“Providing clear regulatory expectations is the key to fostering responsible development.” To define the behavioral boundaries and duties of market entities through more rigorous, in-depth and comprehensive regulatory requirements is to take responsibility for investors and the development. After the release of Consultation Paper on the Proposed Regulatory Requirements for Virtual Asset Trading Platform Operators Licensed by the Securities and Futures Commission (the “Consultation Paper”) on February 20, the Securities and Futures Commission (SFC) of Hong Kong initiated a three-month campaign to solicit opinions of the public and investors and published the Consultation Conclusions on the Proposed Regulatory Requirements for Virtual Asset Trading Platform Operators Licensed by the Securities and Futures Commission (the Consultation Conclusions”) on May 23, which manifests the regulator’s sense of responsibility and reflects the 152 feedbacks from respondents, including that of Accumulus GBA Technology (Hongkong) Co., Ltd. (the “Accumulus [Hong Kong]”). The changes in the Consultation Conclusions can help market entities better understand the expectations of the regulators and the massive investors for them, as well as for the industry’s development.

A prosperous market is a common goal shared by all participants. A prosperous market can provide services for more people and create development opportunities, for which the number of investors in the market is one of the important standards to evaluate its level of development. SFC allows licensed trading platforms to provide their services conditionally to retail investors to inspire the large share of the incremental market, demonstrating its resolution and confidence to completely embrace Web 3.0. So far, Accumulus Platform further implements the policy requirements by providing different trading services for retail investors and professional ones according to their identities, before which the KYC and risk assessment have been adopted to differentiate the users and identify investors.

Trading platforms should shoulder the responsibility of protecting investors’ interests. SFC always prioritizes the protection of investors’ interests, and for trading platforms, executor of the policies, full implementation of the regulatory requirements is the bottom line for their compliant development. Based on the sufficient understanding of the policies, trading platforms should proactively take more efforts within their capabilities to support the regulation during the early stage of the regulation, which shows their responsibility and confidence in the development of the industry. Therefore, licensed platform should not skip the screening process when listing coins by direct copy of the coin list of other platforms. An all-round and detailed due diligence should be launched to meet the regulatory requirement that “the virtual asset (except for a security token) should be issued for at least 12 months”. Accumulus Platform sets up rules for listing coins and takes constant supervision to select coins that are with open source and highly decentralized consensus mechanism, traceable, not fully anonymous, and represent the common will of most stakeholders. For the first batch of coins listed, Accumulus Platform selects six public chain native coins and one stablecoin from over 9 000 coins, and they are all highly decentralized, with abundant application scenarios and a rank of top 30 in terms of both market value and 24-hour trading volume. Accumulus Platform responds to all regulatory requirements quickly by taking effective measures, such as strictly following the rule of storing 98% of assets in cold wallets and establishing investor protection funds. As a result, a multi-layer model of “trust + investor protection funds” is set up to guarantee the security of users’ funds in all aspects.

We firmly believe that Hong Kong will grow into a pacesetter of virtual asset development worldwide. Compared to the occurrence of new things, it is harder and more challengeable to formulate rules to boost their healthy development. From 2018, Hong Kong has done solid work on the regulation of virtual asset industry, in constant pursuit of dynamic balance between supporting the platform operators and protecting investors’ interests. Win-win development is the sustainable development. Market entities and investors expect for targeted and flexible policies that are made based on the different stages of industry’s development, demands of different parties and existing problems. Upholding the principle of “enhancing regulation” and “advancing development” at the same time and refining policies in an accurate and timely manner, Hong Kong proactively shoulders the responsibility of boosting the development of virtual asset industry as the international financial hub while always maintaining the strategic determination and historical confidence that are both lofty and down-to-earth. For market entities and massive investors, this is the largest certainty among uncertainties, as well as the source of the confidence that Hong Kong will become the international virtual asset center.

We believe that virtual asset industry will enjoy a better development in the future. John LEE Ka-chiu, Chief Executive of the Hong Kong Special Administrative Region (HKSAR), stressed that it is the golden chance to develop Web 3.0 now. From fintech, content production, games and entertainment to cultural and creative industry and social mode, Web 3.0 is developing closer connection and more important influence on our work and life. Hong Kong is among the first to set up regulatory regime for the virtual asset industry, providing us with a sense of safety and unprecedented opportunities to embrace Web 3.0. However, it is our increasing aspiration for a better life in the future during the process of exploring Web 3.0’s value that pushes forward Hong Kong’s strengthening of its regulation and encourages the further integration of everyone. Reviewing every round of technological revolution that leads to a new life with irreversible changes, to embrace what is new has become our instinct for development and only choice. Based on this consensus, to some extent, the main drivers of the industry’s regulated and healthy development should not only include external elements such as regulation and investors’ requirements, but also the industry’s reflection and self-adjustment from the internal during the ups and downs of development. It is the mission for the industry to help create the golden chance of Web 3.0 with a new shape. The 152 feedbacks from the respondents are just the constant practice that market entities, regulators, investors and other participants jointly build a new and healthy ecosystem of Web 3.0.

We endeavor to facilitate the prosperity of the market through compliant development. We are clearly aware that Accumulus Platform is still far from perfect. As the implementation of new regulations indicates the direction, we will continue to improve ourselves through constant efforts. Accumulus (Hong Kong) rolls out business when Hong Kong just starts to regulate the industry. At present, we focus on serving the Hong Kong market and understand Hong Kong people’s demand. We intend to become a compliance demonstration platform aiming to protect investors’ interests to the maximum extend, providing reference for regulatory agencies in Hong Kong to make or adjust policies and serving the economic development of Hong Kong. Accumulus (Hong Kong) will explore the issuance of security tokens, bridge blockchain industry, traditional financial markets and real economy, and provide efficient, convenient and low-cost financial services for companies that are in their start-up stage but have the potential to make profits, or roll out business in policy-favorable industries like green development, or yet cannot meet the initial public offering (IPO) requirements of the Stock Exchange of Hong Kong. We will innovate the financing mode, enrich financing channels, enhance the overall competitiveness of Hong Kong’s financial market through green and sustainable financial practice, realize constant technological and governance mechanism innovation through product innovation, and concrete the underlying logic of the industry development. The group company participated in the annual research projects of the Supreme People’s Court and the Supreme People’s Procuratorate, supported the Supreme People’s Court to carry out judicial explanations, and submitted suggestions to the National People’s Congress on the new business forms. Accumulus (Hong Kong) learns from group company’s experience of advancing the rule of law inside the Chinese mainland and apply it to the virtual asset business in Hong Kong, resulting in constant thought and suggestions on the regulated and sustainable development of the industry.

Standing at the historical starting point of virtual asset development, Accumulus (Hong Kong) will move upwards and onwards with regulatory agencies and massive investors, embracing the prosperous future of virtual asset industry together.