A era de "contas cinzentas" na bolsa de Hong Kong e nos EUA chegou ao fim, para onde mais pode ir o seu dinheiro?

Original | Odaily Planet Daily (@OdailyChina)

Author｜jk

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

A week ago, this was still the “Account Opening Street” for mainland investors, with broker booths and mobile trading vans 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 gates 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 may also face a “rejection”.

All these changes began on May 22. Simultaneous regulatory actions 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 are available for investing in overseas assets? Odaily Planet Daily unpacks these questions for readers.

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

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 onboarding, 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 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 declaration’s core contents include: confirmation that all investment funds come from legal sources outside mainland China, that the account has never been closed due to suspicious documents, that any changes must be notified within 7 business days, and consent 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” — 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 are 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 grey 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 — 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, 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 support for RMB deposits, aggressively penetrated the mainland market. Some Hong Kong brokers did not require address proof or did not 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 lenient. The policy focus has shifted from restricting new entries to rectifying existing ones — all previous space has been explicitly closed off.

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

With the new rules, the fastest to act already bought tickets to Hong Kong, but opening accounts has not been smooth. Over the past week, social media has circulated many photos titled “Mainland Investors’ Written Declaration,” all from mainlanders who personally visited Hong Kong brokers’ offline outlets 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’ storefront, was 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: a friend walked in to open an account, signed the declaration, waited over an hour, and was also rejected.

From multiple accounts of the declaration texts posted online, the content closely matches 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 approval; 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 grey zone, this declaration requiring them to confirm that funds come from overseas is itself a gatekeeper.

A report by CaiLianShe on May 27 confirmed this phenomenon: nearly all Hong Kong brokers now require signing a “Cross-border Disclosure Declaration (for investment account opening)” when opening accounts through offline bank channels in Hong Kong from May 26 onward. A Hong Kong foreign bank official also confirmed to CaiLianShe that the new declaration requirement is indeed in place.

The core content of this document states: the account holder must confirm that “all funds supporting investment activities and related settlements come from legal sources outside mainland China”; and that mainland residents should be aware that the account services are only for investors residing in Hong Kong (e.g., living or working there), and that funds must be legal and compliant.

The document also clarifies 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. Not only new accounts are affected; a bank official confirmed that mainland investors who opened accounts between May 23 and 25 also need to sign the new cross-border declaration — with no transitional period.

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

This tightening directly shut down the mainland entry points for 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 Hong Kong licensed brokers still offer limited 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 the SEC and regulated by FINRA, with a relatively sound compliance system. However, recent social media feedback indicates that after the new rules, Yingli’s approval process for mainland residents has tightened significantly, with many walk-in applications failing. Whether an application succeeds 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: no longer requiring address proof, but applicants must use VPN or visit Hong Kong in person; users with UnionPay, Tiansheng, HSBC Hong Kong virtual bank cards must have their location set to Hong Kong during application. Odaily has confirmed with Fosun that this policy is a rumor; account opening still requires compliance with the above-mentioned rules.

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 equally a 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 to transfer funds has been explicitly blocked. This means that previous methods like currency exchange shops, friends’ transfers, or USDT deposits to bypass foreign exchange controls are no longer compliant.

In practice, successful deposits depend on 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 eDDA deposits via ZA Bank. Therefore, for users without a Hong Kong bank account, opening a securities account before obtaining a Hong Kong card has become an unavoidable step.

Overall, after May 2026, the compliant paths for mainland investors to trade HK 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 workers, Hong Kong and Macau residents with overseas proof documents, meeting the “funds come from outside mainland China” condition, can still open accounts with licensed brokers like Yingli, Zhi Fu, Fosun. Tourists may face some rejection, 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 scope is limited and quotas are capped, they are fully compliant, and affected mainland investors’ funds are expected to gradually shift into these channels.

On-chain paths: Hyperliquid, xStocks platforms offer technological alternatives. For users able to meet these 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 recent Hong Kong regulations. Most of these products do not accept mainland Chinese users, making them more suitable for overseas residents.

Conclusion: Tightening significantly, but opportunities remain

This crackdown 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 account abuse. The synchronized regulatory actions send a clear signal: the era of grey profits from this channel is over.

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 status, risk appetite, and self-judgment 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 CaiLianShe, First Financial, and social media firsthand information. For informational purposes only; not investment advice.)