Hong Kong flag enforcement action targets unlicensed payment platforms

香港严厉打击无牌支付平台

据Crypto.news报道，香港金融服务及财政局已向立法会议员表示，对于运营所需牌照的支付平台，监管机构将在必要时采取执法行动。此前，香港金融管理局（HKMA）记录到2024年1月至2026年9月期间收到16宗关于涉嫌无牌储值服务的投诉。

香港官员强调，将针对未持有必要牌照的支付平台采取行动。政府在10月7日致立法会的书面回复中指出，上述时间段内共收到16宗相关投诉，其中仅有一宗被证实成立。

据报道，该书面回复由金融及财政局副秘书陈浩民在咨询金管局及海关后提交。香港媒体PANews援引移动支付网络的消息，于10月10日报道称，陈浩民表示，将根据法定监管框架在必要时采取适当的执法行动，以保护客户及公众利益。

关键事实

• 2024年1月至2026年9月期间，金管局收到16宗关于涉嫌无牌储值服务的投诉，经调查核实其中一宗。举报人称未遭受金钱损失。
• 10月7日的立法会回复由副秘书陈浩民在咨询金管局及海关后作出。
• 根据《支付系统及储值设施条例》，除非适用法定豁免，否则在香港发行或经营储值设施属违法行为。
• 货币兑换及跨境汇款服务受另一套由《反洗钱及恐怖分子资金筹集条例》设立的海关牌照制度管辖。
• PANews报道指出，陈浩民表示，仅注册为金融科技公司而无任何金融牌照的平台是引发此次警告的具体关注点。

投诉来源与背景

政府的回复旨在回应议员陈志荣关于“付款聚合商”的提问。此类平台通过低手续费和“先买后付”优惠吸引小型商户。议员引用了因违约和虚假付款导致商户损失的报告，并对仅注册为金融科技公司、缺乏金融服务牌照且未公开披露合作伙伴及运营情况的平台表示担忧。

关于执法措施，陈浩民表示：“如涉及涉嫌无牌经营储值设施或不遵守《支付系统及储值设施条例》的情况，金管局将直接介入。”回复指出，视乎个案情况，当局将与其他监管机构协调，并将事项转介执法机关。金管局正在跟进已核实案例中的涉事公司，并将随着案件进展决定进一步行动。

按业务性质划分的牌照界限

The government's reply clarified the regulatory ownership of various services. Value-stored facilities are supervised by the HKMA. The HKMA's Consumer Guidelines list multi-purpose prepaid cards and e-wallets as examples, covering value storage facilities used to make payments to issuers and participating third parties, or transfer money between users. Single-use facilities that are only used to purchase goods or services from issuers, and payment methods that do not have stored value capabilities (such as credit cards and Apple Pay), are not covered by the licensing system.

Currency exchange and cross-border remittance services are regulated by customs, and the government said it will take enforcement action against violations of the money service operator licensing system. The government pointed out that ancillary services to the business of licensed stored value operators fall within the scope of statutory exemptions. "Buy before Pay" services operated by banks are still subject to supervision by the HKMA, while other service providers engaged in lending business must hold a money lender's licence under the Money Lenders Ordinance.

Both institutions will evaluate the applicant's ability, integrity and fair operation ability when approving licenses, including customer due diligence, record keeping and customer funds processing. For customers who wish to verify service providers, the HKMA's guidance states that each licensed stored value operator has a unique license number that can be checked in its public register, and warns that users of wallets or prepaid cards that are not operated under the license system may not be protected.

The significance of this move

In recent years, Hong Kong has been building regulatory boundaries for licensed digital assets and payments. The warning reiterated that operating within this range is a legal requirement, not a marketing choice. The merchants and small businesses that Mr CHAN Chi-wing focused on are at greatest risk: they may suffer losses due to default or false payments on unlicensed platforms that have never accepted the customer review and customer fund management requirements that licensed operators must comply with. The tools described by the government-open registers and license number searches-are equally applicable to wallets and prepaid cards in the digital asset space, where licenses have become the dividing line between regulated and supporting providers.

Future Outlook

The next step will be how the HKMA will end its follow-up of the company behind the only verified complaint and whether further enforcement actions will be generated or referrals to law enforcement agencies. In addition, broader licensing activities in the field of encryption services in Hong Kong are also underway, with the government previously outlining new licensing plans for four encryption services.

FAQs

How many complaints has the HKMA received about unlicensed stored value services?

According to the reply given by the Financial Services and Finance Bureau to the Legislative Council on October 7 quoted by Crypto.news, a total of 16 complaints were received from January 2024 to September 2026. Investigators verified one case and the whistleblower stated that no financial loss was sustained.

Which stored value facilities in Hong Kong require a license?

The HKMA's consumer guidance points out that multi-purpose prepaid cards and electronic wallets are typical examples. The licensing system covers value storage facilities used to make payments to issuers and participating third parties, or transfer funds between users. Single-use facilities used solely to purchase goods or services from issuers are outside the scope of the system.

Do currency exchange and remittance platforms require different licenses?

Yes, and from different regulatory agencies. The government stated that platforms that provide currency exchange or cross-border remittance services need to obtain a customs license under the Anti-Money Laundering and Terrorist Financing Ordinance unless statutory exemptions apply.

How do customers check whether a payment provider is licensed in Hong Kong?

The HKMA guidelines state that each licensed stored value operator has a unique licence number that can be checked in its public register. Authorities have warned that the rights of users who use wallets or prepaid cards that are not operated under the license system may not be protected.