APAC Monthly Private Wealth Legal Developments – October 2025

Australia

APRA to consult on targeted changes to CPS 230 for non-traditional service providers

The APRA has announced that it will consult on targeted amendments to CPS 230 Operational Risk management by the end of 2025. This follows industry feedback highlighting challenges when applying new standard's contractual obligations to arrangements with non-traditional service providers (NTSPs).

NTSPs are providers that are typically market-mandated, such as stock exchanges, payment schemes or clearing and settlement facilities. Arrangements with these providers often lack formal contracts or rely on standardised, non-negotiable terms.

The proposed amendments will clarify APRA's expectations for arrangements with NTSPs, particularly around contract uplift and service level monitoring. The changes aim to streamline processes for regulated entities and alleviate regulatory burden, while ensuring a practical prudential framework that enhances resilience across the financial system. All other risk obligations under CPS 230 will remain unchanged. [31 Oct 2025]

ASIC provides further guidance on digital asset innovation

The ASIC has published additional guidance regarding the application of presently existing financial services laws to digital assets. In particular, ASIC has confirmed that stablecoins, wrapped tokens, tokenised securities and digital asset wallets are among the digital asset products that it considers falling within the ambit of 'financial products'. As explained by ASIC Commissioner Alan Kirkland, it is hoped that this updated guidance 'provides the regulatory clarity that firms have been calling for'.

Kirkland further explained that the character of digital assets as financial products would be maintained under the Government's proposed law reform, meaning that almost all digital asset providers will require a financial services licence to ensure proper consumer protection. However, in an attempt to allow firms to consider and implement this guidance, ASIC has announced it will enforce a sector-wide no-action policy until 30 June 2026.

In the same press release, ASIC announced a proposal for new regulatory relief measures to support innovation in digital assets. These measures include class relief for distributors of eligible stablecoins and wrapped tokens, as well as amendments to custody standards to allow omnibus account structures under specified conditions. ASIC is inviting feedback on the proposal until 12 November 2025.

ASIC's position regarding both the no-action position and the proposed regulatory relief was partly informed by its consultation paper in December 2024 (CP 381), a summary of which was posted alongside the aforementioned guidance. [29 Oct 2025]

APRA refines proposed changes to the capital framework of longevity products

APRA has announced the commencement of a second round of consultation regarding proposed changes to the capital framework for longevity products, such as annuities. APRA explains that the changes are 'designed to create an environment that supports the development and availability of longevity products for Australian retirees, while safeguarding policyholder interests'.

This latest round of discussions follows from preliminary consultations in June 2025, where APRA invited community feedback on proposed alterations to the life insurance capital framework. The responses, which were synthesised and incorporated into the updated proposal, demonstrated a desire for a more principles-based approach for determining capital requirements.

Feedback on the updated draft prudential standards is requested by 17 December 2025. [29 Oct 2025]

Treasury invites feedback on draft regulations for payment systems modernisation

The Treasury has announced it is inviting feedback on the Payment Systems Legislation Amendment (2025 Measures No. 1) Regulations 2025 (Cth) and the supporting Explanatory Statement until 11 November 2025. The regulations support the recently passed Treasury Laws Amendment (Payments System Modernisation) Act 2025 (Cth) and, if implemented, will amend sections in the Payments Systems (Regulation) Regulations 2006 (PSRR), the Australian Securities and Investments Commission Regulations 2001 (Cth) (ASIC Regulations) and the Corporations Regulations 2001 (Cth).

The key amendments are as follows:

• ASIC, APRA, ACCC, and AUSTRAC are now designated 'special regulators' under the PSRR. The regulations define the heads of these regulators and their eligible delegates who are authorised to exercise powers under the PSRR. Specified 'prescribed persons' within these special regulators may use or disclose information obtained under the Payment Systems (Regulation) Act 1998 (Cth) to either the RBA or another special regulator. Additionally, the regulations provide civil liability protections for 'prescribed persons' acting in good faith while performing functions or exercising powers under the Act.
• A regulation specifically outlining payment systems that are not financial products (such as Mastercard, VISA, EFTPOS etc...) will be inserted into the ASIC Regulations. A similar provision will be inserted into the Corporations Regulations 2001 (Cth). [29 Oct 2025]

APRA member speaks to Financial Services and ASX Sector Assurance Forum

In a speech to the Financial Services and ASX Sector Assurance Forum 2025, APRA Member Suzanne Smith outlined the regulator's evolving attitudes towards growing technological risks within the financial services' sector.

Smith outlined the following concepts as of particular importance to proper risk management:

• Given the exponential rise in digital banking, online superannuation management and digital insurance platforms, cybersecurity is expected to be audited regularly and will be treated as a concern for the whole company, rather than being characterised simply as an IT issue.
• APRA-regulated entities must inform the Authority in the event of any cyber-incident, whether it pertains simply to an accidental data disclosure or an actual compromise of cybersecurity systems.
• Many banks, insurers and superannuation trustees should be looking to update or replace their technology management capabilities, with many entities relying 'heavily on legacy systems, which are often built on now outdated software and hardware [and are] typically less resilient to cyber threats'. Smith added that there are economic benefits to this proactive approach, as the 'delaying the replacement of technology assets, for example, often comes with hidden costs which eventually need to be paid'.
• APRA is closely monitoring concentration risk, warning that reliance on a small number of critical technology providers, such as cloud, SaaS, PaaS, and IaaS vendors, could pose systemic threats if any were to fail.
• APRA expects entities to implement strong data governance, privacy protections, and AI oversight, with internal audit protocols aimed at ensuring that entities are adapting to emerging technologies to ensure compliance with prudential standards. [28 Oct 2025]

AUSTRAC releases guidance for current and new AML/CFT reporting entities

AUSTRAC has releasedguidance for existing and incoming reporting entities in preparation for the new anti-money laundering and countering the financing of terrorism (AML/CFT) regime. The changes apply to current reporting entities from 31 March 2026 and the regime will expand to include real estate agents and property developers, accountants, lawyers and others from 1 July 2026. The guidance addresses:

• incoming reporting businesses' new obligations and implementation of those obligations;
• changes to existing reporting entities' obligations;
• how reporting entities can practically implement obligations in a cost-effective and appropriately scaled manner; and
• risk insights and indicators for newly regulated sectors and further insights for the digital currency exchange sector.

AUSTRAC will release further resources prior to the new regime's commencement. [17 Oct 2025]

Treasury – Regulatory Initiatives Grid

The Treasury has published its Regulatory Initiatives Grid Edition 2 which outlines publicly known (as at 26 September 2025) regulatory reform priorities and initiatives affecting the financial sector. The report is available PDF, Word and Excel, as well as an accompanying interactive dashboard with updated features to view new initiatives. [17 Oct 2025]

Federal Court dismisses ASIC's conflicted remuneration law contravention claims

The Federal Court of Australia delivered its judgment dismissing ASIC's claims that a director and a consultant for Freedom Group companies were involved in Freedom's licensed entity facilitating its representatives' acceptance of conflicted remuneration.

