Licensing

In Hong Kong, there is no specific licensing regime for family offices. The licensing regime under the Securities and Futures Ordinance (SFO) is activity‐based. If the services provided by a family office do not constitute any regulated activity or they fall within any of the available carve‐outs, the family office is not required to be licensed under the SFO. The licensing implications in Hong Kong do not hinge on whether clients are families.

Here are some examples where a family office will not need a licence:

1. A family appoints a trustee to hold its assets of a family trust, and the trustee operates a family office as an internal unit to manage the trust assets (not providing asset management services to a third party)
2. The family office is established as a separate legal entity which is wholly owned by a trustee or a company that holds the assets of the family (qualifying for the intra‐group carve‐out as full discretionary investment manager)

If a family office provides services to clients who are not related entities, it will be required to be licensed and the type of SFC licence required depends on the services to be provided in Hong Kong.

For more information, family offices may refer to Securities and Futures Commission (SFC)’s circular on the licensing obligations of family offices or contact SFC’s dedicated enquiry email address.

Circular: https://www.sfc.hk/edistributionWeb/gateway/EN/circular/doc?refNo=20EC1
Dedicated enquiry email address: enquiry.familyoffice@sfc.hk