Category: 3. Business

5 January 2026

On 8 December 2025, the Competition and Consumer Commission of Singapore (“CCS”) issued a press release announcing that it has found that two retailers of consumer electronics and home appliances, Courts and PRISM+, have used website design features that mislead consumers.

This article summarises CCS’ findings.

“Sneak into basket”

CCS found that Courts engaged in unfair trade practices by charging consumers for products that they had not selected. During certain promotional periods, Courts’ website included additional items into online shopping carts without the consumer’s consent. For example, after a consumer selected an Apple iPad for purchase, an Acer vacuum cleaner also appeared in the cart.

The CCS press release explains that this practice puts consumers at risk of unknowingly paying for unsolicited items if they fail to notice and remove such items from their online carts before checking out.

CCS intervened in June 2025 and Courts has given an undertaking to cease this practice immediately. In addition to making changes to its website, Courts also agreed to refund customers affected by this unfair trade practice.

“False urgency”

In a separate matter, CCS reviewed certain website design features on PRISM+’s website that were found to create urgency cues during the online purchasing process that could influence consumer purchasing decisions.

The features identified included the following:

• Countdown timers on checkout pages displaying messages such as “Popular items are selling fast! Purchase within the next [timer] minutes to secure stock and avoid losing out”. The timers were not connected to inventory systems and reset automatically upon reaching zero without affecting the checkout process.
• Stock availability indicators stating “In Stock: Running Low” on product pages, even where inventory levels remained substantial. In one instance, the indicator was displayed although monthly sales accounted for only 7% of total available stock. PRISM+ explained that the indicator was applied to products with inventory levels above 100 units; this threshold was not disclosed on the website.
• Statements suggesting market-wide shortages, including references to supply chain disruptions and industry-wide stock shortages. When queried, PRISM+ was unable to substantiate these statements and indicated that they were made in the context of the Covid-19 pandemic.
• Discount representations such as “Up to 67% off” for certain products, where the stated maximum discount was not achievable based on the strikethrough prices shown. In one example, the actual discount amounted to 38%. PRISM+ attributed these discrepancies to technical errors.

PRISM+ has since rectified the relevant website features and provided an undertaking to CCS that it will not engage in unfair trade practices.

CCS advice to businesses and consumers

CCS also encouraged consumers to remain vigilant when shopping online, including reviewing their shopping carts for unexpected items, verifying that payment amounts match intended purchases, and questioning the authenticity of urgency claims before making impulse purchases.

CCS stated that these two interventions form part of its broader enforcement actions against businesses that employ misleading website design features, known as “dark patterns”, to pressure consumers into unintended purchases.

Scott Clements, Partner of Allen & Gledhill’s Competition & Foreign Investment Review Practice, commenting on the expansion of CCS’ regulatory function over consumer protection on 1 July 2025: “The exercise by CCS of its consumer protection powers in the first six months has been noteworthy but unsurprising. CCS had similarly been purposeful in taking on competition infringements since its inception while concurrently setting out its enforcement philosophy. With those foundations, the Commission has, in the last two decades, built on its track record by taking on increasingly sophisticated and complex antitrust cases.”

Reference materials

The following materials are available on the CCS website www.ccs.gov.sg:

Baker McKenzie Wong & Leow, the Singapore member firm of Baker McKenzie, has appointed Kelvin Poa as Country Managing Principal, effective 1 January 2026. Kelvin succeeds James Huang who successfully concluded his term on 31 December 2025, having led the office since 1 January 2023.

Kelvin is a highly regarded lawyer with more than 27 years of experience in investment funds and employment law. He currently heads the Funds and Employment practice groups at Baker McKenzie Wong & Leow, advising venture capital, private equity, and real estate clients on structuring investments, acquisitions, restructurings, and exits. Kelvin also supports asset management clients in navigating transformational transactions and complex reorganizations.

In the employment space, Kelvin provides strategic advice on non-contentious matters, including contracts, separation agreements, and restrictive covenants such as non-solicitation and non-competition terms.

Commenting on his appointment, Kelvin said: “I’m honoured to have been appointed as Country Managing Principal and thank my fellow principals for their trust in me. I would also like to express my appreciation to James for his leadership over the past years, guiding the Firm through post-COVID workplace changes and our office move. I look forward to working closely with our global and regional teams to deliver seamless client outcomes in today’s dynamic market.”

James said, “I congratulate Kelvin on his appointment. His leadership and expertise in the funds and employment space will undoubtedly take the Firm to even greater heights alongside Singapore’s growth as a regional gateway for international investments, talent development, and workplace transformation.”

Billionaires Alex and Vanessa Birkenstock, of the German leather sandal-family, are the buyers of an $85m Rose Bay mansion that sold in the days leading up to Christmas.

The last-minute purchase was the highest residential sale for 2025.

The couple, who were living in Melbourne, have been looking to buy in Sydney for several years with a budget of up to $200m.

Alex has long dreamt of sailing on Sydney Harbour. And with their daughters starting at the exclusive Rose Bay school Kambala this year, the search via top buyer’s agent Simon Cohen gathered pace in the last months of 2025.

With Cohen last spotted in the Maldives and the sales agents, Brad Pillinger of Pillinger and Steven Chen of The Agency, remaining tightlipped on their purchasers, it was left to other sources to spill the beans exclusively to News Corp.

MORE: George Clooney’s new French home

MORE: Packer’s plan for $60m backyard

They’d had their eye on the five-bedroom residence known as Bayview Hill House in Bayview Hill Rd since its May listing with a $90m guide.

Vanessa, a British-German model, who had lived in Australia between 2002 and 2012 before she met her German husband, appeared in campaigns for Kenzo, Myer and Bettina Liano.

She was seen viewing the property late last year with Cohen and loved it so much that she asked her husband to jump on a plane and take a look.

The luxury home was owned by Lawrence Myers, chief executive of James Packer’s family office Consolidated Press Holdings, and his wife, Sylvia.

On a 1039sqm block, the grand property, designed by David Walker and Peter Janks, has incredible views of the Harbour Bridge from nearly every room — even the bathtub and gym.