The allegations related to incentive programs for sales agents who sold an insurance product offered by Freedom. ASIC alleged the use of the incentive program prioritised sales to the detriment of consumers. Justice Goodman rejected the claims on the basis that ASIC failed to establish that the incentives were conflicted remuneration, as whether or not sales agents provided financial advice was not proven. [16 Oct 2025]

APRA Deputy Chair Margaret Cole addresses the FSC Innovation in Retirement conference

Deputy Chair of APRA, Margaret Coke spoke at the FSC Innovation in Retirement conference regarding APRA's priorities for superannuation. The key points from her speech were:

• APRA will publish findings this year from its inaugural stress test of the financial system, which considers financial stability risks resulting from the increased interconnectedness of banking and superannuation.
• The number of fund members in or nearing retirement is increasing; APRA is concerned by the lack of progress in tracking and measuring the success of retirement income strategies pursuant to the Retirement Income Covenant. Findings of this year's pulse check will be released next month.
• Given the number of members near the retirement phase, APRA encourages funds to meet the demand for accessible information on products, services and choices to members nearing or at retirement. Aiming to facilitate product innovation, APRA is progressing reforms to support life insurers to provide more accessible annuity products. APRA will commence a further consultation on reforms shortly and aims to finalise the proposed changes in the first half of next year.
• The impending increase in members entering retirement requires superannuation trustees to manage the associated cyber, investment, liquidity and other risks. To combat rising cyber risks and other, APRA is focusing on regulated entities implementing information controls and APRA's operational risk management standard CPS 230. Additionally, it was noted that 'increased overseas deployment heightens, among other things, currency risk and increased investment in unlisted assets raises questions about the management of liquidity risk and fair valuation'.
• To further transparency, APRA will publish fund-level data on retirement product performance as part of its Comprehensive Product Performance Package from the second half of 2025-26; it is currently working with the Treasury on a new framework for reporting on retirement outcomes to commence in 2027.
• Getting the Balance Right, a new strategic objective in APRA's Corporate Plan which focuses on balancing 'financial safety and stability objectives with competition and efficiency considerations' includes initiatives to introduce further proportionality, remove redundant or duplicative rules, and strengthen data sharing with other agencies. [16 Oct 2025]

ASIC Commissioner Alan Kirkland: Improving consumer outcomes is everyone's job

ASIC Commissioner Alan Kirkland gave an address at the Institute of Managed Account Professionals Independent Thought Conference. Mr Kirkland highlighted that:

• by the end of 2025, ASIC will publish updated guidance (Regulatory Guidance 181) for Australian Financial Services licensees on management of conflicts of interests which will clarify the law's application, set out the types of conflicts which should be identified and managed, and explain arrangements for effectively managing conflicts;
• ASIC plans to focus on licensees and advisers involved in providing managed accounts to retail clients, examining compliance with general obligations, including best interests obligations and management of conflicts of interest; and
• ASIC encourages licensees and advisers to report bad actors to further the protection of consumers and preservation of the industry's reputation. [16 Oct 2025]

AUSTRAC: Powers proposed to tackle high risk products services and channels

Minister for Home Affairs, Tony Burke, has proposed a power for the AUSTRAC CEO to restrict or prohibit high-risk products, services or delivery channels. This proposal is made amidst increasing money laundering and scam risks associated with crypto ATMs. [16 Oct 2025]

ASIC sends message to super trustees in relation to retirement communications

ASIC has published its report on communications to members by superannuation trustees: Report 818 From superficial to super engaged: Better practices for trustee retirement communications. The report sets out ASIC's findings from its review of trustees' implementation of the Retirement Income Covenant. ASIC's found that some trustees' communications to members are 'one-size fits all', including with respect to different phases of retirement and diversity of members. For example, ASIC identified that communications may not account for needs of First Nations, vulnerable, or cultural and linguistically diverse members.

ASIC is calling on trustees to:

• focus on developing communications tailored for members in or approaching retirement, with respect to member groups, diverse needs, member preferences, and accessibility for culturally and linguistically diverse members and members with disability;
• ensure governance structures for retirement income and communications strategy are sufficiently resourced and appropriately managed; and
• improve oversight of external service providers involved in developing and delivering communications.

ASIC and APRA will work together to ensure compliance with Covenant obligations. [14 Oct 2025]

ASIC reviews responsible entities' use of offshore service providers

The ASIC has published a review of responsible entities using offshore service providers when providing managed investment schemes. ASIC reviewed entities responsible for 392 funds with $191,364 million of assets under management. Responsible entities can outsource functions, including investment management, custody, fund administration and transaction processing services, however, they will remain responsible for complying with their obligations. When outsourcing responsible entities must:

• have measures in place to ensure that due skill and care are taken in choosing suitable service providers;
• monitor the ongoing performance of service provider; and
• appropriately deal with any actions by service providers that breach service level agreements or their general obligations.

Responsible entities are primarily outsourcing management and oversight of the investment process and administration of the fund's portfolio, custody, fund administration and transaction processing services. ASIC found significant variation in the sophistication of the risk management systems with larger responsible entities typically having more sophisticated risk management processes.

An area of concern was control over data where offshore service providers reside in foreign jurisdictions subject to foreign government laws which conflict with Australian data protection laws. Those responsible entities regulated by the APRA had more sophisticated cyber and security management arrangements with their offshore service providers.

Responsible entities who outsource to offshore service providers should consider:

• their due diligence when engaging the services of an offshore service provider;
• their oversight obligations in relation to their use of offshore service providers;
• ensuring offshore service providers adhere to their cyber policy standards and those standards required of Australian-based third-party service providers; and
• ensuring an adequate risk management framework is in place for ongoing assessment and monitoring of the risks of offshore service providers. [10 Oct 2025]

ASIC publishes Annual Report 2024-25

ASIC has published their Annual Report 2024-25. In the last year, ASIC ramped up its enforcement activity with ASIC Chair Joe Longo stating it has delivered 'a 50% increase in investigations, an almost 20% increase in new civil enforcement proceedings and the completion of 829 targeted surveillances'. ASIC reported that its increased enforcement activity has resulted in $104.1 million in court-ordered penalties.

A focus of ASIC's enforcement operations has been the superannuation sector where it reports 'a significant increase in unscrupulous business models'. In this sector, ASIC has specifically addressed superannuation platforms handling of death benefits claims and engaged in court-based enforcement actions against Cbus and AustralianSuper.

Additionally, ASIC has commenced a program of regulatory simplification work. To execute this program, ASIC launched the ASIC Simplification Consultative Group which will 'simplify the way regulation is managed by ASIC and how people can interact with us, as well as highlighting areas we see as being ripe for review and reform'. An example of ASIC's simplification program is its response to the declining number of Australian initial public offerings (IPOs) by implementing a shorter IPO timetable as part of a two-year trial. [8 Oct 2025]

APRA calls for stronger action by platform trustees

APRA has called for 'superannuation trustees to accelerate and escalate efforts to safeguard members' investments held in platform products'. This follows APRA's thematic review of superannuation platforms which are collectively responsible for almost 95% of superannuation platform assets. APRA has summarised the review's findings in a letter which calls on superannuation platform trustees to:

• lift standards relating to onboarding, ongoing monitoring and promoting member outcomes;
• confirm their Financial Accountability Regime accountabilities;
• consider whether they have breached the prudential standards and obligations; and
• determine a time-bound action plan to lift standards.

APRA's letter follows the collapse of Shield and First Guardian managed investments schemes with APRA Deputy Chair Margaret Cole stating '[the] fact that First Guardian and Shield managed investment schemes were made available to members by some platform trustees has exposed members to the risk of significant loss and uncertainty'. [7 Oct 2025]

APRA releases Annual Report 2024-25

The APRA has released its Annual Report 2024-25. In response to increased market volatility in the previous year, APRA noted a growing interest in the interconnection between the superannuation and banking sectors and their resilience to a system-wide shock. As such, APRA states it has continued to 'sharpen its supervisory focus and strengthen the prudential settings to ensure banks, superannuation funds and insurers remained stable and resilient'.

In the banking sector, APRA has sought to 'address system risks exposed during the 2023 global banking crisis' by phasing out Additional Tier 1 capital from the bank prudential framework from January 2027, after Additional Tier 1 capital 'failed to fulfil its intended role as going concern capital when several US and European banks either failed or required rescue.'.

In the superannuation sector, APRA remained focused on improving outcomes for fund members by holding superannuation trustees accountable through:

• increasing transparency of product underperformance via annual performance tests and the inaugural release of a comprehensive product performance package containing performance metrics and insights;
• increasing scrutiny of superannuation fund expenditure to ensure it was spent in the best financial interests of fund members; and
• identifying gaps in trustee compliance within APRA requirements.

Additionally, industry feedback raised concerns that APRA's regulatory changes did not sufficiently consider the costs imposed. APRA noted it seeks to get the balance right between financial safety and burdensome regulation. It has internally reviewed its systems to increase the efficiency of lodging data submissions. However, APRA states it 'has no appetite to ease regulatory requirements where it would pose unacceptable risk to the financial system'. [2 Oct 2025]

Hong Kong

HKMA publishes practical insights report on first cohort of GenAI Sandbox and co-hosts GenAI Symposium to share sandbox outcomes

The HKMA has published a report that summarises the practical insights gained from the first cohort of the GenAI Sandbox.

