两岸の規制当局が連携して香港株口座開設を封鎖、あなたのお金はどこへ行くのか？

Original: Odaily Planet Daily (@OdailyChina)

Author: jk

On May 24, Haiphong Road in Tsim Sha Tsui, Hong Kong, was eerily quiet.

A week earlier, it had been the "account-opening street" for mainland investors, with temporary broker booths and mobile vans lined up and crowds bustling. Zero commission for Hong Kong stock accounts, free stocks, support for IPO subscriptions, lax address verification... Brokers had lowered the threshold to the floor to attract mainland clients.

Yet just seven days later, the door slammed shut. Now, mainland clients looking to open a Hong Kong stock account not only have to sign a written declaration confirming funds come from overseas and that they have never forged documents, but even after signing, they may still face rejection.

This turning point began on May 22. A coordinated regulatory crackdown from both sides of the border directly impacted millions of mainland investors who invest in overseas markets through Hong Kong brokers.

How severe is this regulatory storm? What is the real experience for mainland residents trying to open accounts in Hong Kong now? What compliant channels still exist for investing in overseas assets? Odaily Planet Daily breaks it down for readers.

I. Joint Action Across the Strait, the "Gray Channel" for Hong Kong Stock Investment is Blocked Overnight

On May 22, regulatory bodies in Hong Kong and the mainland acted almost simultaneously, launching a pincer attack from both sides.

The Hong Kong Securities and Futures Commission (SFC), after reviewing the account-opening operations of 12 brokerage firms, issued an unusually severe circular. It pointed out several major deficiencies: inadequate due diligence on account-opening documents, acceptance of suspicious or forged documents during the process, and significant weaknesses in managing cross-border agency relationships with overseas intermediaries. The SFC explicitly stated that these accounts might be used for illegal transactions, and the money laundering risk cannot be ignored.

For mainland investors, the SFC attached additional "three-piece" requirements in the circular's appendix: new accounts must submit a written declaration, and deposits, withdrawals, and settlements can only be made through qualified bank accounts opened in the client's own name. The core content of the written declaration includes: confirming that all investment funds come from legitimate sources outside mainland China, the account has never been closed due to use of suspicious documents, the broker must be notified within 7 business days if circumstances change, and agreeing to disclose relevant information to law enforcement and regulatory bodies.



The SFC required all licensed institutions to immediately conduct self-inspections, close accounts opened with suspicious or forged documents, and "dormant accounts" with zero balance and no transactions for 12 months. Senior management was also explicitly named, with those responsible for serious compliance failures potentially facing regulatory and enforcement actions.

Almost simultaneously, the China Securities Regulatory Commission (CSRC), along with eight other ministries (MIIT, MPS, PBoC, SAMR, NFRA, CAC, SAFE), formally issued the "Comprehensive Action Plan for Cracking Down on Illegal Cross-Border Securities, Futures, and Fund Business Activities." The plan includes a 2-year concentrated remediation period, during which existing accounts can only sell assets and transfer funds out, with no new additions allowed. It also issued administrative penalty notices for Tiger Brokers, Futu Securities, and Changqiao Securities for illegal securities business activities by their domestic and foreign entities. The scope, intensity, and determination behind this combination of measures are rare in recent financial regulatory history.

Two documents from different regulatory systems point to the same issue: the long-standing model where a large number of mainland investors invested in Hong Kong and US stocks through Hong Kong brokers, operating in a legal gray area, has officially come to an end. This time, the regulators are serious.

To understand why this crackdown is so decisive, one must look back at the past two or three years and see how "wide" this channel had become.

From 2023 to early 2025, both Hong Kong and US stock markets experienced successive rallies, with many IPO opportunities emerging in Hong Kong, fueling a surge in account openings by mainland investors. At that time, internet brokers like Futu, Tiger, and Changqiao aggressively penetrated the mainland user base with smooth Chinese-language app experiences, low or even zero commissions, and support for direct RMB deposits. Some Hong Kong broker platforms didn't require proof of address, or didn't conduct substantive verification, even allowing deposits in stablecoins (USDT). Opening an account was almost just a click away.

