The primary suggestion of the paper is to include OTC trades under the jurisdiction of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance.
The government of Hong Kong will tighten regulations on over-the-counter (OTC) digital assets trade by subjecting it to the same requirements as the retail digital assets trade.
On Feb. 8, the government published its “Public Consultation on Legislative Proposals to Regulate Over-the-Counter Trading of Virtual Assets.” The consultation will last until April 12.
The primary suggestion of the paper is to include OTC trade under the jurisdiction of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), effective from June 2023. Typically, OTC means deals conducted directly between the provider and the customer without a centralized marketplace, such as an exchange.
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Source: https://cointelegraph.com/news/hong-kong-over-the-counter-crypto-traders-aml-requirements