The GenAI Sandbox provides a risk-controlled environment for banks, supported with targeted supervisory feedback and technical guidance, to develop and test GenAI solutions across three critical domains: risk management, anti-fraud measures, and customer experience.

In the first cohort which was launched in December 2024 (see our previous update), participating banks explored a diverse range of use cases, demonstrating GenAI's potential in areas such as intelligent chatbots, advanced document processing and analysis, and multimodal content generation. These fundamental building blocks underscore GenAI's capacity to streamline operations, enhance customer engagement, and drive product innovation in an enterprise scale.

• Drawing on practical learnings from the technical trials, the report provides guidance to help banks address key challenges throughout the AI implementation lifecycle, including data preparation, model fine-tuning, output evaluation, and ongoing monitoring and optimisation.
• In addition, the participating banks proactively explored methods to address common adoption challenges, such as those relating to hallucination and inaccuracy, bias and fairness, security and privacy, and explainability and transparency.

These findings demonstrate GenAI's potential to add value in banking, particularly in enhancing risk management, anti-fraud capabilities and customer experience. The HKMA encourages authorised institutions to review the report and leverage the insights on how to innovate with AI responsibly. The second cohort (launched in October 2025 – see our previous update) is underway and will continue to explore innovative use cases while deepening investigation into the 'AI vs AI' paradigm, leveraging AI technology itself to better manage risks arising from AI adoption.

The report was presented at the GenAI Symposium co-hosted by the HKMA and Cyberport, which attracted over 500 practitioners from the banking, insurance and technology sectors. The HKMA unveiled a pilot GenAI chatbot to provide users with more interactive access to insights and practical guidance from the sandbox. The chatbot explores the feasibility of deploying a knowledge-bound GenAI solution that addresses common concerns such as hallucinations and inaccuracies. [31 Oct 2025]

SEHK provides updates on Northbound Program Trading Reporting under Stock Connect

Following its circular of 3 April 2025 regarding the announcement on the Shanghai Stock Exchange (SSE) and Shenzhen Stock Exchange (SZSE) Program Trading Management Measures (see our previous update), its circular of 11 July 2025 regarding the publication of Northbound Program Trading Reporting Guidelines by the SSE and the SZSE (see our previous update), and its circular of 17 October 2025 regarding the updates on Northbound Program Trading Reporting under Stock Connect (see our previous update), the Stock Exchange of Hong Kong Limited (SEHK) has issued a further circular to provide additional information to China Connect exchange participants (CCEPs) and trade-through exchange participants (TTEPs):

• High frequency trading (HFT) exemption checklist – Under the Northbound Program Trading Reporting regime, a Northbound program trading investor whose trading activities meet the criteria for HFT is required to submit additional HFT-related information as part of its reporting obligations. However, an exemption from such requirement may be available where the HFT investor satisfies certain conditions. The SEHK has published an HFT Exemption Checklist (available in the dedicated Northbound Program Trading Reporting section of the HKEX Stock Connect webpage) to facilitate the exemption application process.
• Updated technical document – The updated File Interface Specification on Northbound Program Trading Reporting has been posted under the dedicated Northbound Program Trading Reporting section of the HKEX Stock Connect webpage. CCEPs and TTEPs are reminded to note the technical specification of the supporting documents. [31 Oct 2025]

SEHK introduces additional day-end trade files with supplementary information for Hong Kong securities market and Northbound trading under Stock Connect

The SEHK has issued a circular to introduce additional day-end trade files to facilitate trade reconciliation for the Hong Kong securities market and Northbound Trading under Stock Connect. The additional trade files contain supplementary information (ie, Client Order ID, Order ID and Comp ID) and are available on the Electronic Communication Platform for download.

Exchange participants, CCEPs and trade-through exchange participants are requested to note the updated data export specifications for trade files on the respective HKEX webpages for the Hong Kong securities market and Northbound Trading under Stock Connect.

The circular also noted that optional practice sessions were scheduled for CCEPs (Northbound Trading under Stock Connect) and for exchange participants (Hong Kong securities market) on 8 November and 15 November 2025 respectively to assist them in familiarising themselves with the additional day-end trade files. [31 Oct 2025]

HKMA executive director discusses supervisory technology and initiatives for supporting innovation while protecting consumers

In his keynote speech at a 'Risk & Compliance Re-imagined' Seminar, Mr Alan Au, the HKMA's Executive Director (Banking Conduct), discussed the technology used by the HKMA for surveillance.

The HKMA has been utilising various technologies, including robotic process automation, speech transcription and agentic AI to enhance the efficiency and effectiveness of conduct supervision by freeing up its staff from administrative and repetitive tasks, so that its staff can devote more time and effort to complex tasks and supervisory analysis. For example:

• The HKMA has employed a workflow system powered by agentic AI and web-scraping technologies to detect and monitor misleading marketing claims, including the misuse of terms like 'bank' or 'deposit', to protect the public against misleading advertisements or deceptive practices in the market.
• The HKMA has also introduced a speech-to-text system to analyse audio recordings between banks and their customers. Leveraging the system to transcribe and analyse audio recordings, this system facilitates identification of potential compliance issues, such as inadequate product disclosure for the HKMA's further review, enhancing the efficiency of its supervision work. The HKMA's sampling capacity has increased notably as a result.

Mr Au also highlighted the initiatives the HKMA has introduced in recent years to reimagine and adapt its supervisory approach to conducting supervision and consumer protection in the digital age. The areas he covered included online wealth management, responsible use of AI, and anti-scam initiatives. Mr Au noted the need to find the right balance between supporting innovation and protecting consumers, given that technology is a double-edged sword. [30 Oct 2025]

HKMA publishes e-HKD Pilot Programme Phase 2 Report and outlines future direction for e-HKD, prioritising wholesale uses and continuing work on extension to retail uses

The HKMA has published the 'e-HKD Pilot Programme Phase 2 Report', presenting key findings and learnings from 11 industry pilots and setting out its latest policy stance on the e-HKD. Details of each pilot can be found in the factsheets and supplementary reports prepared by the pilot participants, accessible via the links in Appendix A of the report.

Since 2017, the HKMA has been exploring the potential of a central bank digital currency for Hong Kong, with Phase 2 of the pilot programme evaluating the commercial viability and scalability of an e-HKD in various retail scenarios, as well as comparing it with tokenised deposits (see our previous update).

The pilots under Phase 2 explored innovative use cases across three main themes, namely, settlement of tokenised assets, programmability, and offline payments. The results have demonstrated that both e-HKD and tokenised deposits can enable cost-efficient, programmable, and resilient transactions. In particular, the public perception of e-HKD and tokenised deposits was found to be similar, reflecting the public's high trust in Hong Kong's stable banking system. Commercial banks showed a slight preference for tokenised deposits over an e-HKD, citing potential benefits such as lower cost of capital, flexibility in design, and strong customer stickiness.

In light of the findings, the HKMA has concluded that the immediate priority for the e-HKD lies in areas beyond retail use cases, and will prioritise the e-HKD work in wholesale payments (which has already been implemented in some applications), to support the development of the tokenisation ecosystem and cross-border payments, such as settlements of international trade.

In the meantime, the HKMA will maximise Hong Kong's readiness to extend the use of the e-HKD to retail scenarios by laying the policy, legal, and technical groundwork by the first half of 2026, taking into account the design considerations outlined in the report. The HKMA will regularly review the decision to proceed with such an extension, subject to various factors such as market demand, international developments, and evolvement of technologies.

As part of the e-HKD Industry Forum's work, the HKMA will publish a set of common token standards to facilitate the scaled adoption of programmability in digital money. These standards are intended to provide a foundation for the potential future development and adoption of an e-HKD aimed at serving the needs of individuals and corporates in Hong Kong. [28 Oct 2025]

HKMA issues consolidated guidance on registration for RAs under SFO and controls to ensure staff fitness and properness

The HKMA has issued a circular to provide consolidated and updated guidance on registration and related matters in respect of regulated activities (RAs) under the Securities and Futures Ordinance (SFO), and certain controls to ensure the fitness and properness of staff at authorised institutions (AIs).