There’s also a spectacular wet-edge pool with spa and cabana.

The Myers had bought it from retailer Brett Blundy for $43m in 2018.

The sale slotted in at No.2 in the top 20 sales across the country for the year, with Pillinger having been behind both of the two top Sydney deals, this one for $85m and the third top sale nationwide at $82.5m.

Michael Pallier, of Sotheby’s, who had $1bn in sales last year, was the agent for six of the top sales.

The Birkenstocks had also taken a look at the Barangaroo penthouse, which also appears in the top 10 at $80m.

Alex and his brother Christian were reported as having been worth US$3.4bn in 2023 after they sold a majority of their stake in the family business a $4.7bn deal two years before.

The footwear company dates from 1774, with Alex, Christian and their brother Stephan taking control from their father, Karl, in 2002.

Stephan sold his share in 2013.

Alex, 57, reportedly also owns property in New York, Miami and southern Germany.

MORE:

Ian Thorpe’s big windfall

Almost $300 million in refunds, dividends and cheques remain unclaimed by households and businesses across New South Wales, with locals urged to take action to secure the money they are owed.

Unclaimed cash is held by businesses and can accumulate when money is unable to be returned due to missing paperwork or contact information.

Money is then passed on to Revenue NSW when further attempts to return the funds are unsuccessful.

Areas with the most unclaimed cash include Sydney’s CBD and eastern suburbs, where more than $91 million in total is waiting to be snapped up by rightful owners.

About $76 million of the money is located in Western Sydney, with $22 million held in the Central Coast and the Hunter.

Some of the individual unclaimed items are valued in the millions of dollars.

Minister for Finance Courtney Houssos said there were more than 800,000 individual payments that remained unclaimed.

“This is money that belongs to residents of New South Wales, and we want to get that money back to you,” she said.

“It ranges from a few dollars to much larger amounts, but we encourage you to jump online and to check it out.

“This might be that little bonanza that you are waiting for.

“All you need to do is jump onto the website and search your name.”

Money unclaimed for years

Revenue NSW holds an additional $394 million for people registered at addresses outside the state.

Ms Houssos said some of the money had been sitting unclaimed for “many, many years”, with changes implemented to limit the amount of time businesses could hold onto cash.

“We’ve also made some legislative changes that mean businesses can only hold onto money for two years instead of six years to make it again easier for people to get access to their money,” she said.

“We think it’s really important that businesses return that money. If they’re not able to, they return it to the government, and we use our efforts to try and get that money back to residents.

“Even if someone has passed away, and you’re able to inherit that money, there is also a mechanism for you to access it.”

Last year, more than $21 million in unclaimed cash was returned to NSW households.

Anyone who suspects they may not have received money they are owed can visit the Revenue NSW website, where they will be asked to verify their identity and connection to the money.

Laing O’Rourke, as part of MetroVista led by Gamuda, has been awarded the contract to deliver the Sydney Metro West Stations Package West project.

The Sydney Metro West Stations Package West project includes the design and construction of five new underground metro stations and associated precincts at Westmead, North Strathfield, Burwood North, Five Dock, and The Bays. The opening date for the new Metro West Line is targeted for 2032.

As Delivery Partner for Gamuda, Laing O’Rourke will leverage extensive experience in managing multi-billion-dollar programs to oversee program management of the five non-integrated stations. In addition to the role as a Delivery Partner, Laing O’Rourke will be the Managing Contractor responsible for delivering Five Dock Station.

This integral station will deliver rail to Five Dock for the first time, providing residents and businesses with fast, direct access to the Sydney CBD and other parts of the metro network. The complex station construction is well suited to Laing O’Rourke’s commitment to modern methods of construction and leverages experience from the world-class Central Station Metro project.

Five Dock Station marks our fifth Sydney Metro project, reinforcing our reputation as a trusted partner in delivering complex, city-shaping infrastructure.

“We are proud to play a key role in delivering Metro West, a project that will transform how Sydney moves and connects. Our partnership with Gamuda combines global expertise and local capability to ensure this landmark infrastructure project is expertly managed and delivered to the highest standards,” said Mark Dimmock, Laing O’Rourke Managing Director – Australia.

_________________

About Sydney Metro

Sydney Metro is Australia’s biggest public transport project; building, operating and maintaining a network of four metro lines, 46 stations and 113km of new metro rail to revolutionise how Sydneysiders travel in Australia’s biggest city.

Metro trains are now running from Sydney’s booming Northwest region under Sydney Harbour, through new underground stations in the CBD.

Sydney Metro enhances public spaces with vibrant transport precincts, acting as a catalyst for renewal and better connections.

The metro program creates and supports new communities, improves amenities, and delivers new integrated station developments.

2025: A Year of Good Performance

• Performance in 2025 was good, with a Group order backlog of 11.5 trillion yen.
• We will now continue to live up to the expectations that the market has for us.

2026: Put ITO into Practice

• In 2026, I hope that we can put into practice the principle of Innovative Total Optimization (ITO) and pursue great reforms to position MHI Group to bring in higher profits and achieve greater growth in a self-reinforcing positive cycle.
• First, total optimization will halve lead times and enhance operational productivity. In doing so, we aim to generate 100 billion yen in incremental business profit – which is equivalent to 2% of annual Group revenue – going forward.
• Further, we will make concrete the growth strategies of each business for domain expansion.

Treat Changes as Chances and Create Business Opportunities

• Our business environment remains highly uncertain.
• However, we must not allow fear to keep us from changing our ways. Instead, we should view change as the new normal and embrace it as a significant opportunity. We ourselves must adapt flexibly, manage the risks accompanying change, and create new business opportunities. Learn to enjoy the change and find the positive aspects.