As early as July 2016, the CSRC issued a risk warning, naming Tiger Brokers, Futu Securities, and others for providing services to buy and sell overseas securities like Hong Kong and US stocks. At the end of 2022, the CSRC launched a special remediation campaign against overseas brokers like Tiger and Futu. However, the effect was limited; existing accounts continued to function normally, and some platforms even continued accepting new mainland clients through various workarounds after rectification.

This time, the authorities showed no restraint. The policy focus shifted from limiting new accounts to cleaning up existing ones; all previous loopholes have been explicitly sealed off by regulators.

II. "Written Declaration" in Hand, Account Opening Still Fails

As soon as the new regulations were announced, the quickest actors had already bought plane tickets to Hong Kong, but account openings did not go smoothly. Over the past week, multiple photos titled "Written Declaration for Mainland Investors" have circulated on social media, all from mainland individuals who personally visited Hong Kong broker branches to try opening accounts.

Blogger AB Kuai.Dong described a friend's experience: the friend traveled specifically to Hong Kong, visited a KGI Securities branch to apply for a US/HK stock account, was asked to sign a "Written Declaration for Mainland Investors", filled out all the materials, waited over an hour, but was still told "account opening review failed." Blogger Simon also recorded a similar experience; a friend walked in to open an account, signed the declaration, waited over an hour, and ultimately failed as well.

Judging from the declaration texts shared by multiple accounts, the content closely matches the requirements in the SFC circular's appendix, indicating that brokers quickly implemented the new rules after their issuance.

Notably, signing does not guarantee account approval, but refusing to sign certainly prevents it. Blogger Li Zhi provided a blunt interpretation: by having clients sign this declaration, brokers are essentially doing two things: first, transferring compliance responsibility, so that if problems arise, they can claim "the client declared the funds were legal"; second, filtering clients, because most mainland individuals trading Hong Kong and US stocks through Hong Kong brokers are already in a legal gray area. This declaration forces them to confirm in black and white that funds come from overseas, which itself acts as a barrier.

A report from Cailianshe on May 27 also confirmed this phenomenon across almost all Hong Kong broker account openings: starting May 26, opening investment accounts offline through Hong Kong bank branches required new document submissions, including signing a declaration regarding the legal source of funds. A person from a foreign bank in Hong Kong also confirmed to a Cailianshe reporter that the addition of such a declaration does exist.

It is reported that the newly added document is titled "Cross-Border Disclosure Statement (Applicable for Investment Account Opening)." According to documents shown by clients, the core content of the declaration is: the individual opening the investment account must confirm that "all funds used to support investment activities and related settlements come from legitimate sources outside mainland China"; it also requires mainland residents to note that investment account services are only applicable to investors physically present in Hong Kong (e.g., living or working in Hong Kong), and they must ensure the source of funds is legal and compliant.

The document also explicitly states that to comply with relevant Hong Kong regulatory requirements, the bank may require clients to provide supporting documents, and failure to do so may lead to denial or termination of relevant services. Crucially, this doesn't just affect new account openings. A customer service representative from a Chinese state-owned bank confirmed to a Cailianshe reporter that mainland investors who opened investment accounts between May 23 and 25, 2026, will also need to re-sign the new cross-border declaration, with no transition period provided.

III. Who Can Still Open Accounts? Review of Existing Compliant Channels

This tightening has directly closed the mainland entry points for major internet brokers, but not all channels are shut.

Brokers that have completely stopped accepting new mainland clients: Futu Securities, Tiger Brokers, Changqiao Securities, Huasheng Securities. These four have all closed their new account opening channels. Some existing accounts can still trade normally for now, but they are only allowed to sell assets unilaterally, awaiting full closure after the 2-year transition period.

Hong Kong licensed brokers that still retain limited channels for mainland residents (as of the date of this article, the situation is dynamic and subject to change):

KGI Securities is currently one of the few Hong Kong brokers still supporting direct account opening for mainland users. It holds Hong Kong SFC Type 1, 4, and 9 licenses, and its US subsidiary is registered with the SEC and regulated by FINRA, giving it a relatively robust compliance framework. However, based on the latest feedback from social media, KGI has significantly tightened its account opening review for mainland residents after the new regulations, with a marked increase in failed walk-in attempts. Success largely depends on whether the applicant genuinely meets the "funds from outside mainland China" condition.