This guidance has been issued as the certain prior guidance issued by the HKMA have become obsolete. It does not introduce any new regulatory standards.

• The operational and procedural details on registration as a registered institution (RI), application to become an executive officer (EO), and online submission and maintenance of the HKMA register are set out in Annex 1 to the circular.
• Guidance on controls to ensure that relevant individuals, including EOs, relevant individuals under temporary engagement, and itinerant professionals, are and remain fit and proper, as well as compliance with the prohibition of unregistered dealing and disciplinary actions, is set out in Annex 2 to the circular.
• Several reminders regarding the Mandatory Reference Checking Scheme are included in the body of the circular.
• AIs are required to put in place adequate policies and procedures, internal controls, and staff training to ensure compliance with all applicable requirements. Key examples of the applicable guidelines are listed in Annex 3 to the circular.
• AIs are required to ensure the fitness and properness of their employees generally (in addition to EOs and relevant individuals). The HKMA reminds AIs of the need to (among other things) perform comprehensive due diligence on potential employees regarding their history of terminated employments and criminal convictions. Further details are set out in Annex 4 to the circular.
• The previous HKMA circulars superseded by this circular are listed in Annex 5 to the circular. [27 Oct 2025]

SFC suspends former licensed representative for seven months for regulatory breaches relating to order placing and record keeping

The SFC has suspended the licence of Mr Tang Wai Choi, a former licensed representative of Shanxi Securities International Limited (SSIL), for seven months for regulatory breaches relating to order placing and record keeping.

As part of an investigation into a suspected ramp-and-dump scheme, the SFC found that between 10 July 2019 and 10 December 2019, Mr Tang had, unbeknownst to SSIL, logged into a client's securities account and placed 945 orders for the client without valid written authorisation. He also failed to maintain proper records of the order instructions from the client. The above constituted breaches of the SFC's main code of conduct.

Mr Tang's conduct deprived SSIL of the ability to be reasonably certain about the identity of the person responsible for originating the order instructions for transactions, and prevented SSIL from discharging its obligation to maintain a proper audit trail of the client's instructions. His conduct also exposed clients to the potential risk of unauthorised trading and licensed corporations to the risk of potential trade disputes, and could facilitate market misconduct by obscuring the true source of trades. [28 Oct 2025]

SFC bans former relevant individual for seven months for breaches relating to securities accounts and trading

The SFC has prohibited Mr Cheng Lai Ho, a former relevant individual of two registered institutions from re-entering the industry for seven months.

The SFC found that between April 2017 and April 2022, Mr Cheng breached the staff dealing policy and employee code of the two institutions by:

• Failing to make a disclosure upon joining the institutions of the existence of three personal securities trading accounts held at other financial institutions;
• Opening and maintaining a securities margin account at another brokerage firm in the name of his mother after he joined the institutions, and failing to disclose his personal interest in the account to the institutions;
• Conducting over 260 personal trades in the above account without reporting the same or providing the relevant statements of account to the institutions;
• Selling shares in the above account without complying with the minimum holding period required by the institutions; and
• Falsely declared to the institutions on eight occasions that he had complied with their staff dealing policy.

The SFC considers that the above conduct was in breach of the SFC's main code of conduct and calls into question Mr Cheng's fitness and properness to be a regulated person. His concealment of his mother's account and his trading activities was wilful and dishonest, and his failure to disclose his pre-existing personal securities trading accounts to the two institutions casts doubt on his reliability and ability to carry on regulated activities competently. [27 Oct 2025]

SFC and Québec's AMF sign MoU to enhance regulatory cooperation on supervision of cross-border investment management activity

The SFC and the Autorité des marchés financiers (AMF), Québec's financial regulator, have signed a memorandum of understanding (MoU) to strengthen cooperation on the supervision of investment managers of collective investment schemes operating in either market.

The conclusion of the MoU with AMF is by way of signing a counterpart to the Memorandum of Understanding between the SFC and the Ontario Securities Commission on Exchange of Information for Cooperation on Supervision of Cross-Border Investment Management Activity dated 13 May 2025 (see our previous update).

The MoU, signed on the sidelines of the board meeting of the International Organisation of Securities Commissions in Madrid, provides for a regulatory framework for consultation, cooperation and exchange of information in connection with the supervision and oversight of regulated entities engaging in cross-border investment management services.

Following the signing, Québec has been added to the SFC's List of Acceptable Inspection Regimes, facilitating AMF-licensed managers in providing investment management services in respect of SFC-authorised funds. [27 Oct 2025]

HKMA launches industry consultation on proposed revisions to SPM module CA-G-1 to incorporate cryptoasset standards

The HKMA has issued a letter to consult the banking industry on proposed revisions to the its Supervisory Policy Manual (SPM) module CA-G-1 'Overview of Capital Adequacy Regime for Locally Incorporated Authorised Institutions', to incorporate international cryptoasset standards. The consultation will close 24 November 2025. At the time of writing, the letter and the proposed revisions are not publicly available.

This follows the HKMA's consultation launched in September 2025 on a proposed new SPM module and revisions to other modules and guidance to implement Basel Committee's standard on the prudential treatment of banks' cryptoasset exposures (plus consequential and other amendments) (see our previous update). [23 Oct 2025]

SFC consults on proposed enhancements to UT Code to align Hong Kong retail fund regime with latest international regulatory standards

The SFC has launched a three-month consultation on proposed amendments to the Code on Unit Trusts and Mutual Funds (UT Code), which will align Hong Kong's regulatory regime for SFC-authorised funds with the latest international regulatory standards and broaden product offerings for investors. Feedback on the proposals is required to be submitted by 21 January 2026.

The following are the key proposals that are aimed at ensuring that Hong Kong remains a premier asset and wealth management centre that has robust retail fund regulations and fosters product innovation and operational efficiency:

• Financial derivative instruments: Accepting the value-at-risk approach (as an alternative to the current net derivative exposure limit), thereby allowing eligible and well-experienced fund managers greater flexibility in using derivatives and aligns with the practices in major fund jurisdictions;
• Liquidity risk management: Incorporating the latest international standards for liquidity risk management in open-ended funds, particularly IOSCO's Final Report on Revised Recommendations for Liquidity Risk Management for Collective Investment Schemes (May 2025), including ensuring alignment between the liquidity of a fund's asset holdings and its redemption terms, and implementing anti-dilution liquidity management tools for open-ended funds that mainly invest in less liquid assets;
• Phased approach to retail access into private markets: Following its circular in February 2025 clarifying the regulatory requirements for listed closed-ended alternative asset funds (see our previous update), providing flexibility to SFC-authorised unlisted funds to invest in illiquid assets (including private market assets) beyond the 15% investment limit under the UT Code on a case by-case basis and subject to proper safeguards;
• Money market funds: Further strengthening the requirements for such funds, including mandatory use of at least one anti-dilution liquidity management tool, more transparent requirements for eligible high quality money market instruments and money market funds offering constant net asset value.
• Other adjustments to enhance operational efficiency: Examples include refining the acceptability requirements for management companies, enhancing the flexibility of a feeder fund's investment in an SFC-approved underlying master fund without separate authorisation, and consolidating the regulatory framework for specialised schemes.

The proposed amendments to the UT Code are set out in Appendix A to the consultation paper. Consequential amendments to various other codes are also proposed (see Appendices B to E to the consultation paper). [22 Oct 2025]

SFC reprimands and fines registered institution HK$8 million for misclassification of PIs

The SFC has reprimanded and fined a registered institution HK$8 million for deficiencies in its internal systems and controls that resulted in the institution's failure to ensure accurate classification of professional investors (PIs) from 2009 to July 2022.

The SFC found that the registered institution had verified its clients' PI status by an automated process which was based upon its misinterpretation of the minimum portfolio requirement under the Securities and Futures (Professional Investor) Rules for certain types of joint client accounts. The SFC was made aware of the issue via self-reports from the institution and referral of findings from the HKMA.