Three Requests to Enable MHI Group to Continue Growing in an Uncertain Business Environment

• Think Big, with the Entire Group in Mind
  Take the time to look up from your day-to-day work and act with pride as a member of the larger team that is MHI Group. Within the Group, there are hundreds to thousands of people working in the same field as you. Imagine building a community within each of those sub-fields to transform your work practices through the ITO principle of total optimization.
  By broadening your perspective to encompass enhanced value chain collaboration, cross-departmental communication, and proactive market analysis, you will find it easier to identify what challenges you should be working on.
• Think from the Customer’s Perspective
  Focus on what benefits your customers, not just what suits our Group.
  To do this, you need to truly understand your customers. Ask yourself if you know their top concerns and challenges, and whether they are dissatisfied with us, and engage in active communication. The ITO principle of domain expansion begins with fully understanding our customers’ needs and preparing solutions for them. Since customer needs are constantly changing, we must expand the scope of our work accordingly.
• Iterate Quickly, Beginning with the Things Closest to You
  When starting something new, it’s crucial to begin small and move quickly. Formulate your own hypotheses and verify their effectiveness within a limited scope.
  MHI Group’s products and services really do move the world forward. However, the first step is always a small one, taken at scale where you can still look all of your colleagues in the eye. Find joy in the process of making small improvements (“Kaizen”) and seeing their effects, and in trying new things in rapid succession.

　

Since becoming president, I have had the opportunity to visit many domestic and international bases and Group companies. Seeing all of you working with such a bright and positive attitude fills me with great pride.
I am convinced once again that we can achieve significant growth. This year too, let us move the world forward through our work.

SEOUL, January 5, 2026 – Hyundai Motor Group (The Group) today shared its 2026 strategic vision with global employees, with Executive Chair Euisun Chung presenting priorities focused on continuous customer-focused transformation, strengthened ecosystem competitiveness, and AI-driven innovation to navigate evolving market dynamics and lead new industry standards.

During his new year remarks, Executive Chair Chung presented five key strategic priorities — customer-focused evolution, agile decision-making, ecosystem competitiveness, bold collaboration, and leading new industry standards — to navigate the evolving global landscape.

Driving Transformation Through Customer Focus

Executive Chair Chung opened by expressing gratitude to employees and customers, acknowledging 2025’s unprecedented business environment changes while thanking employees for their exceptional performance and customers for their continued trust. He noted that 2026 will bring both headwinds and opportunities as the global business landscape continues to evolve rapidly.

Chung emphasized continuous transformation driven by customer insights. “When conditions get tough and competition fierce, our greatest strength will be our ability to continuously evolve by staying close to our customers,” he said.

Specifically, he encouraged employees to take a moment and assess some fundamental questions: “Did we thoroughly reflect customers’ perspectives in our products? Did we ever compromise in the process of planning or development? Can we confidently speak of our quality in front of customers? Through these questions, we can look back upon ourselves squarely and strive for progress, thereby keeping ourselves resilient against any challenges,” he said.

Agile Decision-Making Through Direct Engagement

Executive Chair Chung welcomed transformation in work methods and leadership. “Leaders must step out into the field, engage directly with people, and understand the essence of situations firsthand,” he said.

He emphasized the importance of speed and clarity in organizational operations. “Above all, what matters most is fast and clear communication, and agile decision-making that is free from formality. Let us work more efficiently,” he said, highlighting that by fresh thinking of its approaches, the Group can continue to achieve innovation.

Building Competitive Advantage Through Ecosystem Strength

Executive Chair Chung reinforced the importance of ecosystem strength, noting that Group businesses such as vehicle and humanoid robot manufacturing each involve tens of thousands of components, requiring exceptional performance and quality across the entire production chain.

“The strength of our supply ecosystem directly amplifies our competitive advantage. Sustainable growth is possible only when the whole ecosystem stays healthy,” he said.

Bold Collaboration for AI-Driven Transformation

Executive Chair Chung emphasized that as AI technology rapidly develops and competitive dynamics shift, the global manufacturing industry is undergoing a major transition. He highlighted the need to advance through bold collaboration with diverse partners in navigating this AI-driven transformation.

“Looking at the automotive market alone, we’ve entered an era where core product competitiveness is determined by AI capabilities,” he noted. Chung emphasized that Hyundai Motor Group is rapidly building capabilities to compete at the highest level, leveraging world-class product design and manufacturing expertise, plus valuable data from manufacturing sites and user experiences.

He shared his strong belief in the Group’s competitiveness in the physical AI field and how this will continue to grow to serve customers. “We possess world-class capabilities in the design and manufacturing of physical products. If we envision a bigger future and boldly expand collaboration with various partners to broaden the industrial ecosystem, I am confident we will deliver greater value to customers,” he said.

Executive Roundtable Focuses on AI Integration and Strategic Execution

Following Executive Chair Chung’s remarks, an open roundtable discussion was held with key executives, including Group Vice Chair Jaehoon Chang, Hyundai Motor Company President and CEO José Muñoz, Kia Corporation President and CEO Ho Sung Song, Hyundai Mobis Co. President and CEO Gyu Suk Lee, and Hyundai Motor Group Presidents Luc Donckerwolke, Sung Kim, and Manfred Harrer. The session was moderated by Executive Vice President and Head of Corporate HR, Hae In Kim. The discussion, informed by an employee survey of more than 7,200 participants globally, addressed future readiness, technology development strategies, and organizational culture.

Executive Chair Chung elaborated on AI’s strategic importance, defining it not as plug-and-play technology but as a force fundamentally reshaping how companies and industries operate. He explained AI is the first technology in human history that can independently define problems and create new knowledge, emphasizing companies excelling in AI internalization will define the industry’s future.

He highlighted that as momentum shifts toward physical AI, Hyundai Motor Group’s data from vehicles, robots, and manufacturing processes becomes increasingly differentiated. “Our future hinges on whether we treat AI as a tool or adopt it as the engine of organizational evolution. The only way for us to sustain our position as a global leader in the years ahead is to embed AI into our organizational DNA, not borrowing it from the outside,” Executive Chair Chung said.

Reinforcing Digital Transformation, Robotics, and Hydrogen Leadership

Vice Chair Jaehoon Chang reinforced the Group’s commitment to digital transformation, emphasizing that the transformation to a software-driven mobility company is essential to its future success and industry leadership.

