Author: Wu said blockchain
In this episode of the dialogue, Hong Kong accountant Xiao Yaohe and Wu Shuo shared the latest investment immigration case progress and related policy dynamics of his clients. On February 7, 2025, a client used Ethereum worth HK$30 million as asset proof and applied to Invest Hong Kong for investment immigration, which was approved. In October 2024, a client who used Bitcoin as asset proof was also approved. This is the first case in Hong Kong to use cryptocurrency as an asset to apply for investment immigration and be approved. The relevant clients are basically from mainland China.
Mr. Siu is the Deputy Managing Partner of Hongyuan CPA Limited and has over 25 years of experience in the accounting and auditing industry. He has held important positions such as Chief Accountant and Administrative Manager in companies listed on the Hong Kong Stock Exchange and multinational corporations.
Please introduce these two cases where cryptocurrencies were used as proof of assets for investment immigration.
Xiao Yaohe: There are currently two successful clients using cryptocurrency to prove their assets. The first case was in October 2024, using Bitcoin. This is the second successful case, using Ethereum. There are two more currently being worked on.
In the investment immigration program, the government or our accountants need to submit a report to prove that a person has assets of HK$30 million. Bitcoin or cryptocurrency (Crypto) can also be used as assets and it is recognized.
So this investment immigration program does not require you to invest in Hong Kong, as long as you hold assets worth HK$30 million, right?
Xiao Yaohe: This is just the first step. First, the applicant needs to prove that he has HK$30 million in assets, no matter where these assets are - whether in Hong Kong, China, Africa, or Australia. After proving that the assets are correct, you pass the first level, and then you need to bring the funds to Hong Kong for investment, and you must invest in designated assets, in simple terms, investing in stocks and bonds of listed companies. You must invest the funds in Hong Kong.
Currently, these two clients, one using Bitcoin and the other using Ethereum, have passed the first step of capital verification, proving that they have HK$30 million in assets. The second step is that they need to bring HK$30 million of funds to Hong Kong for investment within six months.
Can this investment only be made in stocks, and not in assets like Bitcoin and Ethereum ETFs?
Xiao Yaohe: The original intention of this investment immigration program is to require speculators to invest in Hong Kong's stock market, capital market and bond market. This is the most important thing. If you want to invest through other methods, such as the ETF you mentioned, it is possible to say the least.
Because there is a way, first you need to invest 30 million Hong Kong dollars in a limited partnership fund company that you set up yourself. This company is 100% owned by you, you can supervise the company, but there is no clear requirement on how to invest within the company.
It is still uncertain whether the HK$30 million can be used to invest in the Bitcoin ETF issued locally in Hong Kong. If HSBC sells you this product, they must be registered with the Investment Promotion Office and be able to provide a certificate to prove it. If they can issue a certificate, it means that the product can be invested in.
So the process of investment immigration is that first, they have to prove that they have assets worth 30 million Hong Kong dollars (Bitcoin and Ethereum can be used), and then the Hong Kong government will issue them a two-year visa?
Xiao Yaohe: No, you need to complete the investment within six months before you can get a visa. The visa is valid for two years and needs to be renewed after two years. When you renew your visa, you need to prove that the investment is still ongoing. Every year, you need an accountant to issue a report to prove that the total investment is not less than HK$30 million and to ensure that you have not transferred other investments after the investment. However, it does not matter whether the investment is a loss.
Crypto assets can be placed in cold wallets or on large exchanges such as Binance to prove that both methods are feasible.
A look back at the Hong Kong government’s first approval of a crypto asset
Xiao Yaohe: Clients who use cryptocurrency as assets to apply for investment immigration are basically from the mainland. There should not be many other cryptocurrency-related investment immigration cases, because in October 2024, I called the Investment Promotion Office and asked them if there were any similar cases, and they said no. So I was the first one at that time.
The first case was in October 2024. They said at the time that they had never handled a similar case and told me, "It's okay, you do it first, we will discuss it internally." Then about a month later, the first case was successfully approved. I did not participate in their communication, mainly they discussed the matter internally.
In addition to Bitcoin and Ethereum, will the Hong Kong government recognize other currencies such as USDT?
Xiao Yaohe: In fact, there is no official response, no official clear statement, indicating which currencies are recognized and which are not recognized. We are crossing the river by feeling the stones. You can try other currencies, but we have provided two successful cases at present. But from my point of view, the key is the liquidity of these cryptocurrencies and whether they have a very reliable market value.
However, some comments pointed out that in Singapore, cryptocurrencies have always been used as proof of assets, but the difficulty is that customers cannot provide proof of their initial investment funds in cryptocurrencies.
AiYing Compliance The article states that the biggest hurdle is indeed proof of source of funds (SOF). There is a classic contradiction in the cryptocurrency circle - "coins can be obtained, but money cannot be explained". Early players have many "black histories": many people got coins through mining, over-the-counter transactions or even "gifts from friends" in their early years, and they could not produce bank statements or transaction records at all. The "thunderstorm" of the exchange drags down: platforms such as FTX and Binance have had compliance issues, and some users' historical data have been lost or not recognized by regulators. Anonymity is a double-edged sword: although the blockchain is transparent, it is difficult to directly link the wallet address with the real person's identity, and it is difficult for accountants and immigration authorities to trace the source of funds. For example: a large account spent 1 million Hong Kong dollars to buy Bitcoin in 2017, which is now worth 10 million Hong Kong dollars. But the transfer records of that year have long disappeared, or cash transactions were used. How to prove that the 100,000 is legal income? If this point cannot be explained, the immigration application will be directly cold. Therefore, it is recommended to keep evidence from the first day: transfer records of buying coins, exchange bills, tax payment certificates, even a handwritten receipt is better than nothing.