As a result of the misclassification, the registered institution:

• Provided securities pooled lending service to certain clients who did not qualify as PIs without (i) obtaining valid standing authorities for the use of client securities or securities collateral from these clients, in breach of section 4 of the Securities and Futures (Client Securities) Rules, and (ii) disclosing the relevant information prescribed by section 11(3A) of the Securities and Futures (Contract Notes, Statements of Account and Receipts) Rules in the monthly statements issued to these clients; and
• Offered and sold investment products intended for PIs only to certain non-PI clients.

A look-back review conducted by the institution covering the four-year period between July 2018 and July 2022 identified that a total of 560 joint accounts booked and/or managed in Hong Kong were misclassified as PI accounts.

The SFC considers that the institution had failed to act with due skill and care and establish effective systems and controls to ensure accurate classification of PIs and compliance with the applicable regulatory requirements. The institution was also sanctioned in 2021 for failures of a similar nature (see our previous update).

The institution will implement enhanced complaint handling procedures to review any complaints which may be made by clients potentially misclassified as a PI during the relevant period. [20 Oct 2025]

SFC shows support to market initiatives on regulatory compliance for digital asset funds and tokenised funds

The SFC has showed support to the market's initiatives aimed at enhancing regulatory compliance standards in the digital asset sector. At a seminar organised by the Association of Fund Administrators of Hong Kong and the Greater Bay Area on 17 October 2025, Dr Eric Yip (the SFC's Executive Director of Intermediaries) delivered a keynote speech, emphasising the SFC's commitment in raising professional standards and fostering mutual trust in the digital asset market.

The seminar was attended by over 150 participants, including fund and digital asset professionals, as well as legal and compliance experts. The seminar focused on risk management and control measures for digital asset funds and tokenised funds, emphasising the need for collaborative efforts within the fund industry to strengthen technical and regulatory compliance capabilities while adopting innovative technologies.

The SFC's involvement underscored its commitment to empowering industry through education, engagement and transparency as part of its initiatives under Pillar Re (Relationship) of the 'ASPIRe' roadmap (see our previous update). [20 Oct 2025]

SEHK provides updates on Northbound Program Trading Reporting under Stock Connect

Following its circular of 11 July 2025 regarding the publication of Northbound Program Trading Reporting Guidelines by the SSE and the SZSE (see our previous update) and its circular of 15 August 2025 regarding the technical document on Northbound program trading reporting (see our previous update), the SEHK has issued a further circular to provide updates.

CCEPs and TTEPs are requested to note the following:

• They should review their existing client arrangements and, where necessary, implement appropriate measures to ensure that all necessary and valid authorisations and written consents have been obtained from clients for the collection, storage, use, processing, disclosure, and/or transfer of their personal data to the SEHK, other HKEX group members, relevant regulators and law enforcement agencies in Hong Kong, the SSE, the SZSE, or Mainland regulatory authorities and law enforcement agencies, for the purposes of the Northbound Program Trading Reporting regime.
• An updated File Interface Specification on Northbound Program Trading Reporting has been posted on a dedicated page of the HKEX website. CCEPs and TTEPs must ensure that file names of all files uploaded to the Electronic Communication Platform strictly follow the prescribed naming convention, which is case sensitive.
• An optional end-to-end test session will be arranged from 3 to 28 November 2025 (excluding 10 November), and two optional practice sessions will be arranged in early December 2025 (details to be announced in due course). CCEPs and TTEPs are strongly encouraged to join the test session to verify the respective system changes. [17 Oct 2025]

SFC to host AML/CFT webinar sessions on 17 and 18 November 2025

The SFC has issued a circular to inform licensed corporations, licensed virtual asset service providers and associated entities that it will host two webinar sessions (Cantonese and English) on anti-money laundering and counter-financing of terrorism (AML/CFT) on 17 and 18 November 2025 respectively.

The objectives of the webinar are to:

• Provide an overview of the current scam landscape in Hong Kong and related illicit funds flow through securities firms and virtual asset trading platforms;
• Provide an update on major regulatory developments;
• Share supervisory observations relating to AML/CFT;
• Present money laundering typologies and feedback on the suspicious transaction reporting of the securities sector; and
• Introduce the new Suspicious Transaction Report and Management System 2 (STREAMS 2) developed by the Joint Financial Intelligence Unit.

The Appendix to the circular sets out the rundown and speakers of the webinar sessions.

Firms are encouraged to nominate relevant management or supervisory personnel and compliance officers to attend (maximum of two representatives per firm) via the SFC's enrolment form. Places will first be allocated to the first nominee in each of the enrolment forms on a first come first served basis. Any remaining places will be allocated to the second nominee on the same basis. [17 Oct 2025]

CGFin holds fifth meeting discussing latest developments in fintech sector

The Secretary for Financial Services and the Treasury, Mr Christopher Hui, has chaired the fifth meeting of the Coordination Group on Implementation of Fintech Initiatives (CGFin) and conducted exchanges with representatives from the financial regulators, fintech sector and academia on the latest developments of fintech in Hong Kong.

• The Government exchanged views with the participants on various fintech areas, including promoting the development of a digital asset ecosystem while balancing investor protection and risk management, and the significant potential of green fintech in driving the development of sustainable finance.
• The HKMA reported the latest developments of the wholesale central bank digital currency Project Ensemble and the Generative Artificial Intelligence Sandbox initiative.

It was also noted that the Hong Kong FinTech Week 2025, themed 'Curating the New Fintech Era', was held from 3-7 November 2025 in conjunction with the StartmeupHK Festival, with the main conference taking place on 3-4 November 2025. [16 Oct 2025]

HKMA and Cyberport announce second cohort of GenA.I. Sandbox to enable secure and reliable implementation of A.I.

The HKMA and the Hong Kong Cyberport Management Company Limited (Cyberport) have announced the second cohort of the Generative Artificial Intelligence (GenA.I.) Sandbox. Building on the foundation of the first cohort (see our previous update), this coming cohort demonstrates a significant industry shift from experimenting with A.I.'s capability to enabling its secure and reliable implementation.

A total of 27 use cases (see examples here) from 20 banks and 14 technology partners have been selected from over 60 proposals received. The submissions were prioritised based on innovation, technical complexity and potential value to the industry. Participants will gradually onboard to the designated platform by Cyberport's Artificial Intelligence Supercomputing Centre in late 2025, with trials commencing in early 2026.

A defining theme of this cohort is the proactive approach to A.I. governance, with use cases pioneering 'A.I. vs. A.I.' strategies, such as leveraging A.I. to conduct automated quality checks on A.I.-generated outputs, improving accuracy and consistency at a scalable level. The sandbox will also serve as a testing ground for advanced defence mechanisms against deepfake-related fraud.

The HKMA will continue to share good practices and promote the responsible adoption of A.I. within the financial sector. [15 Oct 2025]

ISDA expands digital regulatory reporting solution to cover Hong Kong's revised derivatives reporting rules

The International Swaps and Derivatives Association, Inc. (ISDA) has expanded its Digital Regulatory Reporting (DRR) solution to support revised derivatives reporting rules in Hong Kong, enabling in-scope firms to implement the changes cost-effectively and accurately.

The amendments from the HKMA and the SFC came into effect on 29 September 2025 (see our previous update). This represents the eighth set of reporting requirements available on the ISDA DRR following earlier launches to cover revisions by regulators in Australia, Canada, the EU, Japan, Singapore, the UK and the US. In total, the ISDA DRR will support 12 reporting rule sets in nine major jurisdictions and the ISDA will maintain the DRR code as those rules evolve in future.

The ISDA DRR uses the Common Domain Model – an open-source data standard for financial products, trades and lifecycle events – to convert the industry interpretation into free, machine-executable code. That code can be used as the basis for implementing the rules or to validate that a firm's interpretation is aligned with the industry reading. Further information on the DRR can be found in the ISDA Solutions InfoHub. [15 Oct 2025]

SFC launches dedicated REIT Channel and streamlines authorisation process and documentary requirements to support REIT market growth

The SFC has launched the REIT Channel, a dedicated one-stop channel to facilitate the authorisation of new real estate investment trusts (REITs) for public offerings, as part of its ongoing efforts to advance the development of Hong Kong's REIT market. The new channel enables both local and international REIT applicants to consult the SFC on a confidential basis, enhancing listing preparation and efficiency.