“I believe that what we have built so far in the unexplored realm of SDV will become a solid foundation for the future envisioned by Hyundai Motor Group. We are still in the stage of perfecting our developments, and we are steadily preparing to deploy SDV across various vehicle models,” he said.

He added that the collaboration framework with 42dot remains unchanged, and major development projects incorporating SDV technology will proceed as planned.

Regarding the Group’s robotics initiatives, Vice Chair Chang detailed progress in physical AI development. “Through our collaboration with Boston Dynamics, we are jointly advancing hardware and physical AI, combining world-class robotics R&D with manufacturing expertise,” he said. He noted that logistics robot Stretch and quadruped robot Spot are already gathering real usage data both inside and outside the Group, steadily improving their performance, safety, and cost competitiveness. Humanoid robot Atlas is expected to help people move away from hazardous environments and repetitive tasks, enabling them to focus on creative, high-value roles.

He also highlighted the Group’s comprehensive leadership across the hydrogen value chain. “Hydrogen serves as both an energy carrier and storage solution that complements renewable energy and enhances efficiency. Beyond hydrogen mobility, our Group is leading the entire value chain from production to storage and industrial applications,” Vice Chair Chang said, noting that the Group’s hydrogen achievements are gaining increasing global recognition.

Business Leaders Outline Growth Strategies and Technology Advancement

Hyundai Motor Company CEO José Muñoz outlined growth strategies, saying: “We are minimizing the tariff impact through our localization plans and supply chain restructuring, while continuing to strengthen the areas where we lead.”

Kia Corporation CEO Ho Sung Song highlighted ambitious targets for the year ahead. “Kia has established very ambitious plans with a growth target of over 6 percent this year,” he said, outlining plans to continue expansion of Kia’s PBV ecosystem, centered on the award-winning PV5, and launch volume models including the new Kia Telluride and Kia Seltos SUVs.

Hyundai Mobis Co. CEO Gyu Suk Lee outlined the company’s strategic role. “As Hyundai Motor Group’s core parts company, Hyundai Mobis will play a major role in stably supporting new architectures and the mass production and expanded deployment of SDV,” he said.

President and Head of Strategy and Planning Division Sung Kim addressed global risk management amid low-growth trends. He emphasized enhancing the ability to “anticipate and respond more quickly to global economic and geopolitical developments through sustained monitoring and closer coordination across the group,” adding that the company is working to turn challenges into opportunities for growth.

President and Head of R&D Division, Manfred Harrer provided updates on technology development. “Through the ‘SDV Pace Car’, we are proceeding with the establishment of a mass-production system and verification as originally planned. The tech capabilities secured through this process will be applied to next-generation models,” he said.

Executive Vice President and Head of Corporate HR, Hae In Kim emphasized organizational resilience. “It’s important we learn from experience and transform this into forward momentum. In that process, we must recognize each other’s differences and collaborate by combining our respective strengths,” she said.

President, Chief Creative Officer and Chief Design Officer Luc Donckerwolke encouraged bold innovation, stating that a challenge is “an opportunity to realize our dreams,” and added, “It is the time to reset, disrupt, and innovate.”

Leading New Industry Standards

Executive Chair Chung concluded by encouraging the Group to lead new industry and product standards, emphasizing the opportunity to build a future providing superior value and customer experiences.

Quoting Founding Chairman Ju-yung Chung’s philosophy — “If there is no path, find one. If you cannot find one, make one. As long as I do not think it is a failure, it cannot be a failure” — he inspired employees, noting the strongest force driving Hyundai Motor Group lies in the spirit of perseverance and drive to overcome challenges. “I invite you all to join this journey of transformation with passion and commitment,” he remarked.

He concluded the roundtable by stating, “I feel confident and energized because of this team, because of all of you. And as I mentioned earlier, the passion grows even more thanks to customers who recognize and love what we create. That makes me want to do even better, together.”

Hong Kong, Jan. 5, 2026 (GLOBE NEWSWIRE) — FTI Consulting, Inc. (NYSE: FCN) today announced further investment in its Forensic and Litigation Consulting segment in Asia with the appointment of Mavis Tan as a Senior Managing Director.

Ms. Tan specialises in forensic accounting, dispute support and investigations. She rejoins FTI Consulting in Hong Kong from Control Risks, where she led the firm’s forensic services practice for Greater China and North Asia. She will work closely with clients to address allegations involving accounting improprieties, conflicts of interest, misappropriation of assets and circumvention of regulations.

“We are thrilled to welcome Mavis back to FTI Consulting,” said Michael Cullen, Leader of Asia and Latin America for the Forensic and Litigation Consulting segment at FTI Consulting. “Her addition continues to enhance the leadership position we are building in the investigations market in Asia and the capabilities we have globally. That depth is unmatched, allowing us to help clients navigate crisis and opportunities in the region and around the world.”

Ms. Tan brings more than 20 years of experience as an accountant and has led high-profile and confidential internal and regulatory investigations in the Asia Pacific region. She has assisted high-net-worth individuals and listed multinational companies in responding to complex financial disputes and whistleblower allegations of fraud and corruption, including acting as an expert witness in civil and criminal proceedings.

Ms. Tan also has significant experience conducting forensic due diligence and risk assessments for substantial financial transactions and helping multinationals remediate internal control gaps after an investigation or acquisition.

“I am excited to rejoin FTI Consulting during this pivotal time of transformation and opportunity,” Ms. Tan said. “Renowned for its impact on high-stakes matters globally, FTI Consulting brings together exceptional experts, innovative technology and a culture of integrity to resolve complex financial disputes and uncover the truth. Working alongside industry leaders on headline investigations and disputes allows me to deliver precise, impartial and meaningful results for clients.”

The addition of Ms. Tan continues FTI Consulting’s investment in multidisciplinary expertise in forensic accounting, investigations, data analytics and regulatory compliance in Asia. Within the past six months, the firm has added Rosie Hawes, Andrew Macintosh and Martin Tupila in Singapore.

