La era de "apertura de cuentas en gris" en las acciones de Hong Kong y EE. UU. ha terminado, ¿a dónde más puede ir tu dinero?

Original | Odaily Planet Daily (@OdailyChina)

Author｜jk

May 24th, Hong Kong Tsim Sha Tsui Haiphong Road, eerily quiet to the point of discomfort.

A week ago, this was still the “one-stop street” for mainland investors to open accounts, with broker booths and mobile trading vans lined up, crowds bustling. Zero commission on Hong Kong stock accounts, free stocks, support for IPO subscriptions, reduced address proof requirements… To attract mainland clients, brokers almost lowered the thresholds to the floor.

However, just seven days later, the doors slammed shut. Now, mainland clients wanting to open a Hong Kong stock account must not only sign a written declaration promising funds come from abroad and that materials have never been forged, but after signing, they may also face a “rejection.”

All these changes began on May 22. Simultaneous regulatory measures from both sides directly impacted millions of mainland investors investing in overseas markets via Hong Kong brokers.

How fierce is this regulatory storm? What are the real experiences of mainland residents opening accounts in Hong Kong now? What compliant channels remain for investing in overseas assets? Odaily Planet Daily unpacks these questions for readers.

1. Cross-strait joint effort ends the “gray channel” for Hong Kong and US stock investments

On May 22, Hong Kong and mainland regulators almost simultaneously took action, striking from both north and south.

The Hong Kong Securities and Futures Commission (SFC), after reviewing the account opening procedures of 12 brokerage firms, issued a strongly worded circular. The document pointed out multiple major deficiencies: insufficient due diligence in account opening documents, acceptance of suspicious or forged documents during account opening, and clear weaknesses in managing cross-border agency relationships with overseas intermediaries. The SFC explicitly stated that these accounts might be used for illegal trading, with money laundering risks not to be ignored.

For mainland investors, the circular’s appendix listed additional “three-piece” requirements: 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 name. The core contents of the declaration include: confirming all investment funds originate from legal sources outside mainland China, that accounts have never been closed due to suspicious documents, that any changes must be reported to the broker within 7 business days, and agreeing to disclose relevant information to law enforcement agencies.

The SFC requires all licensed institutions to conduct immediate self-inspections, close accounts opened with suspicious or forged documents, and “dormant accounts” with zero balance and no transactions for 12 months. Senior management is explicitly named, and those seriously negligent in compliance may face regulatory and law enforcement actions.

Almost simultaneously, the China Securities Regulatory Commission (CSRC), together with eight ministries (MIIT, Ministry of Public Security, PBOC, SAMR, CSRC, Cyberspace Administration, SAFE), officially issued the “Implementation Plan for the Comprehensive Rectification of Illegal Cross-border Securities, Futures, and Fund Activities”—a two-year concentrated rectification period during which existing accounts can only sell or transfer out funds, with no new accounts allowed. Administrative penalties for illegal operations by entities like Tiger Securities, Futu Securities, and Changqiao Securities are also announced in advance. The scope, intensity, and enforcement resolve of this combined effort are rare in recent financial regulatory history.

These two documents, from different regulatory systems, point to the same issue: the long-standing gray area where many mainland investors used Hong Kong brokers to invest in Hong Kong and US stocks is officially ending. This time, the regulators are serious.

But to understand why this crackdown is so resolute, we must look back at the past two to three years—how “wide” was this channel?

From early 2023 to early 2025, Hong Kong stocks and US stocks surged in turn, with numerous new stock IPO opportunities emerging, sharply increasing mainland investors’ demand for account opening. At that time, internet brokers like Futu, Tiger, and Changqiao, with smooth Chinese-language apps, low or zero commissions, and RMB deposit support, aggressively penetrated the mainland market. Some Hong Kong brokers did not require address proof or substantive address verification, and even allowed deposits via stablecoins (USDT). Opening an account was almost just a click away.

As early as July 2016, the CSRC issued risk warnings, specifically mentioning Tiger Securities, Futu Securities, and others providing offshore securities trading services. By late 2022, the CSRC launched special rectification efforts against these offshore brokers, but with limited effect—existing accounts continued to operate normally, and some platforms even continued accepting new mainland clients through various loopholes after rectification.

This time, the authorities are no longer lenient. The policy focus has shifted from restricting new accounts to rectifying existing ones—all previous loopholes have been explicitly closed by regulators.

2. “Written declaration” in hand, account opening still fails

With the new rules, the most proactive have already bought tickets to Hong Kong, but account opening is not smooth. Over the past week, social media has circulated many photos titled “Mainland Investor Written Declaration,” all from mainlanders who personally visited Hong Kong brokers’ offline stores to try opening accounts.

Blogger AB Kuai.Dong described a friend’s experience: the friend traveled to Hong Kong specifically to apply for a US/HK stock account at Yingli Securities’ store, being asked to sign the “Mainland Investor Written Declaration”, filled out all materials, waited over an hour, but was still told “account review failed”. Blogger Simon also recorded similar experiences: walk-in account opening, signing the declaration, waiting over an hour, and ultimately being rejected.

From multiple accounts, the declaration texts are highly consistent with the requirements in the SFC circular appendix, indicating that brokers have quickly implemented the new regulations.

It’s worth noting that signing does not guarantee success; refusing to sign makes account opening impossible. Blogger Li Zhi gave a straightforward interpretation: brokers, by having clients sign this declaration, are doing two things: one, shifting compliance responsibility—if something goes wrong, they can say “the client declared the funds are legal”; two, screen clients—since most mainlanders trading Hong Kong and US stocks via Hong Kong brokers are already in a legal gray area, this declaration requiring them to confirm that funds come from abroad is itself a gatekeeper.

