Regulatory environment

A Hong Kong money lenders licence is the authority to carry on the business of lending money, granted by the Licensing Court on an application filed through the Companies Registry and vetted by the Police. It runs for 12 months and must be renewed annually. Its holder is bound not only by the Money Lenders Ordinance (Cap. 163) but by sixteen licensing conditions, which from 1 August 2026 impose, for the first time, a hard cap on a borrower’s debt service burden and a complete ban on asking for loan referees.

From 23 January 2026 the activity of Astana Hub participants is governed by new Rules approved by Order No. 703/НҚ of 31 December 2025, and since July 2026 by an amended version of those Rules. The Rules replaced a 2018 order that had stood for seven years and introduced two genuinely new duties: an annual report on the structure of income, the data in which is confirmed by an auditor, and counter-obligations to develop the IT ecosystem. At the same time the tax reliefs moved into a new Tax Code — Code No. 214-VIII of 18 July 2025, in force from 1 January 2026.

The Competition Ordinance (Cap. 619) is Hong Kong’s principal competition statute: Ordinance No. 14 of 2012, passed by the Legislative Council (LegCo) on 14 June 2012, gazetted on 22 June 2012 and brought fully into operation on 14 December 2015.

Dubai Science Park is one of the ten districts for which the Dubai Development Authority (DDA) issues licences under its Decision No. 1 of 2021, and one of the ten districts TECOM Group calls its own — two lists of ten that do not coincide. A DDA licence opens the door to life sciences activity but confers no right either to sell medicines and medical devices or to treat patients: the product layer belongs to the federal Emirates Drug Establishment (EDE), and patient-facing services to the Dubai Health Authority (DHA). All three licences run in parallel, and none substitutes for another.

A licence from Hong Kong’s Securities and Futures Commission (SFC) is mandatory for anyone carrying on a business in one of the regulated activities listed in Part 1 of Schedule 5 to the Securities and Futures Ordinance (Cap. 571). The Schedule lists thirteen activities, but only eleven are live: Types 1 to 10 and Type 13. For each activity a corporation must have at least two approved Responsible Officers (ROs), the prescribed paid-up share capital, and liquid capital maintained at all times under the Financial Resources Rules.

A Money Service Operator (MSO) is a person who, in Hong Kong and as a business, provides a money changing service or a remittance service and must therefore hold an MSO licence granted by the Commissioner of Customs and Excise under Part 5 of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615, AMLO). The licence runs for two years, an application for its grant has cost HK$3,810 plus HK$945 for each person subject to the fit-and-proper test since 15 May 2026, and operating without a licence carries a fine of up to HK$1,000,000 and up to two years’ imprisonment. The feature that sets the MSO apart from Hong Kong’s other AMLO licences is that an MSO is listed as a “financial institution”, so a breach of the customer due diligence duties in Schedule 2 is a criminal offence, not merely a disciplinary matter.

A trust or company service provider (TCSP) licence is mandatory in Hong Kong for anyone who, by way of business, provides other persons with a registered office, director or secretary services, a nominee shareholder or a trustee. The regime sits in Part 5A of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and is administered by the Companies Registry. A licence runs for three years; at the end of June 2026 there were 7,412 licensees.

A Hong Kong stablecoin issuer licence is required of any person who, in the course of business, issues a specified stablecoin in Hong Kong, or issues outside Hong Kong a stablecoin referenced wholly or partly to the Hong Kong dollar. Licensing is administered by the Monetary Authority (HKMA). The regime has been in force since 1 August 2025.

A subsoil use licence in Kazakhstan is a document issued by a state body on application, granting the holder the right to use a specific subsoil plot. Two licences matter for solid minerals: the exploration licence for solid minerals, issued for six years and extendable once by up to five, and the production licence for solid minerals, issued for up to twenty-five years with an unlimited number of extensions. Both are issued by the Ministry of Industry and Construction of the Republic of Kazakhstan and, since 2026, only through the Unified Subsoil Use Platform.

A DNFBP — a designated non-financial business or profession — is one of five categories of person to which the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) applies the customer due diligence and record-keeping requirements of Schedule 2. Four of those categories hold no TCSP licence: accounting professionals, legal professionals, estate agents and Category B precious metals and stones registrants. This article deals with those four.

A subject of financial monitoring (SFM) — the statutory term for a reporting entity — is an organisation or individual listed in paragraph 1 of Article 3 of Law of the Republic of Kazakhstan No. 191-IV of 28 August 2009 “On Counteracting the Legalisation (Laundering) of Proceeds of Crime, the Financing of Terrorism and the Financing of the Proliferation of Weapons of Mass Destruction” (Law No. 191-IV, the AML/CFT/CPF Law), on which the Law imposes duties to detect and report transactions in money and other property to the Agency of the Republic of Kazakhstan for Financial Monitoring (AFM), the authorised body for financial monitoring (Kazakhstan’s financial intelligence unit).

The Digital Code of the Republic of Kazakhstan is Code No. 255-VIII of 9 January 2026, which on 12 July 2026 replaced the 2003 Law on electronic documents and electronic digital signatures (the companion Law No. 256-VIII simultaneously renamed the Law “On Informatisation” as the Law “On Cybersecurity”) and brought the rules on digital platforms, electronic digital signatures (EDS), electronic documents, biometrics, algorithmic decisions and data circulation together in a single act. For business, the Code operates together with Law No. 230-VIII of 17 November 2025 “On Artificial Intelligence” (in force since 18 January 2026) and with the amendments to the Law on personal data (in force since 25 August 2026). The practical outcome for a company: platform user agreements, document-signing procedures, powers of attorney for employees’ electronic signatures, labelling of AI-generated content and notifications of personal data processing all need to be brought into line with the new rules — administrative fines under the Code of Administrative Offences for breaches in the fields of AI, electronic signatures and cybersecurity are already in force and reach 1,000 MCI (KZT 4,325,000) for large businesses.