Fosun Wealth and Chee Cheung Securities are two other options that still retain channels for mainland users.

One blogger claimed that according to the latest information from Fosun, its revised account opening policy is: proof of address is no longer required, but applicants must use a VPN or be physically present in Hong Kong to apply; users of Hong Kong virtual bank cards like ZA Bank, Tianshan Bank, or HSBC must have their location set to Hong Kong during the application. Odaily has verified this with Fosun officials, who stated this account opening policy is a rumor; account opening still requires compliance with the policies mentioned above.

For users with overseas status (students, work visa holders, permanent residents abroad, etc.), the conditions are relatively relaxed, but they still need to provide proof that funds originate from overseas.

Opening an account is only the first step; how to deposit money is another core constraint of the new regulations.

The SFC circular explicitly requires that deposits, withdrawals, and settlements for mainland investor accounts can only be conducted through accounts opened in the client's own name at licensed banks in Hong Kong or qualified jurisdictions. Transferring funds through third parties or unknown sources is now clearly blocked from a compliance standpoint. This means that previous workarounds to bypass foreign exchange controls, such as using money changers, transfers through friends, or USDT deposits, are no longer feasible in terms of compliance.

Practically speaking, a prerequisite for smooth fund deposits is holding a Hong Kong bank account in the client's own name. Hong Kong virtual banks like ZA Bank and Tianshan Bank support FPS, allowing normal deposits into broker accounts. Some brokers (like KGI Securities) also support eDDA fast deposit, which can be linked to ZA Bank. Therefore, for users without a Hong Kong bank account, getting a Hong Kong card before opening a securities account has become an indispensable step in the complete process.

Overall, after May 2026, the compliant paths for ordinary mainland investors to invest in Hong Kong and US stocks have significantly narrowed, but not completely closed. Based on the current situation, a few avenues remain viable.

Most Stable Path: Compliant Status, Compliant Funding Sources, and Hong Kong Bank Account. Students, overseas work visa holders, and Hong Kong/Macau residents with overseas supporting documents who meet the "funds from outside mainland China" condition can still open accounts with licensed brokers like KGI, Chee Cheung, and Fosun. Tourists may face higher chances of failure, especially concerning the source of funds.

Policy-Compliant Channels: Stock Connect, QDII, Cross-Border Wealth Management Connect. These are the directions regulators explicitly want to guide capital flows towards. Although product types are limited and quotas apply, they are fully compliant. It is expected that the capital of affected mainland investors will gradually shift towards these channels.

On-Chain Path: Platforms like Hyperliquid, xStocks offer technical alternatives. For users who can meet these platforms' account opening requirements, this is also an option. However, it must be noted that such on-chain products have clear compliance boundaries. Recently, several projects offering Hong Kong stock-related crypto products have explicitly announced, in response to the new Hong Kong regulations, that they will stop offering such products. Furthermore, most of these products do not accept registration from mainland Chinese users, making them more suitable for users living overseas.

Conclusion: Significantly Tightened, but Opportunities Still Exist

This tightening represents a concentrated release of long-accumulated tensions. The disorderly expansion by Hong Kong brokers targeting mainland clients over the past few years brought substantial user growth but also left behind significant compliance risks, including forged documents, unknown fund sources, and misuse of dormant accounts. The synchronized actions of regulators on both sides have sent a clear signal to the market: the dividend period of this gray channel has ended.

For mainland investors who still need exposure to Hong Kong and US stocks, the path ahead will not be easier, but compliant choices still exist. Which path to take depends on individual status, risk tolerance, and personal assessment of compliance boundaries. In any case, before signing any written declaration, one must be clear: once signed, the legal responsibility falls squarely on oneself.

(Odaily Note: This article is compiled from official SFC circulars, CSRC announcements, Cailianshe, Yicai Global, and other media reports, as well as first-hand information from social media. It is for informational reference only and does not constitute investment advice.)