Regulatory and Risk Observations on Hong Kong Digital Banks Approved to Offer Virtual Asset Trading Services

Regulatory DevelopmentsBanking ServicesVirtual Asset ComplianceRisk Research

Recently, Hong Kong digital bank Mox Bank received regulatory approval to upgrade its Type 1 license, enabling it to offer virtual asset trading services to customers through integrated accounts. According to publicly disclosed information, the service currently supports trading in Bitcoin and Ethereum denominated in U.S. dollars only. This development marks a further extension of virtual asset–related activities within the licensed banking system.

Business Structure and Partnership Model

Based on the announced arrangements, Mox Bank’s virtual asset trading platform relies on a third-party exchange for trading technology and execution, while custody of clients’ virtual assets is handled by an independent custodian. This division of responsibilities largely mirrors the traditional financial structure in which trading, custody, and account management are relatively segregated, and reflects regulatory expectations around risk isolation within the approved framework.

Fee Structure and Client Segmentation

Publicly available information indicates that the service adopts a tiered fee structure, with different membership levels corresponding to different commission rates. At the entry level, trading commissions are set at 1.25%, while higher-tier clients may benefit from reduced commissions as low as 0.5%. Such tiered pricing mechanisms are common in both traditional financial services and virtual asset platforms. From a compliance perspective, the key consideration is not the level of fees themselves, but whether fee disclosures are sufficient and calculation methods are clearly explained.

Risk Boundaries of Bank Participation in Virtual Asset Trading

Licensed banks providing access to virtual asset trading through integrated accounts may offer clients a user experience closer to that of traditional financial services, but this also introduces new risk management challenges. On one hand, banks must ensure that virtual asset–related activities do not transmit risk to existing deposit-taking or payment systems. On the other hand, the allocation of responsibilities across trading, custody, and settlement functions must remain clearly defined through contractual arrangements and transparent disclosures.

Key Areas of Regulatory Focus

From a regulatory and compliance research perspective, the critical issue lies not in the nature of the assets themselves, but in process controls and ongoing monitoring capabilities. Regulators typically focus on whether customer suitability management, anti-money laundering (AML), and counter-terrorist financing (CFT) measures adequately cover virtual asset trading activities, and whether abnormal transactions can be identified and addressed in a timely manner. While these requirements are consistent with traditional financial regulatory logic, their implementation becomes more complex in an on-chain environment.

Implications for On-Chain Risk Identification and Compliance Monitoring

This development indicates that virtual asset trading is increasingly being embedded within regulated banking systems, with business models aligning more closely with mainstream financial structures. For the industry, this implies that on-chain asset flows will intersect more frequently with accounts held at licensed institutions. Continuous monitoring of transaction pathways, custody structures, and cross-system fund flows will therefore become a critical foundation for risk identification. Such trends also provide new real-world observation scenarios and analytical dimensions for on-chain risk identification and compliance monitoring research, including the work undertaken by Trustformer KYT.

About Trustformer

Trustformer is a leading blockchain security and compliance technology company specializing in providing professional risk management and compliance solutions for the global cryptocurrency ecosystem. We have developed the cutting-edge Trustformer KYT (Know Your Transaction) platform, which integrates artificial intelligence, blockchain analytics, and regulatory technology to deliver comprehensive, accurate real-time transaction monitoring, risk assessment, and suspicious activity reporting services.

With deep industry expertise and technological innovation, Trustformer is dedicated to helping Virtual Asset Service Providers (VASPs), crypto financial institutions, and investors build a safer and more transparent crypto financial environment. We believe that driving compliance and trust through technology can contribute to the thriving growth of the global digital economy.