In parallel, the SFC has streamlined the authorisation process and documentary requirements for REITs, taking into account latest updates under the Listing Rules and market practices. The SFC anticipates that under this process, it can decide on a new REIT authorisation application within four weeks from take-up under normal circumstances.

The following documents regarding the streamlined process for new REIT authorisation applications have been updated:

• Checklist on REIT Authorisation and Documentary Requirements;
• Checklist for Application for Authorisation of Real Estate Investment Trusts; and
• Frequently Asked Questions relating to Real Estate Investment Trusts (REIT FAQs) – Questions 2, 6, 8-13, 15A and 16 have been updated and Questions 8A, 12A-12D have been added.

To facilitate secondary offerings of existing SFC-authorised REITs, the SFC has issued a circular to REIT managers setting out the streamlined content requirements for secondary offering documents. For closer alignment with the requirements for listed companies, REITs seeking authorisation of their secondary offering documents may now adopt the same content requirements as listed companies under the Listing Rules, with necessary modifications. A new Question 63A has been added to the REIT FAQs to provide more practical guidance. The disclosure requirements under the Code on Real Estate Investment Trusts as set out in the circular will continue to apply.

The SFC has also updated the Size Tests for Notifiable Transactions and Connected Party Transactions. [13 Oct 2025]

HKEX announces new Head of Trading Operations and new Head of Connect

The HKEX has announced the appointment of Mr Phillip Wu as Managing Director, Head of Trading Operations, and Ms Sally Kwok as Managing Director, Head of Connect.

• Mr Wu joins the HKEX on 20 October 2025 and will be responsible for leading the Trading Operations teams for both the cash and derivatives markets. He will report to Mr Xu Liang, HKEX Head of Operations. Mr Wu was previously at HSBC, where he was Managing Director, Group Chief Control Officer for HSBC's Global Operations, Deputy Chief Operating Officer, and Global Procurement. Prior to this, he spent 16 years at J.P. Morgan, rising to the position of Managing Director.
• Ms Kwok will commence her new role on 1 January 2026, and will lead a newly established Connect team within the Markets Division, consolidating HKEX's Connect-related initiatives across all asset classes. She will report to Mr Gregory Yu, HKEX Head of Markets. Ms Kwok is currently Co-Head of Trading, overseeing the cash equities market and the Stock Connect programme, as well as client services and market structure. She has held senior positions at HKEX for more than 17 years and previously worked at UBS. [13 Oct 2025]

HKEX advances commodities business with new subsidiary in Dubai

The HKEX has announced the launch of Commodity Pricing and Analysis Limited (CPAL), a new subsidiary based in Dubai (United Arab Emirates), which has in recent years positioned itself as a major global commodities trading hub.

CPAL will operate as a commodities pricing administrator, providing independent price reporting and market analysis dedicated to the global metals market, including the support of the London Metal Exchange (LME)'s development of sustainable metal premia that was announced in April 2025. The establishment of CPAL also underscores the HKEX Group's ambitions in expanding its commodities business and helping to drive greater connectivity between China and fast-growing markets in the Middle East.

The LME, a wholly owned subsidiary of HKEX, has announced the next steps in its plans to develop sustainable metal premium pricing for LME-approved brands, which include the publication of a discussion paper on its proposed pricing methodology. CPAL will serve as the pricing administrator for the sustainable metal premia. [13 Oct 2025]

SFC publishes latest issue of Enforcement Reporter focusing on fighting scams in digital age

The SFC has published the latest issue of its Enforcement Reporter, discussing ongoing anti-scam efforts in the digital age:

• Growing threat of financial scams: In 2024, the Hong Kong Police Force recorded over 44,000 deception cases, a fourfold increase in five years. Scam-related complaints have shown an alarming year-on-year increase during the first half of 2025, surpassing more than half of 2024's full-year total.
• Emerging scam trends: Key scam trends include cross-border scams, impersonation on social media, rise of finfluencers (some of whom engaging in unlawful activities such as promoting unauthorised investment products, charging fees for investment advice, and engaging in unlicensed activities), cryptocurrency-related scams, market manipulation via social media, and more prevalent SMS phishing.
• The SFC's strategies to combat scams: The SFC has introduced a Social Media Monitoring System (SENSOR) to monitor potential signs of financial scams. The Alert List on the SFC's website provides timely warnings to investors about potential fraudulent schemes and serves as a database of 'risky entities'. The SFC is working with major social media platform operators to establish direct notification-and-removal mechanisms after its first takedown protocol was established in October 2024 with a major platform operator. It plans to implement a 'detect and remove' model to proactively identify and prevent the investing public from encountering fraudulent content.
• Practical tips for investors: The SFC sets out various tips to stay ahead of scams.
• Anti-Scam Consumer Protection Charter 3.0: This was launched in collaboration with other financial regulators, technology firms and telecom companies to promote dialogue and collaboration on combating financial frauds and scams (see our previous update).
• Enforcement actions: The SFC discussed two recent enforcement actions against finfluencers engaging in unlawful activities.
• Global and regional collaboration: The SFC discussed international and regional initiatives to raise public awareness and strengthen monitoring of online platforms through collaboration with platform providers. [9 Oct 2025]

FSTB announces launch of The Family Office Playbook

The Secretary for Financial Services and the Treasury has announced the launch of 'The Family Office Playbook: A guide for legacy builders', which is a guide created by Bloomberg, the Financial Services and the Treasury Bureau (FSTB), and Invest Hong Kong.

The playbook, which can be accessed via Bloomberg's portal, is a comprehensive guide tailored for family offices, offering a clear roadmap for those planning to establish or expand their operations in Hong Kong. It covers practical advice on strategy formulation, navigating the regulatory environment, investment management, operational efficiency, and wealth succession and philanthropy.

Since its inception a year ago, the Hong Kong Family Office Nexus has become a powerful engine in fostering the development of Hong Kong's family office ecosystem. The HKMA's partnership with Bloomberg has enabled it to integrate global resources and provide family offices with a digital knowledge hub, professional insights, and a platform for exchange. The hub has attracted over 4,000 views globally, reflecting Hong Kong's strong appeal in the global wealth management arena. In addition, Invest Hong Kong has successfully assisted over 200 family offices to set up or expand in Hong Kong, achieving the target set in the 2022 Policy Address ahead of schedule. [9 Oct 2025]

OTC Clear adopts version 14 of Main Book of 2021 ISDA Interest Rate Derivatives Definitions from 26 September 2025

OTC Clearing Hong Kong Limited (OTC Clear) has issued a circular to inform participants that it has adopted (in its entirety) Version 14 of the Main Book of the 2021 ISDA Interest Rate Derivatives Definitions with effect from 26 September 2025, for the purposes of interpreting or implementing the contract terms of each contract registered with OTC Clear irrespective of its registration time. The new version includes updates on (among others) the bespoke permanent cessation fallbacks for KRW-CD 91D and amended fixing time for INR-MIBOR-OIS compound.

Contracts that are registered with OTC Clear on or after 26 September 2025 will adopt the new version. The contract terms for the contracts that were registered with OTC Clear prior to 26 September 2025 will be amended pursuant to the new version, with the amendment taking effect from 26 September 2025. [6 Oct 2025]

SFC suspends former RO and MIC of former licensed corporation for four months over failures relating to credit risk management and suspicious transaction monitoring and reporting

The SFC has suspended Mr Joey Lo Wai Hon, a former responsible officer (RO) of MTF Securities Limited (MTF), for four months for failing to properly manage credit risks and to identify and report suspicious trading patterns of clients. Mr Lo was also a former manager-in-charge for key business line of MTF.

The disciplinary action follows the SFC's findings that MTF had, between January and July 2021, failed to:

• Maintain effective policies and procedures to ensure the proper management of credit risks arising from its granting of trading limits to clients; and
• Maintain an effective ongoing monitoring system to identify, examine and report suspicious trading patterns in client accounts.

The above constituted breaches of the SFC's main code of conduct and other regulatory requirements on risk management and anti-money laundering and counter-financing of terrorism. The SFC considers that the breaches were attributable to Mr Lo's failure to discharge his duties as an RO and a member of the senior management of MTF at the material time. Mr Lo is guilty of misconduct and his fitness and properness to carry on regulated activities have been called into question.

