In a groundbreaking shift for global crypto adoption, Hong Kong has officially recognized Bitcoin (BTC) and Ethereum (ETH) as valid assets for its Capital Investment Entrant Scheme (CIES). This marks a pivotal moment for cryptocurrency holders—especially those from mainland China—who are exploring residency-by-investment pathways. In this article, we’ll explore the real-world cases, procedural steps, regulatory nuances, and major challenges applicants face when using digital assets to qualify for Hong Kong investment immigration.
First Confirmed Cases: Bitcoin and Ethereum Used Successfully
According to萧耀和 (Raymond Siu), Deputy Managing Partner at Hongyuan Certified Public Accountants, two successful cases have already been approved:
- October 2024: The first-ever approval using Bitcoin as asset proof.
- February 7, 2025: A second applicant was approved using Ethereum, with assets valued at HKD 30 million.
Both applicants were mainland Chinese nationals. These milestones confirm that Hong Kong’s investment immigration authorities are open to crypto-based wealth verification—provided it meets strict compliance standards.
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Step 1: Proving Eligible Assets
Under the re-launched CIES, applicants must prove they hold at least HKD 30 million in qualifying assets. While traditional assets include cash, stocks, and real estate, the government now accepts cryptocurrencies like Bitcoin and Ethereum as part of net worth calculations.
Importantly:
- The assets do not need to be held in Hong Kong initially.
- They can reside in cold wallets or on reputable exchanges such as Binance.
- Valuation is based on market prices at the time of application.
However, only highly liquid and widely recognized cryptocurrencies are likely to be accepted. While there is no official list, Siu suggests that factors like market capitalization, trading volume, and price transparency play a key role.
That said, stablecoins like USDT may also be considered—but their acceptance remains uncertain due to regulatory scrutiny around reserve backing and issuer transparency.
Step 2: Relocating Funds and Making Qualified Investments
Passing the initial asset verification is just the beginning. Applicants must then transfer HKD 30 million into Hong Kong within six months and invest it in designated financial instruments, including:
- Listed equities on the Hong Kong Stock Exchange
- Bonds issued by Hong Kong-based entities
- Real estate investment trusts (REITs)
- Other approved securities
Direct investment in cryptocurrencies (e.g., buying more BTC or ETH) does not fulfill this requirement. However, there may be a workaround.
Limited Partnership Fund (LPF) Route: A Strategic Option?
Applicants can set up a 100%-owned Limited Partnership Fund (LPF) in Hong Kong. Once established, this fund can technically invest in a broader range of assets—even potentially including Hong Kong-listed crypto ETFs, such as those offered by HashKey or potentially future offerings from banks like HSBC.
But here's the catch: the product must be registered with the Investment Promotion Office, and the fund manager must issue an official investment confirmation letter. If such documentation exists, the investment could count toward compliance.
This structure offers flexibility while maintaining regulatory alignment—a growing trend among high-net-worth individuals leveraging blockchain wealth.
Visa Timeline and Renewal Requirements
After completing both asset verification and qualified investment:
- A two-year visa is granted.
To renew, applicants must prove:
- The invested capital remains in Hong Kong.
- No unauthorized withdrawals or asset transfers have occurred.
- An annual audit report from a certified accountant confirms ongoing compliance.
Notably, investment performance does not matter—even if the portfolio loses value, as long as the original amount is still notionally invested and properly documented.
Major Challenge: Source of Funds (SOF) Verification
Despite progress, one hurdle remains formidable: proving the legitimate origin of crypto assets.
As AiYing Compliance highlights, many early adopters struggle with what’s known as the “coin out, cash unclear” dilemma. Common issues include:
- Coins acquired through mining with no formal records
- Peer-to-peer (P2P) trades conducted in cash
- Gifts from friends or family without traceable documentation
- Lost transaction histories due to exchange collapses (e.g., FTX)
Even if someone holds HKD 30 million worth of Bitcoin today, immigration officers will ask: Where did it come from?
Blockchain’s pseudonymity further complicates matters—while transactions are transparent, linking wallet addresses to real-world identities requires extensive forensic accounting.
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How to Strengthen Your SOF Case
Experts recommend proactive documentation:
- Save all exchange purchase records and bank transfer slips.
- Keep tax filings related to crypto gains.
- Maintain paper trails—even handwritten receipts—for early trades.
- Use regulated custodians or exchanges that provide auditable statements.
Starting now is crucial. The best evidence is created long before an application is submitted.
Why Hong Kong Is Leading in Crypto-Friendly Immigration
Compared to jurisdictions like Singapore—where crypto has long been accepted but source-of-funds rules are strict—Hong Kong offers a balanced approach. By embracing innovation while enforcing due diligence, it positions itself as a gateway for Web3 entrepreneurs and digital asset holders seeking residency in Asia.
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Frequently Asked Questions (FAQ)
Can I use any cryptocurrency for my application?
Currently, only Bitcoin and Ethereum have been successfully used. Others like USDT or altcoins lack official recognition. Acceptance depends on liquidity, market stability, and verifiability.
Do I need to sell my crypto to make the required investment?
Yes. You must convert your crypto into fiat and reinvest HKD 30 million into approved instruments like stocks or bonds in Hong Kong.
Is a cold wallet acceptable for asset verification?
Yes. Whether your crypto is stored in a cold wallet or on a major exchange, it can be verified—as long as you provide proof of ownership and current valuation.
How long does the entire process take?
From submission to visa issuance: typically 6 to 12 months, depending on document completeness and government processing times.
Can I manage my own investments under the LPF structure?
Yes. As the sole owner of a Limited Partnership Fund, you retain control over investment decisions—though annual audits are mandatory.
What happens if my investment loses value?
As long as you haven’t withdrawn funds or violated investment rules, depreciation won’t affect renewal. The focus is on compliance, not returns.
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Final Thoughts
Hong Kong’s acceptance of Bitcoin and Ethereum as valid assets for investment immigration signals a bold step toward financial modernization. While challenges remain—especially around source-of-funds verification—the path is now clearer than ever for crypto-native individuals seeking residency in one of Asia’s most dynamic financial hubs.
With proper planning, documentation, and professional guidance, blockchain wealth can open doors beyond digital finance—into new lives, new markets, and new opportunities.