A report by CaiLianShe on May 27 confirmed this phenomenon: nearly all brokers in Hong Kong now require clients to sign a declaration of legal fund sources when opening accounts offline through bank channels from May 26 onward. An employee of a Hong Kong foreign bank also confirmed the addition of this requirement.

The new document is called “Cross-border Disclosure Declaration (Applicable for Investment Account Opening).” According to the document shown by clients, the core content states: the account holder must confirm that “all funds supporting investment activities and related settlements come from legal sources outside mainland China”; also, mainland residents should note that the account services are only for investors residing in Hong Kong (e.g., living or working there), and funds must be legal and compliant.

The document also states that, to comply with Hong Kong regulatory requirements, banks may request proof of fund sources; failure to provide such proof may result in service denial or termination of existing accounts. Notably, this affects not only new accounts but also those opened between May 23-25, 2026, which must re-sign the new cross-border declaration—no transitional period is provided.

3. Who can still open accounts? Existing compliant channels overview

This tightening directly shut down the mainland access points of major online brokers, but not all channels are closed.

Brokers that have completely ceased accepting new mainland clients: Futu Securities, Tiger Securities, Changqiao Securities, Huasheng Securities. These four have closed new account openings; some existing accounts still trade normally, but are only allowed to sell out, with a two-year transition period before full withdrawal.

Currently, a limited number of Hong Kong licensed brokers still retain channels for mainland residents (as of publication, the situation remains dynamic):

Yingli Securities is among the few still supporting direct account opening for mainland users. It holds Hong Kong SFC licenses No. 1, 4, and 9, with a US subsidiary registered with SEC and regulated by FINRA, with a relatively complete compliance system. However, recent social media feedback indicates that after the new regulations, Yingli’s account approval process has tightened significantly, with many walk-in failures. Success largely depends on whether applicants truly meet the “funds originate outside mainland China” condition.

Fosun Wealth and Zhi Fu Securities are two other options still maintaining channels for mainland users.

Some bloggers claim that Fosun’s latest official statement states that the new policy no longer requires address proof, but applicants must use VPN or visit Hong Kong in person; users with Hong Kong virtual bank cards like ZhongAn, Tiansheng, HSBC, must have location set to Hong Kong during application. Odaily has confirmed with Fosun that this is a rumor; account opening still requires compliance with the above policies.

For users with overseas status (students, work visa holders, permanent residents abroad), conditions are relatively relaxed, but proof of funds from abroad is still required.

Opening an account is just the first step; how to transfer money in is the core constraint of the new regulations.

The SFC circular explicitly states that deposits, withdrawals, and settlements for mainland investor accounts must be made through accounts opened in the client’s name at licensed banks in Hong Kong or qualified jurisdictions. Using third-party or unclear sources to transfer funds has been explicitly blocked. This means that previous methods like currency exchange via money changers, friend transfers, or USDT deposits are no longer compliant.

In practice, successful deposits require holding a real-name Hong Kong bank account. Virtual banks like ZA Bank and Tiansheng support FPS fast transfers, allowing normal deposits into broker accounts; some brokers (like Yingli Securities) support quick deposit via eDDA linked to ZA Bank. Therefore, for users without a Hong Kong bank account, opening a securities account before securing a Hong Kong card has become an unavoidable step.

Overall, after May 2026, the compliant paths for mainland investors to trade Hong Kong and US stocks will be significantly narrowed, but not entirely closed. Based on current conditions, several routes remain viable:

Most reliable path: compliant identity, compliant fund channels, and a Hong Kong bank account. Students, overseas work visa holders, Hong Kong/Macau residents with overseas proof documents, who meet the “funds come from outside mainland China” condition, can still open accounts with licensed brokers like Yingli, Fosun, Zhi Fu. Tourists face higher failure risks, especially regarding fund sources.

Policy-compliant channels: Hong Kong Stock Connect, QDII, Cross-border Wealth Management Connect. These are the directions regulators prefer to channel funds, despite restrictions and quota limits. Funds will gradually shift into these compliant channels.

On-chain paths: Platforms like Hyperliquid, xStocks offer technical alternatives. For users able to meet platform requirements, these are options. However, such on-chain products have clear compliance boundaries. Recently, many projects offering Hong Kong stock crypto products have issued notices stating they will cease such offerings in response to recent Hong Kong regulations. Most of these products do not accept mainland Chinese users, making them more suitable for overseas residents.

Conclusion: Tightening but opportunities remain

This crackdown is a concentrated release of long-standing contradictions. Hong Kong brokers’ unchecked expansion into mainland clients over recent years brought substantial user growth but also significant compliance risks—fake documents, unclear fund sources, dormant accounts misused, etc. The synchronized regulatory actions send a clear signal: the era of gray profits from this channel is over.

For mainland investors still wishing to hold Hong Kong and US stocks, the road ahead will be tougher, but compliant options still exist. The choice depends on personal status, risk appetite, and self-judgment of compliance boundaries. Regardless, before signing any declaration, be fully aware: once signed, legal responsibility falls on oneself.

(Odaily note: This article synthesizes official circulars from the Hong Kong SFC, announcements from the mainland CSRC, reports from Caixin, Yicai, and social media firsthand information. For informational purposes only; not investment advice.)