In June 2025, the SFC prohibited Ms Wong Lai Suen, a former RO and executive director of MTF, from re-entering the industry for six months (see our previous update). [2 Oct 2025]

Singapore

MAS: Initiatives to support development of carbon markets

The National Climate Change Secretariat, Ministry of Trade and Industry, Enterprise Singapore and MAS have announced a number of initiatives to support the development of high-integrity carbon markets, including:

• the publication of voluntary carbon market guidance on how companies can use carbon credits as part of their decarbonisation plans;
• engaging with leading corporates in Asia to set up an industry-led buyers' coalition to aggregate demand for high-quality carbon credits; and
• the introduction of a new financial sector carbon market development grant to support financial institutions' participation in carbon markets.

Applications for the grant has opened on 1 November 2025. [28 Oct 2025]

MAS consults on measures to seek civil compensation

The MAS has published a consultation paper setting out proposals to enhance investors' ability to seek civil compensation for losses suffered from market misconduct. Three key proposals are suggested to strengthen the investor recourse regime:

• facilitating self-organisation;
• providing access to funding; and
• reducing legal barriers to civil action.

Responses are requested by 31 December 2025. [24 Oct 2025]

MAS speech: Enhancing Singapore's role as regional hub

The MAS has published a speech by its Deputy Chair and Minister for National Development, Chee Hong Tat, on enhancing Singapore's financial services sector. In this regard, Mr Tat highlighted four strategic priorities:

• building on Singapore's competitive strengths in key areas – including asset and wealth management, insurance, foreign exchange and capital markets – to deepen capabilities and enhance resilience as a hub;
• proactively establishing new growth pillars, such an in AI;
• strengthening the country's regional and global connectivity by deepening trade, payment, and financial linkage; and
• strengthening the talent pipeline.

Mr Tat also highlighted some of the initiatives and measures adopted aimed at strengthening Singapore's capital markets. [22 Oct 2025]

MAS launches initiative to extend settlement capabilities

The MAS has announced the launch of a new initiative – BLOOM (borderless, liquid, open, online, multi-currency) – to extend settlement capabilities offered by financial institutions.

Through BLOOM, MAS will collaborate with the financial industry to enable settlement in tokenised bank liabilities and well-regulated stablecoins, whilst managing risks in the digital settlement asset landscape through standardised approaches.

BLOOM members will work together to address challenges and opportunities of common interest to the industry. Initial focus areas include: distribution and clearing of settlement assets; programmable controls to enhance and automate compliance checks; and agentic payments for seamless and automated transactions. [16 Oct 2025]

SGX Group and Indonesia Stock Exchange launch depository receipts linkage

The SGX Group has announced the launch of the Indonesia-Singapore Depository Receipt Linkage, with an inaugural batch of Singapore Depository Receipts being issued. This development follows the signing of a memorandum of understanding between SGX Group and the Indonesia Stock Exchange in 2024. [16 Oct 2025]

MAS: Response to PQ on stablecoins impact and public education efforts

The MAS has published the response to a Parliamentary question (PQ) on whether the Government monitors the ratio of manned bank front counters to senior residents across different areas in Singapore. MAS stated that although it does not record manned counters, it monitors bank branch numbers and locations. [15 Oct 2025]

ABS: Banks to strengthen anti-scam measures

The ABS has announced that, from 15 October 2025, major retail banks will implement enhanced fraud surveillance on all digital transactions in order to strengthen customer protection measures against scams. Where banks detect that an account is being quickly emptied and suspect a scam, transactions may be held for a 24-hour cooling period before being released or rejected immediately. Customers may experience delays in digital payments and transfers, including for legitimate transactions, as banks bolster consumer protection efforts. [3 Oct 2025]

MAS: Key regulatory and enforcement actions Q3 2025

The MAS has published a summary of the key enforcement actions it has taken during the period July to September 2025. [1 Oct 2025]

Indonesia

New fit and proper test regulation for the financial technology innovation, digital financial assets, and crypto assets sector

On 20 June 2025, the OJK issued OJK Regulation No. 16 of 2025 on Fit and Proper Tests and Reassessments for Principal Parties in the Financial Technology Innovation Sector, Digital Financial Assets, and Crypto Assets (OJK Reg. 16). This regulation introduces a uniform regime for the fit and proper test for the main parties in these sectors, which include:

• a controlling shareholder (holding more 25% or more of issued shares with voting right, or less than 25% of issued shares with voting right but exercising control directly or indirectly);
• members of the board of directors; and
• members of the board of commissioners.

Under this OJK Reg. 16, assessments are based on three criteria: integrity, financial soundness and competence of the candidate. OJK Reg. 16 outlines details procedures and requirements for the fit and proper test and reassessments.

OJK Reg. 16 provides that the fit and proper test approval of the main parties issued by OJK prior to enactment of OJK Reg. 16 or by other authority overseeing the digital financial asset trading organisers (i.e, Commodity Futures Trading Supervisory Agency (Badan Pengawas Perdagangan Berjangka Komoditi or Bappebti) before the transfer of supervisory authority to OJK, will remain valid. OJK Reg. 16 took effect since 1 October 2025. [10 Oct 2025]

Malaysia

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]

BNM publishes discussion paper on asset tokenisation

BNM has published a discussion paper setting out BNM's proposed approach to exploring asset tokenisation in the Malaysian financial sector. Responses are requested by 1 March 2026. [30 Oct 2025]

BNM speech: Future-proofing Islamic financial market

BNM has published the opening address by its Deputy Governor Adnan Zaylani Mohamad Zahid at the IFMC Roundtable at Global Islamic Finance Forum 2025. Mr Zahid discussed the development of Islamic finance in Malaysia over the past forty years, noting that the country has secured the top position in the Islamic Finance Development Indicator 2024 for the twelfth consecutive year. He then highlighted three steps to future-proof the market:

• broadening the sukuk investors pool beyond traditional segments;
• building a future-oriented market infrastructure, conducive for innovation; and
• advancing repo instruments to deepen the market.

Mr Zahid also called for innovation in areas like asset tokenisation, green finance, and waqf-based instruments. [17 Oct 2025]

BNM: Transition from KLIBOR to MYOR and MYOR-i

BNM has announced that it is replacing the Kuala Lumpur Interbank Offered Rate (KLIBOR) with the Malaysia Overnight Rate (MYOR) and Malaysia Islamic Overnight Rate (MYOR-i). KLIBOR will cease to exist on 1 January 2029.

MYOR and MYOR-i, introduced in 2021 and 2022 respectively, are transaction-based benchmark rates based upon transactions in active and liquid markets. Key milestones in the transition include:

• By 1 October 2026, market participants are expected to be operationally ready to offer products referencing MYOR and MYOR-i as part of their standard offering;
• By 1 July 2027, KLIBOR will cease to be used in new trades across all products;
• By 1 July 2027, BNM plans to mandate the use of MYOR-i for all new Islamic financial products; and
• By 30 June 2028, all legacy KLIBOR contracts will be converted to MYOR/MYOR-i where possible, and any remaining contracts shall incorporate robust fallback provisions. [16 Oct 2025]

BNM launches RENTAS+ to enable round-the-clock interbank settlement

BNM has announced the launch of RENTAS+, an enhancement to RENTAS, Malaysia's real-time gross settlement system. Developed internally using cloud technology, RENTAS+ facilitates continuous interbank funds transfer and settlement, operating around the clock throughout the year. To enable round-the-clock settlement, BNM has also introduced an automatic liquidity facility using repurchase agreements and sell and buy back agreements. [7 Oct 2025]

Thailand

BOT announces launch of cross-border QR payment linkage

The BOT has announced the launch of the cross-border QR payment linkage between Thai banks and three Chinese payment service providers. The launch means that users from China will be able to use the three Chinese payment service providers to scan Thai merchants displaying Thai QR Codes issued specified banks.

