned Mr Cheung Ngai Yi, a former relevant individual of a registered institution, from re-entering the industry for life following his criminal conviction for stealing client assets. Mr Cheung was sentenced by the District Court on 31 March 2025 to 30 months' imprisonment after he pleaded guilty to theft.

The Court found that Mr Cheung, an account manager for a client of the registered institution at the relevant time, had misappropriated HK$1,530,500 from the client's account via 88 unauthorised ATM withdrawals between 13 May 2016 and 7 February 2017. Mr Cheung had unlawfully retained the client's ATM card and the PIN document, and, without the client's authorisation, sold the client's investment holdings and transferred the proceeds of HK$1,203,182.40 to the client's bank account for his subsequent unauthorised ATM withdrawals.

The SFC is of the view that Mr Cheung had exploited and violated the trust that his client had placed in him for his own personal gain, and therefore lacked the fundamental honesty and integrity expected of regulated individuals in the industry. [5 Nov 2025]

SFC issues guidance in two new circulars to licensed VATP operators to tap global liquidity and diversity offerings

The SFC has published its expected standards for SFC-licensed virtual asset trading platform (VATP) operators in two new circulars, as part of its initiatives under the ASPIRe roadmap to develop Hong Kong as a global virtual asset (VA) hub (see our previous update). The circulars were previewed by Ms Julia Leung (SFC CEO), at a Hong Kong FinTech Week 2025 fireside chat.

In one circular, the SFC sets out its regulatory approach and expected standards for licensed VATP operators to integrate their order books with those of affiliated overseas VATP operators.

Subject to implementing the measures in the circular, orders from different platforms will be permitted to be combined into an aggregate shared liquidity pool, enabling order matching and execution across platforms. VATP operators seeking to operate shared order books should obtain prior written approval from the SFC. The terms and conditions for operating a shared order book will be imposed on the operator's licence.
This is SFC's first step under Pillar A (Access) of the ASPIRe roadmap to attract global platforms, order flows and liquidity providers.
As the next step, the SFC will explore the feasibility of allowing licensed brokers to direct client orders to regulated overseas liquidity pools within the same group before considering whether to expand the arrangement further.

In another circular (with Appendices I, II and III), the SFC broadens the range of products and services that can be offered by SFC-licensed VATPs (advancing Pillar P (Products) of the ASPIRe roadmap), by:

Modifying the requirements on token admission (for example, allowing VATP operators to offer trading in VAs without a 12-month track record for professional investors and for HKMA-licensed stablecoins);
Clarifying current regulatory requirements on VATPs for the distribution of tokenised securities and investment products relating to digital assets; and
Updating the requirements on VATPs providing custody services for their clients' digital assets which may not have been made available for trading via the VATP. [3 Nov 2025]

HKMA unveils Fintech 2030 at Hong Kong FinTech Week 2025

The HKMA's Chief Executive, Mr Eddie Yue, has unveiled Fintech 2030, a forward-looking strategy for driving Hong Kong's fintech development, at the Hong Kong FinTech Week 2025 in a keynote speech. Fintech 2030 will focus on four strategic pillars, collectively known as 'DART', covering a portfolio of over 40 initiatives, including:

Creating Next-generation Data and Payment Infrastructure: The HKMA will develop robust and future-ready infrastructure to support secure, efficient and scalable data sharing as well as bolster cross-border payment connectivity, from unlocking credit and boosting trade finance for enterprises, to enabling more personalised financial services and facilitating easier cross-border remittances for individuals.
A New Holistic 'Artificial Intelligence x Authorised Institutions' Strategy (AI² Strategy): The new strategy will further drive the comprehensive and responsible adoption of AI across the financial sector in Hong Kong and beyond, as well as develop shared, scalable AI infrastructure and finance-specific models in collaboration with industry stakeholders. The HKMA aims to leverage AI to boost accessibility, responsiveness, and customisation in banking services while maintaining transparency and accountability to ensure public trust.
Enhancing Business, Technology and Quantum Resilience: The HKMA is taking proactive steps to strengthen the resilience of the financial sector, including a new fintech-specific cybersecurity certification framework and a new system of early detection through real-time analysis. In shaping the future of quantum finance, the HKMA will drive industry readiness for post-quantum cryptography and build quantum-safe infrastructure for secured financial services.
Tokenisation of Finance: The HKMA will accelerate the tokenisation of real-world assets, including financial assets, and regularise the issuance of tokenised government bonds and exploring the concept of tokenising the Exchange Fund papers. Their settlements on blockchains will be enabled by new forms of digital money, including the e-HKD, tokenised deposits, and regulated stablecoins. The HKMA will soon launch the Project Ensemble pilot to empower real-value transactions and will continue to incubate innovative tokenisation use cases in collaboration with industry stakeholders and other central banks. [3 Nov 2025]

Singapore

MAS and ABS respond on delays in banks processing local fund transfers due to anti-scam measure

MAS and ABS have published their response to concerns about delays in banks' processing of local fund transfers due to anti-scam measures. MAS and ABS acknowledged the concerns, and stated that banks have whitelisted some categories of transactions that are not subject to the measure, such as recurrent GIRO payments and payments to billing organisations. However, expanding the whitelist requires careful consideration to avoid the risk of exploitation by scammers. Banks will continue to refine their measures over time. [27 Nov 2025]

MAS announces completion of equities market review

MAS has announced the completion of the Equities Market Review Group's review and the release of its final report. Key measures, which are aimed at strengthening the competitiveness of Singapore's equities market, include:

establishment of a dual listing bridge connecting the SGX and Nasdaq;
launch of a S$30 million 'Value Unlock' Package to help listed companies unlock shareholder value and deepen engagement;
appointment of the second batch of asset managers under the S$5 billion Equity Market Development Programme (EQDP), with a total of S$2.85 billion placed across six managers; and
trading and market structure enhancements intended to strengthen market making, modernise post-trade custody, and reduce board lot size.

MAS has also published a speech by Chee Hong Tat, Minister for National Development and Deputy Chairman of MAS, detailing these measures. [19 Nov 2025]

MAS and Deutsche Bundesbank sign MoU on tokenisation and cross-border settlement

MAS has announced that it has signed a memorandum of understanding (MoU) with the Deutsche Bundesbank regarding collaboration on cross-border digital asset settlement. Under the MoU, MAS and the Deutsche Bundesbank agree to collaborate on technological and financial innovation by:

fostering the development of new settlement solutions that reduce the costs and processing times of cross-border transfers between Singapore and Germany; and
promoting common standards for cross-border payments, foreign exchange and securities flows involving tokenised assets in order to enhance interoperability between different digital asset platforms. [13 Nov 2025]

MAS, BoE and BoT collaborate on synchronised FX settlement

The BoT has announced its collaboration with the BoE and the MAS to explore the technical and policy implications of settling foreign exchange (FX) transactions using synchronised settlement mechanisms.

The collaboration will test synchronised FX settlement across a diverse technical and institutional landscape. In the first instance, the experiments will leverage simulated versions of participating central banks' real time gross settlement systems and distributed ledger technology -based settlement environments to test:

interoperability between the systems of the participating central banks; and
complex, multilateral use cases involving different types of settlement infrastructure. [13 Nov 2025]

MAS completes live trial for settlement of interbank overnight lending with wholesale CBDC

MAS has announced that it has completed a live trial for settlement of interbank overnight lending transactions using wholesale central bank digital currency (CBDC) on the Singapore Dollar Test Network, an operational shared ledger infrastructure that enables firms to test the settlement of tokenised financial assets using wholesale CBDC. MAS will build on its CBDC settlement pilot by planning a future trial in which tokenised MAS Bills will be issued to Primary Dealers and settled using CBDC. More details of this future trial will be released in 2026. [13 Nov 2025]

MAS consults on AI risk management guidelines

MAS has published for consultation a set of proposed guidelines on AI risk management. The draft guidelines set out MAS' supervisory expectations on oversight of AI risk management in financial institutions, key AI risk management systems, policies and procedures, key AI life cycle controls, as well as capabilities and capacity needed for the use of AI.

