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两岸監管聯手封堵港股開戶,你的錢還能去哪?

jk
Odaily资深作者
2026-05-28 07:15
本文約4137字,閱讀全文需要約6分鐘
現存合規窗口梳理。
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  • 核心觀點:中國內地與香港監管機关于2026年5月22日聯手出擊,徹底封堵了內地投資者通過香港券商投資港美股的大量灰色通道,要求新開戶及部分存量客戶簽署資金合法來源聲明,並設2年過渡期清退存量,導致開戶難度驟增、合規路徑大幅收窄。
  • 關鍵要素:
    1. 5月22日,香港證監會(SFC)發布嚴厲通函,指出券商開戶存在重大合規缺陷,要求新開戶必須提交書面聲明,確認資金來自中國內地以外合法來源,且出入金僅可通過本人名義的香港銀行賬戶。
    2. 同一日,中國證監會聯合八部委印發《綜合整治非法跨境證券期貨基金經營活動實施方案》,設置2年整治期,期内存量賬戶只許賣出,禁止新增,並對富途、老虎、長橋等券商進行行政處罰。
    3. 新規下,「書面聲明」簽署並非開戶保證,多起實地開戶案例顯示,即使提交聲明,內地投資者仍面臨審核失敗,券商藉此轉移合規責任並篩選客戶。
    4. 開戶困境波及所有券商,部分銀行(如中資銀行)要求2026年5月23日前已開戶的內地投資者補簽新版《跨境披露聲明》,無過渡緩衝期。
    5. 富途、老虎、長橋、華盛證券已全面停止接受內地新客戶;盈立、復星財富、致富證券等仍保留有限通道,但審核極嚴,需滿足「資金來自境外」等條件。
    6. 資金入金路徑被明確封堵:此前通過錢莊換匯、USDT入金等繞過外匯管制的做法已不可行,必須通過本人名義的香港實名銀行卡(如ZA Bank、天星銀行)進行。
    7. 現有合規路徑包括:擁有海外身份及境外資金來源的投資者;港股通、QDII、跨境理財通等政策渠道;以及面向海外用戶的鏈上平台(如Hyperliquid),但後兩者存在品種限制或合規邊界。

Original|Odaily Planet Daily(@OdailyChina)

Author|jk

On May 24th, Haiphong Road in Tsim Sha Tsui, Hong Kong, was eerily quiet, making people feel uncomfortable.

A week ago, this street was still the "account opening street" for mainland investors, lined with temporary booths and mobile vans from brokerages, bustling with crowds. With zero commission for Hong Kong stock accounts, free stocks, support for IPOs, and relaxed address verification requirements... brokerages had practically lowered the threshold to the ground to attract mainland clients.

However, just seven days later, the door slammed shut. Now, for mainland clients wanting to open a Hong Kong stock account, they not only have to sign a written declaration stating that their funds come from overseas and that they have never forged any documents, but after signing, they might still be met with a "rejected" response.

The turning point for everything began on May 22nd. Regulators from both regions simultaneously implemented a coordinated set of measures, directly impacting millions of mainland investors who invest in overseas markets through Hong Kong brokerages.

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

1. Cross-Border Collaboration, Overnight Shutdown of the "Grey Channel" for Hong Kong Stock Investment

On May 22nd, regulatory bodies in both Hong Kong and Mainland China took action almost simultaneously, applying pressure from both ends.

The Hong Kong Securities and Futures Commission (SFC), after reviewing the account opening operations of 12 brokerage firms, issued an unusually stern circular. The document pointed out several major deficiencies: inadequate due diligence on account opening documents, acceptance of suspicious or forged documents during the account opening 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, posing a money laundering risk that cannot be ignored.

For mainland investors, the SFC's circular appendix listed an additional "three-piece" requirement: new account applicants must submit a written declaration, and all deposits, withdrawals, and settlements must be conducted through a qualified bank account opened in the client's own name. The core content of the written declaration includes: confirming that all investment funds originate from legitimate sources outside Mainland China; that the account has never been closed for using suspicious documents; to notify the broker within 7 business days if circumstances change; and to agree to disclose relevant information to law enforcement and regulatory bodies.



The SFC demanded that all licensed institutions immediately conduct self-inspections, close accounts opened with suspicious or forged documents, as well as "dormant accounts" with zero balance and no transactions for 12 months. Senior management was also explicitly named and warned; those with severe compliance failures may face regulatory and enforcement actions.

