Starting June 1, 2023, centralized virtual asset trading platforms (VATPs) operating in Hong Kong must obtain a license from the Securities and Futures Commission (SFC) under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance. Pre-existing VATPs can continue to provide virtual asset (VA) services until May 31, 2024, without violating licensing requirements, but new VATPs cannot commence operations until they obtain a license. The deeming arrangement under the AMLO allows pre-existing VATPs to continue operating while their license applications are being processed until June 1, 2024, subject to certain conditions. The SFC has issued a circular outlining the requirements that pre-existing VATPs must meet to qualify for the deeming arrangement, including the submission of a license application before February 29, 2024, arrangements to comply with regulatory requirements, and the onboarding of at least two responsible officers with necessary competence requirements and regulatory framework papers. The circular advises pre-existing VATPs to onboard more than two responsible officers for contingency purposes. The SFC will take appropriate actions against non-compliance with regulatory requirements.