The guidelines aim to establish a set of expectations that are generally applicable across the financial sector and may be applied in a proportionate manner, commensurate with the size and nature of financial institutions' activities, use of AI, and their risk profiles. Responses are requested by 31 January 2026. [13 Nov 2025]

MAS speech on achieving open and interoperable networks in digital asset space

MAS has published a speech by its Deputy Managing Director (Markets & Development), Leong Sing Chiong, at the Layer One Summit. Mr Chiong spoke about digital asset initiatives over the past year and noted that progress has been mixed. He outlined two main points for scaling tokenisation in finance: trust is essential, and networks should be trusted, open and interoperable. Mr Chiong additionally emphasised the need for seamless networks and sound infrastructure within the digital financial ecosystem, and highlighted a number of MAS initiatives aimed at supporting those goals. [12 Nov 2025]

MAS: Response to PQ on anti-scam measures by banks in 'whitelist' situations

MAS has published the response to a PQ on anti-scam measures by banks in prescribed 'whitelist' situations. MAS replied that it has worked with banks on additional safeguards such as a recent measure where, for accounts with at least $50,000 balance that are being rapidly drained of funds, banks will delay the processing of further transfers to allow consumers time to re-consider if the transaction is indeed legitimate. MAS further noted that it is mindful not to unduly impede legitimate transactions, and there are whitelisted transactions that are not subject to this measure. [4 Nov 2025]

MAS: Response to PQs on unlicensed financial advice provided by content creators

MAS has published the response to PQs on how MAS ensures that past materials left accessible online no longer carry the risk of misleading consumers of financial products, and what interim enforcement actions will MAS conduct before the guidelines on responsible online financial content come into effect in March 2026. MAS replied that it has recently published two sets of guidelines: one for content creators and another for financial institutions when they conduct digital advertising activities. These are in addition to existing guidelines published in 2019, which provide examples of activities that would constitute provision of financial advice. [4 Nov 2025]

Malaysia

BNM revises policy document on RMiT

The BNM has revised the policy document on risk management in technology. It aims to strengthen financial institutions' management of technology and cyber risks, improve service availability and resilience of financial services, and maintain public trust in the security of the financial system.

The policy document has been updated to include the following:

expand the applicability to include non-bank merchant acquirer and intermediary remittance institution with more than 5% market share of transaction value or volume;
enhance financial institutions' resilience to service disruptions, including the adoption of a customer-centric approach to managing intermittent issues;
heighten cyber security controls and practices in line with global standards and best practice;
strengthen the security of digital services through stronger fraud detection, proactive monitoring and customer empowerment; and
facilitate the secure adoption of new or advanced technology.

The policy document is effective 28 November 2025 except where otherwise specified in the text. [28 Nov 2025]

BNM revises policy document on RMiT

The policy document has been updated to include the following:

expand the applicability to include non-bank merchant acquirer and intermediary remittance institution with more than 5% market share of transaction value or volume;
enhance financial institutions' resilience to service disruptions, including the adoption of a customer-centric approach to managing intermittent issues;
heighten cyber security controls and practices in line with global standards and best practice;
strengthen the security of digital services through stronger fraud detection, proactive monitoring and customer empowerment; and
facilitate the secure adoption of new or advanced technology.