At almost the same time, the China Securities Regulatory Commission (CSRC), together with eight other ministries (MIIT, MPS, PBoC, SAMR, NFRA, CAC, SAFE), formally issued the "Implementation Plan for Comprehensive Rectification of Illegal Cross-Border Securities and Futures Fund Operations Activities". The plan sets a 2-year concentrated rectification period, during which existing accounts can only be used for selling holdings and transferring funds out, with no new positions allowed. It also issued administrative penalty warnings against Tiger Brokers, Futu Securities, and Longbridge Securities for illegal securities business operations by their related entities both domestically and abroad. The scope, intensity, and determination behind this coordinated regulatory action are rare in recent financial supervision history.

Two documents from different regulatory systems point to the same issue: The long-standing model where mainland investors traded Hong Kong and US stocks through Hong Kong brokerages, which operated in a legal grey area, has officially come to an end. Regulation is serious this time.

But to understand why this crackdown is so decisive, one must look back at the past two to three years and see just how "broad" this channel had become.

From 2023 to early 2025, both Hong Kong and US stock markets saw successive surges, with numerous IPO opportunities in Hong Kong, significantly boosting the demand for account opening among mainland investors. At that time, internet brokerages represented by Futu, Tiger, and Longbridge aggressively penetrated the mainland user market with advantages like smooth Chinese-language app experiences, low or even zero commissions, and support for direct deposits in RMB. Some Hong Kong brokerage platforms did not require address proof, or did not conduct substantive address verification, and even allowed deposits using 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 for trading Hong Kong and US stocks. At the end of 2022, the CSRC launched a special rectification campaign targeting overseas brokerages like Tiger and Futu. However, the effectiveness was limited; existing accounts remained active, and some platforms even continued accepting new mainland clients through various workarounds even after rectification.

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

2. Even with a "Written Declaration", Account Opening Still Fails

When the new regulations were announced, the quickest movers had already booked flights to Hong Kong, but account opening wasn't smooth sailing. Over the past week, social media has been flooded with photos titled "Written Declaration for Mainland Investors", all from mainlanders who personally visited Hong Kong brokerages' physical branches to try opening accounts.

Blogger AB Kuai.Dong described a friend's experience: The friend made a special trip to Hong Kong, visited a branch of Yingli Securities to apply for a US/HK stock account, was asked to sign a "Written Declaration for Mainland Investors", filled out all the materials, waited for over an hour, and was still told "account opening review failed". Blogger Simon also documented a similar experience where his friend walked in to open an account, signed the declaration, waited for over an hour, and ultimately did not pass.

Based on the declaration texts shared by various accounts, the content closely matches the requirements in the SFC circular's appendix. Brokerages clearly implemented the new rules promptly after they were issued.

Notably, signing doesn't guarantee account opening, but refusing to sign makes it impossible. Blogger Li Zhi provided a straightforward interpretation: By having clients sign this declaration, brokerages are essentially doing two things: Firstly, transferring compliance responsibility - if something goes wrong, they can say "the client declared the funds were legal". Secondly, screening clients - because most mainlanders trading Hong Kong/US stocks through Hong Kong brokerages are in a legal grey area, this declaration forces them to confirm in black and white that their funds come from overseas, which in itself acts as a barrier.

A report from Cailianshe on May 27th also confirmed this phenomenon, which was prevalent across almost all Hong Kong brokerages' account openings: Starting May 26th, new requirements emerged for documents provided by clients opening investment accounts offline through Hong Kong bank branches, including signing a declaration about the legal source of funds. Sources from foreign banks in Hong Kong also confirmed to Cailianshe reporters that this new signing requirement exists.

Reportedly, the newly added document is called the "Cross-border Disclosure Statement (Applicable for Applying for Investment Account Opening Services)". According to documents shown by clients, the core content of the statement is: The individual opening the investment account must confirm that "all funds supporting investment activities and related settlements originate from legitimate sources outside Mainland China". Mainland residents are also reminded that the investment account service is only applicable to investors physically located in Hong Kong (e.g., living or working in Hong Kong) and should ensure the funds are legally compliant.

The document also specifies that, in order to comply with relevant Hong Kong regulatory requirements, the bank may request supporting documents from the client. If the client fails to provide them, the bank may refuse to provide the services, and existing services may also be terminated. It is worth noting that this doesn't just affect new accounts. A customer service representative from a Chinese state-owned bank confirmed to Cailianshe reporters that mainland investors who had already opened investment accounts between May 23 and 25, 2026, also need to sign the new cross-border declaration retroactively, with no transition period provided.