FTI Consulting’s Asia-based team of forensic accountants, financial experts, data analysts, technologists, statisticians, economists and business intelligence professionals analyse complex data and apply proven investigative and forensic accounting methods to support legal teams and act as independent investigators and experts.

About FTI Consulting
FTI Consulting, Inc. is a leading global expert firm for organizations facing crisis and transformation, with more than 8,100 employees located in 32 countries and territories as of September 30, 2025. In certain jurisdictions, FTI Consulting’s services are provided through distinct legal entities that are separately capitalized and independently managed. The Company generated $3.70 billion in revenues during fiscal year 2024. More information can be found at www.fticonsulting.com.

FTI Consulting, Inc. 
555 12^th Street NW
Washington, DC 20004
+1.202.312.9100

Investor Contact: Mollie Hawkes
+1.617.747.1791
mollie.hawkes@fticonsulting.com

Media Contact: Matthew Bashalany
+1.617.897.1545
matthew.bashalany@fticonsulting.com

Source: FTI Consulting, Inc.

Client Alert  |  January 5, 2026

---

This update provides a detailed overview of the key takeaways for the industry from the Consultation Conclusions and the Further Consultation.

On December 24, 2025, the Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) published consultation conclusions on legislative proposals to regulate virtual asset (VA) dealing (VA Dealing Conclusions) and custodian service providers (VA Custody Conclusions) in Hong Kong (collectively, the Consultation Conclusions).[1] The Consultation Conclusions follow the FSTB and the SFC’s joint consultations on VA dealing (VA Dealing Consultation) and custodian (VA Custody Consultation) regimes launched on June 27, 2025 (as discussed in our previous client alert).

In parallel with the release of the Consultation Conclusions, the FSTB and the SFC have also commenced a further public consultation on new licensing regimes for providers of VA advisory and management services (the Further Consultation).[2] Comments in relation to the Further Consultation are due by January 23, 2026.

The short timeframe for comments on the Further Consultation reflects the FSTB and SFC’s eagerness to progress the implementation of these regimes as a matter of priority, with the FSTB and SFC also flagging in the Consultation Conclusions that they intend to introduce a bill into the Legislative Council in 2026 to implement the VA dealing, custodian, advisory and management service licensing regimes through amending the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (AMLO). This is consistent with the SFC’s continued efforts throughout 2025 to implement its ASPIRE Roadmap and support the development of the virtual asset industry in Hong Kong.[3]

We have set out below a detailed overview of the key takeaways for the industry from the Consultation Conclusions and the Further Consultation.

I. VA DEALING CONCLUSIONS

A. Scope and Coverage

As expected and supported by the industry, the SFC has clarified that the scope of the VA dealing definition under the AMLO will be aligned with the definition of Type 1 regulated activity (i.e. dealing in securities) under the SFO. In other words, the definition will cover any person, by way of business, making or offering to make any agreement with another person, or inducing or attempting to induce another person to enter into or offer to enter into an agreement, with a view to acquiring, disposing of, subscribing for or underwriting VAs (VA Dealing Services). However, in a significant shift from the definition proposed in the VA Dealing Consultation, the definition of VA Dealing Services will not cover making or offering to make an agreement where the purpose or pretended purpose of which is to secure a profit to any of the parties from the yield of VAs or by reference to fluctuations in the value of VAs. In carving out this activity from the definition of VA Dealing Services, the FSTB and SFC have noted that they consider these types of activities to generally be activities involving derivatives and structured products referencing VAs which in their view will generally fall within Type 1, Type 2 or Type 11 regulated activity under the SFO. The new licensing regime also will not cover providers dealing solely in tokenized securities (which will be covered under the SFO instead).

Frustratingly for the industry, the only clear exemption outlined by the FSTB and SFC from the definition of VA Dealing Services is for stablecoin issuers licensed by the Hong Kong Monetary Authority (HKMA) and conducting regulated stablecoin activity. All other potential exemptions discussed in the VA Dealing Conclusions – such as for those transactions conducted through SFC-regulated VA dealers, transactions as principal, intra-group transactions, use of VA for payments for goods or services, and incidental dealing by VA managers (as discussed in the Further Consultation), distribution of VAs generated as rewards for ledger maintenance and for VA issuers in relation to activities regarding VAs created by them – remain merely ‘under consideration.’

The VA Dealing Conclusions also indicate that a range of other topics relevant to the scope and coverage of this regime remain pending further consideration, including the following:

• while the provision of margin trading in VA will fall within the definition of VA Dealing Services, there is some uncertainty at this stage as to whether the SFC will ultimately permit licensed VA dealers to provide margin trading, with the VA Dealing Consultation flagging that this (along with applicable regulatory requirements) ‘will be carefully assessed taking into account various factors such as client credit risk, liquidity risk and concentration risk, capital requirements, risk capital charges and operational controls requirements’; and
• activities such as VA staking and VA borrowing and lending ‘will also be considered’.

The VA Dealing Conclusions also note that the SFC will take a ‘substance over form’ approach to the definition of VA Dealing Services, as the paper flags that whether the provision of peer-to-peer transactions or the provision of decentralized or ‘technological’ services will require a licence will depend on the substance of the activities (rather than the form or terminology used to describe the service) and whether the service is carried on as a business.

B. Dealing of VA through non-SFC licensed VATPs or liquidity providers

One of the most welcome developments in the VA Dealing Consultation for the industry was the suggestion that the FSTB and SFC would consider allowing licensed VA dealers to acquire or dispose of VAs for clients via non-SFC licensed virtual asset trading platforms (VATPs) or liquidity providers, subject to appropriate safeguards. Despite the ‘vast majority’ of respondents supporting this proposal, the FSTB and SFC appear to have now backed away from embracing this development, notwithstanding the SFC’s aim to integrate Hong Kong with global liquidity under the ASPIRE Roadmap. Instead, the VA Dealing Conclusions refer to the SFC’s recent decision to allow SFC-licensed VATPs to integrate with intra-group liquidity via a shared order book.[4] However, given that this particular reform was only introduced comparatively recently, we consider it unlikely that the levels of liquidity available through SFC-licensed VATPs using shared order books will be considered by the industry to be a sufficient substitute for being allowed to trade via non-SFC licensed VATPs or liquidity providers globally. Given this we expect continued pressure from the industry for the SFC to relax this requirement going forward.

