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Dialogue organizer: Hong Kong investment immigrants recognize Bitcoin and Ethereum as asset certificates for the first time. Please list the details of the application process

On February 7, 2025, a customer used Ethereum worth HK$30 million as proof of assets to apply for investment immigration to Invest Hong Kong.

Author: Wu said blockchain

In this dialogue, Hong Kong accountant Xiao Yaohe shared with Wu said the latest investment immigration case progress and related policy developments of his clients. On February 7, 2025, a customer used Ethereum worth HK$30 million as proof of assets to apply for investment immigration to Invest Hong Kong. In October 2024, a customer who used Bitcoin as proof of assets was also approved, making it the first case in Hong Kong to use cryptocurrency as an asset to apply for approval for investment immigration. The relevant customers are basically from mainland China.

Mr. Xiao is the deputy managing partner of Hongyuan Certified Public Accountants Co., Ltd. and has more than 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 Stock Exchange of Hong Kong and multinational companies.

Audio transcription is done by GPT and there may be errors. Listen to the full podcast:

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https://www.xiaoyuzhoufm.com/episodes/67a740e8d74435e4a3e2cfbb

Please introduce these two cases in which cryptocurrencies were used as asset proof of investment immigrants

Xiao Yaohe: For the time being, there are two successful customers who use cryptocurrency to prove assets. The first case was in October 2024, using Bitcoin. This is the second success case, using Ethereum (ETH). There are two other things currently being done.

In the investment immigration program, the government or our accountants need to submit a report proving that a person has assets of HK$30 million. Things like Bitcoin or cryptocurrency (Crypto) can also be used as an asset and it is recognized.

So this investment immigration plan does not require you to invest in Hong Kong, as long as you hold assets worth HK$30 million?

Xiao Yaohe: This is just the first step. First of all, applicants need to prove that they have assets of HK$30 million, no matter where these assets are-whether in Hong Kong, China, Africa, or Australia, it doesn’t matter. After proving that the assets are correct, you pass the first level. After that, you need to bring the funds to Hong Kong for investment, and you must invest in designated assets. Simply put, you must invest in stocks, bonds, etc. of listed companies. You have to put your money into Hong Kong.

At present, these two customers, one uses Bitcoin and the other uses Ethereum, have passed the first step of capital verification, proving that they have assets of 30 million Hong Kong dollars. The next step is that they need to bring HK$30 million of funds to Hong Kong for investment within six months.

Can this investment only invest in stocks, but not in assets such as Bitcoin and Ethereum’s ETFs?

Xiao Yaohe: The original intention of this investment immigration plan is mainly 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, there is a slight possibility.

Because there is one solution, first you need to invest HK$30 million in a Limited Partnership Fund company you own. This company is 100% owned by you. You can supervise the company, but there are no clear requirements for how to invest within the company.

It is uncertain whether the HK$30 million can be invested in the locally issued Bitcoin ETF in Hong Kong. If HSBC sells you this product, they must register with the Investment Promotion Office and provide a certificate that can prove it. If they can issue certificates, it is equivalent to products that can be invested in.

So the process for investment immigrants is to first prove that they have assets of 30 million Hong Kong dollars (Bitcoin and Ethereum can be used), and the Hong Kong government will issue them a two-year visa?

Xiao Yaohe: No, the investment still needs to be completed within half a year. The visa will be issued only after it is completed. The period is two years and will be renewed after two years. When renewing, you need to prove that the investment is continuing. Every year, you need an accountant to issue a report to prove that the total investment is no less than HK$30 million and to ensure that you have not transferred other investments after investing. However, it doesn’t matter whether the investment is losing money.

Cryptocurrency assets can be placed on large exchanges such as Cold Wallet or Binance to prove that both methods are feasible.

Review of the case where the Hong Kong government first approved cryptocurrency assets

Xiao Yaohe: Customers who use cryptocurrency as assets to apply for investment immigration are basically from the mainland. There should not be many investment immigration cases related to cryptocurrencies, because in October 2024, I called the Investment Promotion Office and asked if there were any similar cases, but they said no. So I was the first.

The first case was in October 2024. They said at that time that they had never handled similar cases and said to me,”It’s okay, you do it first and we will discuss it internally.” Then about a month later, the first case was successfully approved. I didn’t participate in their communication, mainly because they were discussing this 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, saying that which currencies are recognized and which ones are not recognized are just crossing the river by feeling for the stones. You can try other currencies, but so far we have provided two success stories. But from my perspective, the key is the liquidity of these cryptocurrencies and whether they have a very reliable market value.

However, some commentators pointed out that in Singapore, cryptocurrency has always been used as proof of assets, but the difficulty is that customers cannot provide proof of initial investment funds in cryptocurrency.

AiYing Compliance article stated that the biggest difficulty is indeed the Proof of Source of Funds (SOF). There is a classic contradiction in the cryptocurrency circle-“The money can be taken out, but the money cannot be explained clearly.” Early players had a lot of “dark history”: many people obtained coins through mining, over-the-counter transactions and even “gift from friends” in their early years, but they could not get bank records or transaction records at all. The “thunder” of the exchange has dragged it down: Platforms such as FTX and Binance have experienced compliance problems, and some users ‘historical data has been lost or not recognized by regulators. Anonymity is a double-edged sword: Although blockchain is transparent, it is difficult to directly link wallet addresses to real identities, and it is difficult for accountants and immigration authorities to trace the source of funds. For example: a large household spent 1 million Hong Kong dollars on Bitcoin in 2017, which is now worth 10 million Hong Kong dollars. But the transfer records of that year have long disappeared, or the transaction was in cash. How can we prove that the 100,000 yuan is legal income? If you can’t explain this, the immigration application will go straight. Therefore, it is recommended to leave evidence from the first day: transfer records of the purchase of coins, exchange bills, tax payment certificates, even a handwritten receipt, is better than nothing.

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