Hong Kong Bans Smart Contracts in Cold Wallets, Mandates 24/7 Monitoring

Markets 2025-09-02 11:30

Hong Kong Bans Smart Contracts in Cold Wallets, Mandates 24/7 Monitoring

Hong Kong's securities regulator imposed immediate new custody requirements for digital asset platforms Friday, responding to mounting cybersecurity threats that have cost investors billions globally. The Securities and Futures Commission issued updated compliance standards mandating 24/7 monitoring systems, whitelisted withdrawal addresses, and enhanced wallet security protocols for all licensed virtual asset trading platforms operating in the territory.


What to Know:

  • The SFC banned smart contracts in cold wallets and requires real-time reconciliation of client assets following global custody vulnerabilities
  • New rules take immediate effect as Hong Kong positions itself as a regional digital asset hub through expanded regulatory frameworks
  • Requirements include unauthorized access detection systems and stringent controls over cold wallet transactions to prevent asset losses

Regulatory Response to Global Threats

The regulatory crackdown stems from what the SFC described as "multiple cases of custody vulnerabilities" witnessed internationally. Dr. Eric Yip, the commission's Executive Director of Intermediaries, emphasized that client asset protection remains the top priority for Hong Kong's digital asset ecosystem development.

The regulator's own review earlier this year revealed significant gaps in cybersecurity preparedness among virtual asset service providers. "Multiple cybersecurity incidents at overseas virtual asset platforms resulting in significant client asset losses have also highlighted persistent risks to custody globally," the SFC stated in its circular.

Key vulnerabilities identified include compromised third-party wallet solutions and insufficient transaction verification processes. The commission noted inadequate access controls over approval devices as another critical weakness plaguing the industry.

New Custody Standards and Technical Requirements

The updated framework introduces several technical mandates that platforms must implement without delay. Cold wallet implementations now face restrictions on smart contract usage, with the SFC stating these should be eliminated "to minimize potential online attack vectors associated with on-chain smart contracts."

Whitelist controls become mandatory for preventing unauthorized asset transfers. The circular specifies that "any modifications or additions to the cold wallet whitelist should be subject to stringent controls and oversight."

Transaction verification receives heightened scrutiny under the new rules. Each transaction must undergo systematic verification to ensure only authorized transfers proceed. Real-time reconciliation of on-chain client assets with ledger balances becomes a non-negotiable requirement.

Platforms must establish mechanisms for detecting unauthorized access to critical wallet infrastructure. The SFC demands "effective 24/7 monitoring" of systems, networks, wallets, and infrastructure components. Any unexpected transactions causing discrepancies require immediate flagging and investigation.

Hong Kong's Broader Digital Asset Strategy

The custody requirements represent the latest development in Hong Kong's aggressive push to establish regional dominance in digital assets. The territory has rolled out multiple initiatives this year designed to attract cryptocurrency businesses while maintaining investor protection.

January saw the Hong Kong Monetary Authority launch new supervisory arrangements for local banks developing blockchain products. The central bank described this as enabling institutions to "maximize the potential benefits of DLT adoption by effectively managing the associated risks."

May brought passage of the Stablecoin Ordinance, creating comprehensive licensing requirements for stablecoin issuers. Any entity issuing Hong Kong dollar-referenced stablecoins anywhere globally now requires central bank licensing.

The SFC announced plans in June to permit digital asset derivatives trading for professional investors. This expansion aims to broaden product offerings and strengthen Hong Kong's fintech hub credentials.

Policy Framework Evolution

The government's "Policy Statement 2.0 on the Development of Digital Assets in Hong Kong" released June 26 represents the clearest signal of the territory's cryptocurrency ambitions. The statement introduced the LEAP framework, focusing heavily on stablecoin regulation and asset tokenization policies.

This unified regulatory approach covers all virtual asset service providers under a single framework. The policy demonstrates Hong Kong's commitment to comprehensive oversight while encouraging industry growth.

The territory's embrace of digital assets has naturally triggered increased regulatory scrutiny. However, officials stress that enhanced oversight supports rather than hinders industry development.

Understanding Key Terms

Virtual Asset Trading Platforms operate as digital marketplaces where users buy, sell, and trade cryptocurrencies and other digital tokens. These platforms require licensing in Hong Kong and must comply with custody requirements.

Cold wallets store cryptocurrency offline, disconnected from internet networks to prevent hacking attempts. Smart contracts are self-executing programs on blockchains that automatically enforce agreement terms without intermediaries. Stablecoins are cryptocurrencies designed to maintain stable values, typically pegged to traditional currencies like the US dollar. Asset tokenization converts physical or traditional financial assets into digital tokens on blockchain networks.

Closing Thoughts

Hong Kong's immediate implementation of stricter custody standards reflects growing global concern over digital asset security vulnerabilities. The territory continues balancing investor protection with its ambitions to become Asia's premier cryptocurrency hub through comprehensive regulatory frameworks.

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This content is for informational purposes only and does not constitute investment advice.

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