The VA Dealing Conclusions do also indicate that ‘looking ahead’, the SFC will continue to incorporate market feedback through directly engaging with the industry and applicants via the pre-application process, and in doing so will ensure that ‘the SFC’s requirements are both practical and appropriately tailored to the diverse range of VA service providers’.

C. Holding of client VAs with SFC licensed VA custodians

The VA Dealing Consultation asked for respondents to advise as to what a ‘commercially viable and AML compliant operational flow to conduct VA dealing activities’ would look like if licensed VA dealers were required to hold client VAs only with SFC-licensed VA custodians.

The VA Dealing Conclusions note that a number of respondents supported this proposal in order to provide stronger assurance of safe custody, while others supported allowing firms to custody client VAs with licensed custodians regulated in jurisdictions which adhere to the standards of Basel Committee on Banking Supervision, International Organization of Securities Commissions or the Financial Action Task Force and also adhere to comparable standards of investor protection measures.

The FSTB and SFC have acknowledged the ‘diverse’ perspectives of respondents on this particular point, and indicated that they will take comments into consideration in formulating the relevant regulatory requirements in order to appropriately balance investor protection, market efficiency and commercial viability. However, given that overseas regulation of custodians remains in a comparatively early stage of development, the SFC will require licensed VA dealers to custody client VAs with SFC-regulated VA custodians. Notwithstanding this, the SFC will consider the operational feasibility of this requirement for payment facilitation or short-term settlement and will take the comments on these points into consideration in formulating the regulatory requirements that will apply to licensed VA dealers.

D. No Transitional Period

Consistent with the position outlined in the VA Dealing Consultation, the FSTB and SFC have indicated that there will be no deeming arrangement for existing VA dealers. Instead, the licensing regime will take full effect on the commencement date of the relevant statutory provisions. However, given the implications of a ‘hard’ commencement date, the Hong Kong Government and the SFC will consider an appropriate commencement date, taking into account the time market participants need to adjust their business models.

However, in the interim, the FSTB and SFC have encouraged entities already engaged in VA Dealing Services to reach out to the SFC or HKMA (as applicable) as soon as possible to initiate the pre-application process. During this early engagement, the SFC will walk pre-applicants through the application process.

An expedited licensing approval process will be available to SFC-licensed VATPs, licensed corporations and registered institutions currently providing VA Dealing Services to ensure a smooth transition to the new regime.

II. VA CUSTODY CONCLUSIONS

A. Scope and Coverage

The VA Custody Consultation originally proposed that a person would require a VA custodian service provider licence (VA Custodian Licence) if they, by way of business, safekept either (i) VAs on behalf of clients; or (ii) instruments enabling transfer of VAs of clients on behalf of clients. Taking into account the comments received and applying a risk-based approach, the FSTB and the SFC have decided to focus on limb (ii) of the originally proposed definition, such that a VA Custodian Licence will be required if a person safekeeps any instrument enabling the transfer of VAs for its clients (VA Custodian Services). The FSTB and SFC have indicated that this is intended to ensure that the licensing regime targets the ‘core risk area’ in VA custody (i.e. entities which safeguard private keys), rather than capturing as top layer trustees or fund managers which delegate the VA custody function to a third-party custodian and whose own role in VA custody is administrative and contractual.

Importantly, the VA Custody Conclusions have provided helpful guidance as to whether providers of multi-party computation (MPC) services or other technology services will require a VA Custody Licence. The FSTB and SFC have indicated that this will be considered on a case-by-case basis, with the focus being on whether a ‘person can unilaterally transfer its clients’ VAs’. In particular, the VA Custody Conclusions have indicated that:

• an MPC provider will not require a licence if its clients can transfer their own VAs (either together with the MPC provider or unilaterally) and its clients have the ability to reconstruct the complete private key independently or retrieve access to their VAs without support from the MPC provider (e.g., where its clients can export the full cryptographic key without involving the MPC provider);
• an MPC provider may require a licence if its clients cannot unilaterally transfer their VAs (e.g. where a recovery kit has not been provided by the MPC service provider); and
• that the SFC is likely to also take into consideration whether the MPC provider’s clients can independently access and manage their assets at all times.

We consider this guidance helpful on two fronts. First, the VA Custody Consultation’s clear discussion of the applicability of this regime to MPC providers indicates in our view that the SFC will allow the use of MPC solutions by the industry going forward. This is an important and welcome development given the SFC’s previous insistence that the associated entities of SFC-licensed VATPs use only Hardware Security Module (HSM) solutions to custody client VAs. Second, this guidance suggests that MPC providers which offer direct custody Wallets-as-a-Service or embedded wallet solutions should not require a VA Custodian Licence to provide such services or solutions to customers in Hong Kong.

Finally, the VA Custody Conclusions have helpfully flagged that the definition of VA Custodian Services is intended to be technology neutral, and that the SFC’s focus in determining whether a specific decentralized model or provider of a specific technological service will require a licence will depend on the ‘substance’ of the service provided. For example, a staking service provider which provides ‘custodial’ staking services through which it has the ability to unilaterally transfer client VAs will require a VA Custodian Licence. In contrast, a non-custodial wallet provider lacking the ability to transfer VAs will likely not require a licence.