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

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

Brokerages that have fully stopped accepting new mainland clients: Futu Securities, Tiger Brokers, Longbridge Securities, and Huasheng Securities. These four have all closed their new account opening channels. Existing accounts can still trade normally for now, but according to regulations, they can only be used for selling, awaiting full closure after the 2-year transition period.

Hong Kong licensed brokerages that currently still retain limited channels for mainland residents (situation is dynamic as of the article's publication date):

Yingli Securities (uSmart) is currently one of the few Hong Kong brokerages that still supports 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, indicating a relatively sound compliance framework. However, based on the latest feedback on social media, since the new regulations were implemented, Yingli has significantly tightened its account opening review for mainland residents, with a marked increase in failed walk-in applications. Whether an application succeeds depends heavily on whether the applicant genuinely meets the condition of "funds originating from outside Mainland China".

Fosun Wealth and Chefu Securities (CGS International) are two other options that still retain channels for mainland users.

Some bloggers claimed that according to the latest official message from Fosun, its adjusted account opening policy is: Address verification is no longer required, but users must apply using a VPN or by physically appearing in Hong Kong. Users with Hong Kong virtual bank accounts (like ZA Bank, Tianxing Bank, HSBC) must have their location set to Hong Kong during the application. Odaily has verified with Fosun officially; this account opening policy is a rumor. Account opening must still comply with the compliance policies mentioned above.

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

Opening an account is only the first step. How to deposit money into the account is also a core constraint of the new regulations.

The SFC circular explicitly requires that for mainland investor accounts, deposits, withdrawals, and settlements can only be conducted through an account opened in the client's own name at a licensed bank in Hong Kong or a qualified jurisdiction. The practice of transferring funds through money changers, friends, or USDT deposits to circumvent foreign exchange controls is now explicitly blocked from a compliance perspective.

Operationally, the prerequisite for successfully depositing funds is holding a Hong Kong local real-name bank account. Hong Kong virtual banks like ZA Bank and Tianxing Bank support FPS (Faster Payment System), which can be used to deposit funds into brokerage accounts normally. Some brokerages' eDDA fast deposit function also supports linking ZA Bank. Therefore, for users without a Hong Kong bank account, getting a Hong Kong bank card before opening a securities account has become an indispensable step in the entire process.

Overall, after May 2026, the compliant paths for ordinary mainland investors to invest in Hong Kong and US stocks have been significantly narrowed, but not completely closed. Based on the current situation, several routes are still viable.

Most Stable Route: Compliant Identity, Compliant Fund Channels, and Hong Kong Bank Account. International students, overseas work visa holders, and Hong Kong/Macau residents, possessing the necessary proof of overseas status and meeting the "funds from outside Mainland China" condition, can still open accounts at licensed brokerages like Yingli, Chefu, and Fosun Wealth. Tourists face a higher chance 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 aim to guide funds toward. Although the range of products is limited and there are quota caps, they are fully compliant. It is expected that funds from affected mainland investors will gradually shift towards these channels.

On-Chain Routes: Platforms like Hyperliquid and xStocks offer technical alternatives for users who can meet their account opening requirements. However, it should be noted that these on-chain products have clear boundaries in terms of compliance. Recently, many projects offering Hong Kong stock crypto products have issued announcements stating that, in response to Hong Kong's new regulations, they will no longer offer such products. Furthermore, most of these types of products do not accept registration from mainland Chinese users, making them more suitable for users living overseas.

Conclusion: Significant Tightening, but Opportunities Still Exist

This round of tightening is a concentrated release of long-accumulated contradictions. The disorderly expansion of Hong Kong brokerages targeting mainland clients over the past few years, while generating substantial user growth, has also left behind numerous compliance risks, including forged documents, unidentified fund sources, and misuse of dormant accounts. The synchronized actions of regulators from both sides send a clear signal to the market: The bonus period for this grey channel is over.

For mainland investors who still need to allocate funds to Hong Kong and US stocks, the path ahead will not be easier, but compliant options still exist. Which path to take depends on an individual's identity status, risk tolerance, and personal judgment of compliance boundaries. Regardless, before signing any written declaration, one must be clear: once signed, the legal responsibility falls on oneself.

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

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