Currently, arrangements for cross-border QR payment collaboration is in place with nine countries. [30 Oct 2025]

India

SEBI implements eligibility criteria for derivatives

SEBI has published a circular about the implementation of eligibility criteria for derivative on existing non-benchmark indices. The circular concerns prudential norms. [30 Oct 2025]

SEBI circulars: Ease of doing business

SEBI has published two circulars regarding the ease of doing business including:

• ease of doing business - interim arrangement for certified past performance of investment advisers and research analysts prior to operationalisation of Past Risk and Return Verification Agency; and
• ease of doing business measures - enabling investment advisers to provide second opinion to clients on assets under pre-existing distribution arrangement. [30 Oct 2025]

SEBI extends timeline for mandatory implementation of systems and processes for T+0 settlement

SEBI has further extended the timeline for the mandatory implementation of systems and processes for Qualified Stock Brokers to the T+0 settlement cycle. Further guidance to the timeline shall be circulated in due course. [30 Oct 2025]

RBI: Draft circular on guidelines to facilitate faster cross-border inward payments

The RBI has published a draft circular on guidelines to facilitate faster cross-border inward payments. Feedback on the draft is requested by 19 November 2025. [29 Oct 2025]

SEBI consults on mutual fund regulation

SEBI has published a consultation seeking views on the SEBI (Mutual Funds) Regulations, 1996. Responses are requested by 17 November 2025. [28 Oct 2025]

IFSCA amends IFSCA (Listing) Regulations, 2024

The IFSCA has amended the IFSCA (Listing) Regulations, 2024 to provide the regulatory framework for listing of specified securities, debt securities, depository receipts and other permitted financial products on the recognised stock exchanges in the IFSC. [28 Oct 2025]

SEBI consults on the offering of incentives by debt issuers

SEBI has published a consultation on permitting debt issuers to offer incentives in public issues to certain category of investors. Responses are requested by 17 November 2025. [27 Oct 2025]

IFSCA consults on regulatory framework for dematerialisation of securities

The IFSCA has published a consultation paper to seek comments from the public on the proposal for dematerialization of securities by entities in the IFSC jurisdiction. Responses are requested by 16 November 2025. [27 Oct 2025]

SEBI allows the transfer of PMS business

SEBI has published a circular allowing the transfer of portfolio management services business (PMS business) after obtaining prior approval from SEBI. [24 Oct 2025]

SEBI: Consultation on relaxation of KYC requirements for NRI clients

SEBI has published for consultation a proposal to allow non-resident Indian (NRI) clients to complete the know your customer (KYC) process via digital video identification without being physically present in India. Feedback on the proposal is requested by 13 November 2025. [23 Oct 2025]

IFSCA: Framework on stewardship code

The IFSCA has issued its framework for the stewardship code. The set of principles are aimed at guiding regulated entities undertaking investment activities in IFSC which act as institutional investors by aligning their practices with global standards for long-term value creation. [23 Oct 2025]

SEBI consults on process standardisation for opening mutual fund folios and executing initial investments

SEBI has published a consultation paper on proposals to standardise the process for opening mutual fund folios and executing first investments. SEBI proposes that new folios should be verified for full KYC compliance at both the Asset Management Company and KYC Registration Agency levels. Responses are requested by 14 November 2025. [23 Oct 2025]

IFSCA consults on differential distribution rules for restricted and venture capital schemes

The IFSCA has published a consultation paper on proposals to facilitate blended finance and other fund structures in the IFSC(s) by permitting differential distribution in the Venture Capital Schemes and Restricted Schemes under Part A and B, respectively, of Chapter III of IFSCA (Fund Management) Regulations, 2025. Comments on the consultation are requested by 11 November 2025. [22 Oct 2025]

SEBI: Consultation on easing transfer of securities made before April 2019 and simplifying share dematerialisation process

SEBI has published for consultation proposed amendments to certain provisions of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 to facilitate the transfer of securities transferred prior to 1 April 2019 and to simplify the process of dematerialisation of securities. Feedback is requested by 7 November 2025. [17 Oct 2025]

IFSCA consults on changes to Banking Handbook – restrictions on activity of providing credit

The IFSCA has published a consultation on proposed amendments to the restrictions by the authority on the activity of providing credit, which is outlined in Module 16 of the IFSCA Banking Handbook: Conduct of Business (COB) Directions. Comments on the amendments are requested by 7 November 2025. [17 Oct 2025]

IFSCA: Consultation on amendments fund management regulations

The IFSCA has published a consultation on proposed amendments to its fund management regulations. The proposals are aimed at enhancing ease of doing business, introducing additional safeguards and providing clarifications. Responses are requested by 6 November 2025. [17 Oct 2025]

SEBI: Master circular for issue and listing of debt and related securities

SEBI has published a master circular consolidating all previous circulars related to the issue and listing of non-convertible securities, securitised debt instruments, security receipts, municipal debt securities and commercial paper. [15 Oct 2025]

SEBI: Relaxation in timeline for disclosure of allocation methodology by angel funds

SEBI has extended the deadline for angel funds to disclose their investment allocation methodology in private placement memorandums (PPMs) to 31 January 2026. Accordingly, any investments made by existing angel funds after this date must be in compliance with the allocation methodology specified in their respective PPMs. [15 Oct 2025]

RBI seeks views on consolidation of regulations

The RBI has published for consultation a set of master directions that consolidate existing regulatory instructions. Additionally, it has issued a list of circulars that it plans to repeal. The proposal is intended to improve the accessibility of regulatory instructions for regulated entities and thereby reduce their compliance cost. Feedback is requested by 10 November 2025. [10 Oct 2025]

SEBI: Review of block deal framework

SEBI has issued a circular which sets out modifications to the existing block deal framework. Block deal refers to the execution of large trades through a single transaction without putting either the buyer or seller in a disadvantageous position. The provisions outlined in the circular will take effect 60 days after issuance. [8 Oct 2025]

RBI consults on amendments to firms' internal ombudsman mechanism

The RBI has published a consultation on a draft master direction regarding the internal ombudsman mechanism in various regulated entities (REs), following a review of the existing instructions. The draft directions are aimed at strengthening the internal grievance redress mechanism within a RE and ensuring a speedy and meaningful resolution of customer complaints by enabling a review (by an apex level authority within the RE) before their rejection. Responses to the consultation were requested by 28 October 2025. [7 Oct 2025]

RBI seeks feedback on amendments to integrated ombudsman scheme

The RBI has published for consultation the draft Reserve Bank - Ombudsman Scheme, 2025 following a review of the integrated ombudsman scheme that was launched in 2021. Responses are requested by 28 October 2025.

Additionally, the RBI has issued a notification to bring state co-operative banks and central co-operative banks under the ambit of the integrated ombudsman scheme, with effect from 1 November 2025. [7 Oct 2025]

Philippines

BSP strengthens regulatory relief policy

BSP has announced that banks may now grant any borrower in calamity-affected areas a grace period of up to six months for loan repayments. The circular also stated when the victims - or potential victims - of specific calamities can claim relief for tropical typhoons that hit land or not, other natural hazards, or human-induced hazards. [27 Oct 2025]

BSP and PDIC amend agreement on bank examination

The BSP and the PDIC have signed a revised memorandum of agreement on bank examination. The revised agreement is intended to prevent duplication of efforts and establish a data-sharing framework to optimise the use of bank reports, information, and findings. [23 Oct 2025]

SECP streamlines submission of AML manual and AML compliance form requirement

The SECP has announced that financing and lending firms are no longer required to submit the Anti-Money Laundering (AML) Operating Manual and the Anti-Money Laundering Compliance Form. Moving forward, for compliance monitoring purposes, the Financing and Lending Companies Department will assess the compliance of firms on their AML Council registration and submission of the Money Laundering and Terrorist Financing Prevention Program. [21 Oct 2025]

BSP expands access of overseas Filipinos to retirement funds

The BSP has announced that it has updated its rules to give more overseas Filipinos more investment options. Personal Equity and Retirement Account Unit Investment Trust Funds are now exempt from the non-resident ownership rule that previously limited their ability to invest in BSP securities. [20 Oct 2025]

SECP consults on revised guidelines on beneficial ownership disclosure and transparency

The SECP has published for consultation a draft memorandum circular on the revised guidelines on beneficial ownership disclosure and transparency. Feedback is requested by 9 November 2025. The revised rules will take effect 15 days after their publication in two newspapers of general circulation in the Philippines. [10 Oct 2025]

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