B. Persons who will require a licence and licensing exemptions

The VA Custody Conclusions also provide a non-exhaustive list of entities that are likely to require a VA Custodian Licence:

• associated entities of SFC-licensed VATPs that currently provide VA Custodian Services under the VATP regime (and who wish to continue to do so in the future);
• SFC-licensed corporations which are licensed for Type 13 regulated activity under the SFO, as well as banks, subsidiaries of locally incorporated banks and stored value facilities, if they provide VA Custodian Services. This includes where such safekeeping is carried on as part of providing VA Dealing Services or acting as depositaries of SFC-authorised funds with VAs in the funds’ portfolios; and
• licensed or registered fund managers, if they self-custody VAs by way of safekeeping the private keys or similar instruments which enable the transfer of fund VAs. However, this may be subject to a limited exemption for self-custody of new tokens which may not be subject to established VA custody infrastructures, which is under consideration).

The FSTB and the SFC have also indicated that certain licensing exemptions will be provided, including but not limited to exemptions for:

• entities that only custody VAs for their group companies;
• stablecoin issuers licensed by the HKMA under the Stablecoins Ordinance (Cap. 656) which custody only the stablecoins that issued by them; and
• for legal and accounting professionals that may be appointed to hold the back up of private keys or similar instruments for their clients or appointed by a court to administer assets, including VAs.

C. Individual licensing regime

One of the most noteworthy aspects of the VA Custody Consultation was the suggestion that the SFC would require group entities and/or their personnel involved in the safekeeping of private keys by a licensed VA custodian to be licensed or accredited. This would have reflected a significant departure from the SFC’s approach to licensing of individuals and group entities to date.

The VA Custody Conclusions expressly acknowledge that ‘many’ respondents did not consider it necessary for group entities to obtain licenses, and that concerns were raised in consultation responses that requiring multiple entities from the same corporate group to be licensed would lead to inefficiencies and regulatory overreach. Consistent with this feedback, the VA Custody Conclusions establish that:

• SFC-regulated VA custodians can rely on their overseas group resources and infrastructure without automatically triggering a requirement for group entities to be licensed, provided that the SFC-regulated entity retains the ability to ‘independently and unilaterally move or transfer’ client VAs; and
• Overseas group entities must not market themselves to the public of Hong Kong as licensed by the SFC unless they are in fact licensed by the SFC.

Interestingly, the latter statement suggests that the SFC will be willing to licence entities based offshore. This would be a notable departure from the traditional approach taken by the SFC under the SFO to licensing only entities providing regulated activities in Hong Kong.

The VA Custody Conclusions also establish that all individuals performing ‘core custody functions’ throughout the custody chain will also need to be individually licensed, and identify the following individuals in particular as requiring individual licences:

• senior management responsible for monitoring and supervision of the VA custodian;
• individuals who have direct access to private keys or the authority to initiate or approve VA transfers (i.e. including but not limited to the initiator and intermediate approvers);
• personnel participating in multi-signature or threshold signing schemes; and
• individuals with access to private key generation, storage or recovery systems.

The FSTB and SFC have also indicated that they expect only responsible officers (or executive officers for HKMA-registered VA custodians), managers-in-charge (or relevant managers HKMA-registered VA custodians) and their delegates to be authorized to carry out the above functions. Additionally, individuals employed by group entities of the SFC-regulated VA custodian who are authorized to carry out these core custody functions must be accredited to the SFC-regulated VA custodian, and a proper delegation of authority from the licensed entity to the individual employed by the group entity must be obtained before the individual can access the private key or sign VA transactions.

Helpfully, the VA Custody Conclusions establish that individuals engaged in clerical roles (i.e. performing routine tasks following established procedures such as document filing or data input) will not require licences, nor will staff members of internal corporate functions of a VA custodian (e.g. those in HR, finance and accounting, legal and compliance roles). This is consistent with the approach taken by the SFC to the licensing of individuals under the SFO more broadly.

D. No Transitional Period

Consistent with the position outlined above in relation to the VA Dealing Services licensing regime, there will be no deeming arrangement for existing VA custodians. Instead, the licensing regime will take full effect on the commencement date of the relevant statutory provisions.

However, an expedited licensing approval process will be provided to associated entities of SFC-licensed VATPs, banks or subsidiaries of locally incorporated banks which have already undergone the SFC’s or the HKMA’s assessment process in relation to their VA Custodian Services and are already engaged in providing such services.

III. SUMMARY OF THE FURTHER CONSULTATION ON THE VA ADVISORY AND MANAGEMENT SERVICES LICENSING REGIMES

In response to industry feedback for clarification on the treatment of entities providing VA advisory and management services under the VA Dealing Services licensing regime, the SFC and the FSTB have indicated that they now intend to license VA advisory and VA management services as separate regulated VA services under the AMLO. This will mirror the existing securities licensing regime applicable to licensed corporations under the Securities and Futures Ordinance (Cap. 571) (SFO).

A. VA advisory service licensing regime

The Further Consultation proposes that any person who carries on a business of providing VA advisory services in Hong Kong (VA Advisory Services) must be licensed by or registered with the SFC. The proposed definition of ‘advising on VA’ mirrors the definition of ‘advising on securities’ under the SFO – i.e:

• giving advice on whether; which; the time at which; or the terms or conditions on which, VAs should be acquired or disposed of; or
• issuing analyses or reports, for the purposes of facilitating the recipients of the analyses or reports to make decisions on whether; which; the time at which; or the terms or conditions on which, VAs are to be acquired or disposed of.

The FSTB and SFC have proposed providing a range of similar exemptions to those available in relation to Type 4 regulated activity under the SFO, namely, exemptions for:

• the provision of VA Advisory Services solely to wholly-owned group companies;
• VA Advisory Services that are wholly incidental to licensed VA dealing or solely for the purposes of licensed VA fund management;
• solicitors, counsels and certified public accountants for acts wholly incidental to their professional practice;
• VA Advisory Services that are wholly incidental to a registered trust company’s discharge of duty; and
• VA Advisory Services that are conducted through a generally available publication or broadcast.