The policy document is effective 28 November 2025 except where otherwise specified in the text. [28 Nov 2025]

SCM: Capital Markets Malaysia publishes Sustainable Batik Disclosure Guide

The SCM has announced Capital Markets Malaysia's release of the Sustainable Batik Disclosure Guide (SBDG). This practical tool seeks to help batik artisans, entrepreneurs and producers to easily disclose their ESG data and practices. The SBDG comprises 34 priority ESG disclosures, aligned with key local and international sustainability standards. It is structured across 'Basic', 'Intermediate', and 'Advanced' levels to support artisans and entrepreneurs at different stages of sustainability and maturity. [7 Nov 2025]

BNM publishes policy on management of customer information and permitted disclosures

BNM has published a policy document introducing new requirements for financial service providers including:

notifying BNM to include a customer information breach that cause or likely to cause significant harm to customers or if the customer information breach involves or likely to involve a large number of customers; and
notifying the affected customers of a customer information breach that causes or likely to cause significant harm to the customers.

The effective date of the new requirements is 31 October 2025. [31 Oct 2025]

Thailand

SECT proposes amendments to mutual fund fee regulations

The SECT has proposed amendments to the regulations related to calculation and disclosure of mutual fund fees.

Feedback is requested by 21 December 2025. [21 Nov 2025]

MAS, BoE and BoT collaborate on synchronised FX settlement

MAS has announced its collaboration with the BoE and the BoT to explore the technical and policy implications of settling foreign exchange (FX) transactions using synchronised settlement mechanisms.

interoperability between the systems of the participating central banks; and
complex, multilateral use cases involving different types of settlement infrastructure. [13 Nov 2025]

SECT changes knowledge and suitability tests

The SECT has announced the amendment regulations for contacting and providing services to investors by initial coin offering (ICO) portals, mandating that ICO portals perform a suitability test, that is, assess investors' suitability for digital token investments, at least once every two years. [4 Nov 2025]

India

SEBI: Reclassification of REITs as equity related instruments for facilitating enhanced participation by mutual funds and SIFs

SEBI has issued a circular regarding the reclassification of real estate investment trusts (REITs) as equity related instruments in order to facilitate enhanced participation by mutual funds and specialized investment funds (SIFs).

With effect from 1 January 2026, any investment made by mutual funds and SIFs in REITs shall be considered as investment in equity related instruments.

Existing investment in REITs held by debt schemes of mutual funds and investment strategies of SIFs as on 31 December 2025, shall be grandfathered.

In terms of para 2.7 of the Master Circular for Mutual Funds dated 27 June 2024, Association of Mutual Funds in India (AMFI) shall include REITs in the list of classification of scrips as per their market capitalization.

Asset Management Companies (AMCs) shall issue an addendum to make necessary changes in the scheme documents and the same shall not be considered as fundamental attribute change for the scheme.

Any inclusion of REITs in the equity indices shall be carried out only after a period of six months i.e., 1 July 2026. [28 Nov 2025]

IFSCA consults on Master Circular for broker dealers and clearing members

IFSCA has released a CP on the draft Master Circular for broker dealers and clearing members which would supersede all the circulars and guidelines issued by SEBI and IFSCA with respect to broker dealers and clearing members.

Comments are requested by 20 December 2025. [29 Nov 2025]

SEBI announces additional incentive to distributors for onboarding new individual investors from B-30 cities and women investors

SEBI has published a circular regarding the incentives for mutual fund distributors when onboarding new individual investors from B-30 cities, at mutual fund industry level; and new women individual investors from both Top 30 and B-30 cities. [27 Nov 2025]

IFSCA: Disclosure requirement under framework for global access in the IFSC

IFSCA has published a circular regarding disclosure requirements under Clause 39 of the circular, Regulatory Framework for Global Ascess in the IFSC. The circular sets out the key risks and disclaimers which must be displayed to clients at every login. [26 Nov 2025]

SEBI publishes circulars regarding activities of debenture trustees outside of the purview of SEBI

SEBI has published a circular specifying the conditions for debenture trustees to undertake activities that are not regulated by SEBI. The conditions, among others, include:

they shall undertake such activities that are not regulated by SEBI only at arms' length basis through one or more separate business unit (SBU), segregated by an ethical wall and ring-fenced from the SEBI-regulated activities;
they shall prepare and maintain separate records in the SBU for the non-SEBI activities;
other resources, including IT infrastructure may be shared between SEBI-regulated and non-SEBI activities subject to due procedures approved by the board of directors of the debenture trustees; and
they shall ensure that advertising or marketing material and webpages displaying information pertaining to non-SEBI activities shall be separate and distinct from SEBI-regulated activities.

