A era de "contas cinzas" para ações de Hong Kong e dos EUA chegou ao fim, para onde mais seu dinheiro pode ir?

Original | Odaily Planet Daily (@OdailyChina)

Author｜jk

May 24th, in Tsim Sha Tsui, Hong Kong, Haiphong Road, the scene was so deserted that it felt somewhat unsettling.

A week ago, this was still the “one-stop street” for mainland investors opening accounts, with broker booths and mobile trucks lined up, crowds bustling. Zero commission on Hong Kong stock accounts, free stocks, support for IPO applications, weakened 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 overseas and materials have never been forged, but after signing, they might still 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.

一、两岸联手，终结港美股投资“灰色通道”

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

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 the process, 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 significant money laundering risks.

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 the account has 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 demanded all licensed institutions 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 was explicitly named, and those seriously negligent in compliance could face regulatory and law enforcement actions.

Almost simultaneously, the China Securities Regulatory Commission (CSRC), together with eight ministries (MIIT, Ministry of Public Security, People’s Bank of China, State Administration for Market Regulation, China Financial Regulatory Authority, Cyberspace Administration, State Administration of Foreign Exchange), officially issued the “Implementation Plan for Comprehensive Rectification of Illegal Cross-border Securities, Futures, and Fund Activities” — setting 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 were also announced in advance. The scope, intensity, and enforcement resolve of this combined action 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 coming to an end. 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 — just how “wide” was this channel?

From 2023 to early 2025, Hong Kong stocks and US stocks surged in turn, with numerous new stock IPO opportunities emerging, greatly boosting mainland investors’ demand for accounts. At that time, internet brokers like Futu, Tiger, and Changqiao, with smooth Chinese-language apps, low or zero commissions, and support for RMB deposits, aggressively penetrated the mainland market. Some Hong Kong brokers didn’t require address proof or didn’t verify addresses substantively, 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 had launched special rectification efforts targeting these offshore brokers. However, the effect was limited; 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 holding back. The policy focus has shifted from restricting new accounts to rectifying existing ones — all previous loopholes have been explicitly closed by regulators.

二、"书面声明"在手，开户仍然失败

With the new rules, the fastest to act already bought tickets to Hong Kong, but account opening was not smooth. Over the past week, social media 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”. After filling out all materials and waiting over an hour, they were 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 shared declaration texts, the content aligns closely with the requirements in the SFC circular appendix, indicating that brokers have quickly implemented the new regulations.

It’s worth noting that signing the declaration does not guarantee account approval; refusing to sign makes approval 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 explicitly requires them to confirm that funds come from overseas, which is itself a gatekeeping measure.

A report by CaiLianShe on May 27 confirmed this phenomenon: nearly all brokers in Hong Kong now require signing a “Fund Source Declaration” when opening accounts offline through bank channels from May 26 onward. An employee of a Hong Kong foreign bank also confirmed to CaiLianShe that the new declaration requirement is indeed in place.

The document titled “Cross-border Disclosure Declaration (Applicable to Investment Account Opening)” states that: the account holder must confirm that “all funds supporting investment activities and related settlements come from legal sources outside mainland China”. It also reminds mainland residents that the service is only for investors residing in Hong Kong (e.g., living or working there), and that funds must be legal and compliant.

The document further states that, to comply with Hong Kong’s regulatory requirements, banks may request proof of funds; failure to provide such proof could lead to service denial or termination of existing accounts. Notably, this affects not only new accounts. An official customer service representative of a Chinese bank confirmed that investors who opened accounts between May 23 and 25, 2026, must also sign the new cross-border declaration — with no transitional period given.

三、谁还能开户？现存合规窗口梳理

This tightening directly shut down the mainland entry 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, with a two-year transition period before full withdrawal.

Currently, a few licensed Hong Kong brokers still offer limited channels for mainland residents (as of the article’s publication, this 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 the SEC and regulated by FINRA, making its compliance system relatively robust. However, recent social media feedback indicates that after the new rules, Yingli’s account approval process for mainland residents has become stricter, with many walk-in failures. Whether an account can be approved largely depends on whether the applicant can prove “funds come from outside mainland China.”

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

Some bloggers claim that Fosun’s official latest policy states that: no address proof is required anymore, but applicants must use VPN or visit Hong Kong in person; users with Hong Kong virtual bank cards like ZhongAn, Tiansheng, HSBC, must have their location set to Hong Kong during application. Odaily has confirmed with Fosun that this rumor is false; 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 overseas funds 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 only be made through accounts opened in the client’s name at licensed banks in Hong Kong or qualified jurisdictions. Using third-party or source-unknown channels for fund transfers has been explicitly blocked. This means that previous methods like currency exchange through 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) also support quick deposits via eDDA linked to ZA Bank. Therefore, for users without a Hong Kong bank account, opening a Hong Kong card before opening a securities account 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. Several routes remain viable:

Most reliable path: compliant identity, compliant fund channels, and a Hong Kong bank account. Students, overseas workers, 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, Zhi Fu, Fosun. Tourists face higher failure risks, especially regarding proof of funds.

Policy-compliant channels: Hong Kong Stock Connect, QDII, Cross-border Wealth Management Connect. These are the directions regulators hope to guide funds into. Although product varieties are limited and quotas capped, they are fully compliant, and affected investors’ funds are expected to gradually shift into these channels.

On-chain paths: Hyperliquid, xStocks platforms offer technical alternatives. For users able to meet platform requirements, these are options. However, these on-chain products have clear compliance boundaries. Recently, many projects offering Hong Kong stock crypto products have issued notices stating they will no longer provide such products in response to Hong Kong’s new regulations. Most of these products do not accept mainland Chinese users, making them more suitable for overseas residents.

结语：大幅收紧，但机会依然存在

This tightening is a concentrated release of long-standing contradictions. Hong Kong brokers’ unregulated expansion into mainland clients over recent years brought substantial user growth but also created many compliance risks, including forged documents, unclear fund sources, and dormant accounts being misused. The synchronized crackdown from both sides sends a clear signal: the era of gray profits from this channel has ended.

For mainland investors still wishing to hold Hong Kong and US stocks, the road ahead will not be easier, but compliant options still exist. The choice depends on personal identity, risk tolerance, and self-assessment of compliance boundaries. In any case, before signing any written 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 firsthand social media information. For informational reference only, not investment advice.)