The Hong Kong MSO licence offers a structure that enables efficient operations across major markets, supporting trade in key currencies through established payment corridors. With no initial capital requirement and unrestricted monthly transaction volumes, it provides a cost-effective route to launching a global business.
Hong Kong provides a favourable environment to start and run a payment company driven by transparent regulation, administrative support from authorities in fintech development and innovation and geographical proximity to main target customers, markets and trade routes.
Time frames
Obtaining an MSO licence in Hong Kong typically takes between 6 and 12 months, depending on the complexity of the application and the regulator’s review process. This period covers the preparation of documentation, regulatory approvals, and compliance checks. In some cases, certain crypto-related activities may be initiated immediately after the MSO application has been submitted.
MSO Licence Requirements
To obtain an MSO licence in Hong Kong, the regulator expects the applicant to be a well-run, well-planned, and well-resourced company with a clear business proposition and a 3–5 year plan. Certain functions, such as technology, may be outsourced to a parent company abroad, provided compliance and oversight remain transparent. Importantly, there is no initial capital requirement for an MSO licence.
Applicants must also provide a set of supporting documents, including:
Applicant’s particulars (Business Registration Certificate, incorporation docs, annual return, group structure, Articles of Association).
Premises documentation (tenancy agreement, floor plan, photos, landlord consent for business premises, local storage, and management office).
Individual directors/partners/UBOs (Fit and Proper Person Declaration, ID/Passport, proof of residence).
Corporate partners/directors (registration documents, Articles of Association).
Authorisation letters (signed by partners or board).
Other documents (Business Plan, AML/CTF Policy, agreements with third parties, appointment of CO/MLRO, bank account proof).
Scope of work
Our work is structured in four key Stages to ensure a smooth and efficient MSO licence application process.
Stage One
During the client onboarding stage, we begin with an in-depth interview with the client and collect initial information about the desired business model and the UBO(s).This information serves as the foundation for the Application Development Document, which outlines the regulatory roadmap, timelines, and key risks. Following its completion and approval by both parties, we begin with the production of core main Stage One documents:
Business plan
Financial forecast for at least three years
Governance and organisational structure
Following completion, the application formally proceeds to Stage Two.
Stage Two
During Stage Two, we collaborate with the client to prepare the full suite of risk management, AML, and IT security documentation required for regulatory purposes. This includes developing key risk assessments and related policy materials, as well as recruiting Key Individuals and introducing the client to a partner bank for account opening.
Once the documentation framework is established, we assist in designing and implementing internal controls that address the identified risks. These controls are then reassessed to confirm their effectiveness and to identify any areas that may require improvement.
In parallel, we support the client in preparing the final policy and governance documents that form part of the regulatory submission. This process includes addressing any gaps from earlier work and delivering tailored training to ensure the client’s team fully understands and can apply the developed materials.
Main Stage Two documents:
AML and general risk assessments
Business-wide risk management documentation
Policy and governance frameworks
IT security documentation
With the completion of Stage Two, the application package is finalised and ready for submission to the regulator.
Liaison with the regulator
Once the full application pack is submitted to the regulator, we assist the client by managing their correspondence with the regulator and guiding them through follow-up queries until the licence is granted.
During the documentation preparation stage, Fintheo supports the client by introducing trusted banking partners for account opening and assisting with recruitment through Fintheo.Recruitment, ensuring compliance, governance, and banking partners are aligned.
About Us
We are a team of former MLROs, compliance officers, and fintech and regtech professionals, dedicated to guiding firms through the regulatory landscape. Since 2019, our team has actively supported customers in building, scaling and expanding fintech businesses by providing a full suite of consulting services.
Our commitment to provide end-to-end support for businesses pursuing regulated activities led to the creation of Fintheo. We are a tech-driven company that strives to offer impeccable service to customers. As part of our proposition, we also offer a purpose-built e-money software platform which is fully DORA-compliant. In 2022, we expanded our services to include Fintheo.Recruitment, a division focused on sourcing fit and proper individuals for director and management roles to support clients during the licensing process.