Updated Guidance on Registration in Respect of Regulated Activities under the Securities and Futures Ordinance and Controls to Ensure Fitness and Properness of Staff

55th Floor, Two International Finance Centre, 香 港 中 環 金 融 街 8 號 國 際 金 融 中 心 2 期 55 樓 8 Finance Street, Central, Hong Kong 網 址：www.hkma.gov.hk Website: www.hkma.gov.hk Our Ref: B1/15C G16/1C 27 October 2025 The Chief Executive All Authorized Institutions Dear Sir / Madam, Updated Guidance on Registration in Respect of Regulated Activities under the Securities and Futures Ordinance and Controls to Ensure Fitness and Properness of Staff I am writing to provide a consolidated and updated guidance on registration and related matters in respect of regulated activities under the Securities and Futures Ordinance (hereafter “RAs”) and certain controls to ensure fitness and properness of potential employees of authorized institutions (AIs), so as to facilitate compliance. Registration and related matters in respect of RAs Under the securities regime, any person carrying on RAs has to be licensed or registered with the Securities and Futures Commission (SFC), unless a specific exemption is applicable. An AI should apply for registration with the SFC to become a registered institution (RI) if it intends to engage in one or more applicable RAs, and appoint at least two executive officers (EOs) to directly supervise the conduct of each proposed RA. For other relevant individuals (ReIs), the institution should register them onto the Register of Securities Staff of AIs (HKMA Register) before they carry on any regulated function of any regulated activity for the institution. With the development of securities regime over the years, the Hong Kong Monetary Authority (HKMA) notes that certain guidance previously issued on registration-related matters had become obsolete. With an aim to providing a more convenient access to registration-related requirements and arrangements that

• 2 - remain applicable, the HKMA has reviewed and updated in this circular the relevant guidance. This consolidated guidance has not introduced any new regulatory standards. In consolidating the existing guidance, the operational and procedural details on registration to become an RI, application to become an EO, and online submission and maintenance of the HKMA Register are set out in Annex 1; further guidance on controls to ensuring relevant individuals (also including EOs, ReIs under temporary engagement and itinerant professionals) are and remain fit and proper, and compliance with the prohibition of unregistered dealing and disciplinary actions is set out in Annex 2. RIs are reminded that reference checks from previous employers of a proposed ReI should cover, among other things, whether the individual is or has been dismissed, requested to resign, or subject to internal investigations or disciplinary actions by the previous employers in relation to conduct matters. In addition, RIs are reminded to adhere to the requirements of the conduct-related information to be reported under the Mandatory Reference Checking (MRC) Scheme. RIs are also reminded about the effectiveness and comprehensiveness of self-declaration mechanism. AIs should provide a clear response within a reasonable period of time when receiving other RIs’ request for information about previous employees. AIs may make reference to the response timeline prescribed under the MRC Scheme. It is imperative that the industry makes a joint effort together to ensure the fitness and properness of the practitioners. AIs should comply with this circular and all applicable requirements issued and updated by the regulators from time to time. Some key examples of the existing applicable guidelines are set out in Annex 3. AIs are reminded to put in place adequate policies and procedures, internal controls and staff training to ensure compliance. Certain controls to ensure fitness and properness of potential employees In addition to EOs and ReIs, AIs also need to ensure the fitness and properness of their employees. Taking this opportunity, the HKMA would like to remind all AIs of the need to, among other things, perform comprehensive due diligence on potential employees regarding their history of terminated employments and convictions of offences. Please refer to Annex 4 for details.

• 3 - The previous HKMA circulars superseded by this circular are listed in Annex 5. Should you have any questions on this circular, please contact Ms Candy Tam at 2878-1292 or Ms Hoi-yan Tseung at 2878-1408. Yours faithfully, Alan Au Executive Director (Banking Conduct) Encl. c.c. Securities and Futures Commission (Attn: Dr Eric Yip, Executive Director, Intermediaries)