The SFC and FSTB have indicated that the regulatory requirements to be imposed on VA advisors are expected to broadly follow the existing regulatory requirements on Type 4 licensed corporations or registered institutions providing VA Advisory Services pursuant to the SFC and HKMA’s Joint Circular on intermediaries’ virtual asset-related activities dated December 22, 2023 (December 2023 Joint Circular).[5]

B. VA management service licensing regime

The Further Consultation proposed that any person who carries on a business of providing VA management services in Hong Kong (VA Management Services) must be licensed or registered with the SFC. The proposed definition of ‘VA management’ mirrors the definition of ‘asset management’ under the SFO – i.e. the provision of a service of managing a portfolio of VAs for another person. This definition will likely capture VA portfolio management services and VA discretionary account management services (e.g. where a firm is delegated with discretionary power to make investment decisions in VAs for a fund).

The FSTB and SFC have proposed providing a range of similar exemptions to those available in relation to Type 9 regulated activity under the SFO, namely, exemptions for:

• the provision of VA Management Services to wholly-owned group companies;
• VA Management Services that are wholly incidental to VA Dealing Services of a licensed VA dealer;
• solicitors, counsels and certified public accountants for acts wholly incidental to their professional practice; and
• VA Management Services that are wholly incidental to a registered trust company’s discharge of duty.

Notably, the SFC and FSTB have proposed not setting a de minimis threshold (for instance, a stated investment objective or an intention to invest 10% or more of the gross asset value of a portfolio in VAs). This means that any entity providing asset management services for a portfolio that invests in VA will require a licence or registration, regardless of whether their portfolio has only a negligible exposure to VA. The FSTB and SFC have stated that their rationale for not setting a de minimis threshold is to uphold regulatory standards and investor protection, and to align with the licensing regime for asset management under the SFO as well as the VA Dealing Services licensing regime which does not provide for any de minimis thresholds.

We anticipate that the regulatory requirements applicable to SFC-regulated VA managers will ultimately broadly align with those applicable to Type 9 licensed corporations engaged in VA management activities under the December 2023 Joint Circular. These include requirements in relation to matters such as fund portfolio valuation and risk management.

Consistently with the position taken in relation to VA dealing, the Further Consultation flagged that the SFC is considering whether VA managers should be required to safekeep the VAs of the private funds they manage only with SFC-regulated VA custodians, or whether they should have flexibility to appoint any custodians. We expect this area to be subject to considerable industry feedback.

The Further Consultation helpfully acknowledged the challenges encountered by private equity and venture capital fund managers in their custody of new tokens which is not supported by SFC-regulated VA custodians. The SFC and FSTB indicated that they will consider allowing self-custody by these fund managers up to a limited threshold without the need to obtain a VA Custodian Licence.

C. No Transitional Period

Consistent with the position stated in the Consultation Conclusions, the FSTB and SFC have not proposed to provide a deeming arrangement to pre-existing VA advisors and pre-existing VA managers. Instead, the licensing regime will become fully effective on the commencement date of the relevant statutory provisions. Industry stakeholders are encouraged to reach out to the SFC or HKMA (as applicable) as soon as possible to initiate the pre-application process. Likewise, an expedited licensing approval process will be available to entities which have already undergone the SFC’s or the HKMA’s assessment process in relation to their provision of VA Advisory Services or VA Management Services and are already engaged in these activities.

IV. CONCLUSION

The Consultation Conclusions and the Further Consultation are welcome developments in the regulation of the crypto ecosystem in Hong Kong. However, with respect to the VA Dealing Conclusions, there are a number of aspects of the regulatory requirements that are still under consideration by the SFC. Industry stakeholders already engaged in or interested in providing VA Dealing and VA Custodian Services are encouraged to engage with the SFC as soon as possible. VA dealers and VA custodians who do not contact the SFC or HKMA (as applicable) for pre-application may suffer business disruptions, as they will have to stop operations on the commencement date of the licensing regime. Specifically, with respect to entities providing VA Dealing Services, the SFC has said that early engagement would provide invaluable feedback on the setting of applicable regulatory requirements.

[1] “Consultation Conclusions on Legislative Proposal to Regulate Dealing in Virtual Assets and Further Public Consultation on Legislative Proposal to Regulate Virtual Asset Advisory Service Providers and Virtual Asset Management Service Providers”, jointly published by the FSTB and SFC on December 24, 2025, available here (VA Dealing Conclusions); and “Consultation Conclusions on Legislative Proposal to Regulate Virtual Asset Custodian Services”, jointly published by the FSTB and SFC on December 24, 2025, available here (VA Custody Conclusions).

[2] See the VA Dealing Conclusions (see the link in footnote 1 above).

[3] See our previous client alerts in relation to the implementation of the ASPIRE Roadmap here.

[4] See our previous client alert here.

[5] “Joint circular on intermediaries’ virtual asset-related activities” jointly published by the SFC and HKMA on December 22, 2023, available here. See our previous client alert in relation to the December 2023 Joint Circular here.

---

The following Gibson Dunn lawyers prepared this update: William Hallatt, Emily Rumble, Arnold Pun, and Jane Lu.

Gibson Dunn’s lawyers are available to assist in addressing any questions you may have regarding these developments. If you wish to discuss any of the matters set out above, please contact any member of Gibson Dunn’s Financial Regulatory team, including the following members in Hong Kong:

William R. Hallatt (+852 2214 3836, whallatt@gibsondunn.com)

Emily Rumble (+852 2214 3839, erumble@gibsondunn.com)

Becky Chung (+852 2214 3837, bchung@gibsondunn.com)

Arnold Pun (+852 2214 3838, apun@gibsondunn.com)

Jane Lu (+852 2214 3735, jlu@gibsondunn.com)

© 2026 Gibson, Dunn & Crutcher LLP.  All rights reserved.  For contact and other information, please visit us at www.gibsondunn.com.

Attorney Advertising: These materials were prepared for general informational purposes only based on information available at the time of publication and are not intended as, do not constitute, and should not be relied upon as, legal advice or a legal opinion on any specific facts or circumstances. Gibson Dunn (and its affiliates, attorneys, and employees) shall not have any liability in connection with any use of these materials.  The sharing of these materials does not establish an attorney-client relationship with the recipient and should not be relied upon as an alternative for advice from qualified counsel.  Please note that facts and circumstances may vary, and prior results do not guarantee a similar outcome.