Hong Kong Substantiated One Complaint Over Suspected Unlicensed Payment Services

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Hong Kong Substantiated One Complaint Over Suspected Unlicensed Payment Services

Hong Kong details 16 complaints over suspected unlicensed payment services

Hong Kong regulators say they can intervene when a provider operates a stored value service without the required license. From January 2024 to September 2026, the Hong Kong Monetary Authority (HKMA) received 16 complaints about suspected unlicensed services and substantiated one. The complainant reported no financial loss.

  • One complaint was substantiated; the HKMA is following up with the company.
  • Payment, remittance, currency exchange and lending services are governed by different rules.
  • Check that a provider’s license covers the specific service it offers.

One case substantiated; enforcement outcome remains pending

In a written reply to the Legislative Council on Oct. 7, Hong Kong’s Financial Services and the Treasury Bureau said the HKMA had received 16 complaints about suspected unlicensed stored value services between January 2024 and September 2026. The authority substantiated one complaint. The complainant reported no monetary loss. The HKMA is following up with the company before deciding whether to take further action.

Acting Secretary Joseph Chan said the HKMA would intervene in suspected cases of unlicensed stored value facility operation or non-compliance with the relevant ordinance:

“In cases involving suspected unlicensed SVF operation or non-compliance with the PSSVFO, the HKMA will intervene directly.”

The reply does not name the company or explain what happened in the other 15 cases. It also does not show how common unlicensed services are or measure losses across the wider payments market.

The response followed a question from lawmaker Chan Chun-ying about payment aggregators. He raised concerns about providers offering merchants low fees and buy now, pay later (BNPL) options, along with reports of defaults and false payments that had caused merchant losses. These were concerns raised in the legislature. The reply gave no figures or specific cases to show how widespread the problems are.

Different payment services, different rules

Hong Kong does not have one blanket “payment license” for every business handling digital payments. The rules depend on what a provider does: hold value for payments, exchange currencies, send money across borders or lend.

Stored value wallets and prepaid cards

Under the Payment Systems and Stored Value Facilities Ordinance (PSSVFO), issuing or operating a stored value facility (SVF) in Hong Kong without a license is an offense, unless a statutory exemption applies. An SVF holds value for payments to its issuer and participating third parties, or for transfers between users. Multipurpose prepaid cards and electronic wallets are examples.

The HKMA says single-purpose facilities, which can only be used to buy goods or services from their issuer, do not fall under this licensing system. It also distinguishes SVFs from payment methods that do not hold stored value, such as credit cards and Apple Pay. What matters is how a payment method works. The brand name alone does not determine whether a specific service needs a license.

Consumers can check an SVF operator’s unique license number against the HKMA’s public register. The authority warns that users of wallets or prepaid cards operating outside Hong Kong’s licensing system may not have their interests protected. A polished app, or a claim to be a fintech company, does not prove that the provider has the required authorization.

Remittances, currency exchange and lending

Currency exchange and cross-border remittance businesses generally need a Customs and Excise Department license under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, unless an exemption applies. The government’s reply lists services ancillary to a licensed SVF operator’s business as one statutory exemption.

Lending has its own rules. Banks offering BNPL services remain under HKMA supervision. Other providers conducting a lending business must obtain a money lender license under the Money Lenders Ordinance. Calling a product “buy now, pay later” does not, on its own, determine which rules apply.

The government said licensing reviews assess applicants’ competence, integrity and ability to operate fairly. Requirements vary by regime and activity, but may include customer checks, record keeping and proper handling of client funds. These safeguards do not remove risk. They set standards and provide oversight that an unlicensed provider may not face in the same way.

A stablecoin license is not a general payment license

Hong Kong’s stablecoin regime is a separate part of its digital payments framework. Anchorpoint, a joint venture established by Standard Chartered Bank (Hong Kong), HKT and Animoca Brands, said it received an HKMA stablecoin issuer license in April 2026. Standard Chartered said Anchorpoint planned to issue HKDAP, a Hong Kong dollar-backed stablecoin, in phases through selected authorized distributors.

Anchorpoint named cross-border payments and the settlement and distribution of tokenized real-world assets as intended uses. Those are company plans, not proof of adoption, transaction volume or realized benefits. A stablecoin issuer license also covers only its own regulatory scope. It does not automatically authorize a company’s separate wallet, remittance, currency exchange or lending services.

How should merchants and consumers check a provider?

Start with the service, not the marketing label. Find out which legal entity holds customer funds, sends money, exchanges currency or extends credit, and which license covers each activity. Then check the relevant regulator’s register. For SVF operators, the HKMA says its public register can be searched by the operator’s unique license number.

Merchants should also find out when a payment becomes final, who takes the loss if it is reversed or turns out to be false, and what recourse is available if the provider fails. Low fees matter. But they are a poor bargain if the terms leave a business carrying unexpected losses.

Key questions, answered

  • How can I check whether a stored value operator is licensed?

    Check the operator’s unique license number in the HKMA’s public register. Make sure the listed entity is the same company providing the service.

  • Does one license cover every payment service a company offers?

    No. Stored value, remittances, currency exchange and lending have different requirements. Authorization for one activity does not automatically cover the others.

  • What happened after the substantiated complaint?

    The HKMA is following up with the company and will decide whether to take further action as the case progresses. The government reply did not announce a final enforcement outcome.

  • Does Anchorpoint’s stablecoin license authorize unrelated payment services?

    No. Its license covers stablecoin issuance. Other services may need separate authorization under different rules.

The HKMA has confirmed one complaint and says it is still considering what to do next. The company involved has not been named, and no enforcement outcome has been announced.

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