The provisions of this circular shall come into force immediately.

SEBI has also published a circular specifying modification to Chapter IV of the debenture trustees Master Circular. The provisions of this circular come into effect immediately.

A circular on the timeline for submission of information by the issuer to the debenture trustees was also published by SEBI. The provisions of this circular shall come into effect from quarter ended 31 December 2025. [25 Nov 2025]

SEBI extends mutual funds review consultation deadline

SEBI has announced an extended deadline for its 'Comprehensive review of SEBI (Mutual Funds) Regulations, 1996' consultation. Responses are now due by 24 November 2025. [19 Nov 2025]

IFSCA consultation: Regulatory framework for implementation services by investment advisers

IFSCA has published for consultation a draft framework for providing implementation services by investment advisers registered with IFSCA. Comments on the consultation are requested by 3 December 2025. [13 Nov 2025]

IFSCA consults on pension fund regulations

The IFSCA has published a CP on the proposed IFSCA (Pension Fund) Regulations, 2025. The proposals cover:

voluntary participation of subscribers in pension scheme;
flexibility to determine the frequency and amount of contributions; and
offering a variety of investment options.

Feedback is requested by 25 November 2025. [4 Nov 2025]

IFSCA consults on amendments to regulations to capital market intermediaries

The IFSCA has published a CP on the proposed amendments to the IFSCA (Capital Market Intermediaries) Regulations, 2025. The proposed amendments aim to enhance the ease of doing business for capital market intermediaries in the IFSC.

Comments are requested by 24 November 2025. [3 Nov 2025]

IFSCA amends anti money laundering, counter-terrorist financing and know your customer guidelines

IFSCA has released modifications under the IFSCA (Anti Money Laundering, Counter-Terrorist Financing and Know Your Customer) Guidelines, 2022. [31 Oct 2025]

Philippines

SECP requests comments on proposed guidelines on the issuance and disclosure of sukuk

SECP has published a notice requesting for comments on the second exposure draft of the SECP proposed guidelines on the issuance and disclosure of sukuk.

Responses are requested by 12 December 2025. [26 Nov 2025]

BSP: Customers allowed to access large-value funds

BSP has reiterated that customers can withdraw amounts above P500,000.00, or its equivalent amount in foreign currency and do so without unnecessary delays. Under BSP Circular No. 1218, Series of 2025, withdrawals using traceable means or non-cash channels do not require additional documentary requirements. In case the customer needs to withdraw more than P500,000.00 in cash, the customer only needs to present documents showing the legitimate purpose of the withdrawal. The submission and review of said proof, nevertheless, should be straightforward and not unduly delay customers' access to their funds as these are already part of the BSP-supervised financial institutions' existing customer due diligence or know-your-customer process. [24 Nov 2025]

SECP consults on amendments to REIT regulations

SECP has published a consultation on proposed amendments to the rules governing real estate investment trusts (REITs).

The draft amendments seek to broaden the list of income-generating real estate assets that may comprise a REIT's portfolio, provide flexibility for the REIT sponsor in reinvesting proceeds from the listing of the REIT, and relax the minimum public ownership requirement. Responses to the consultation are requested by 3 December 2025. [20 Nov 2025]

Taiwan

FSC: Taskforce confirms technical feasibility validation of real world asset tokenisation

The FSC has announced that its taskforce has completed its final (validation) reports, confirming the technical feasibility validation of real world tokenisation. The FSC has also outlined its next steps in respect of regulatory adaptation and the establishment of an real world asset token trading platform. [17 Nov 2025]

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APAC Monthly Private Wealth Legal Developments – November 2025

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