Dialogue organizer: Hong Kong investment immigrants recognize Bitcoin and Ethereum as asset proof for the first time, details of the application process, and what difficulties are there

Editor: Wu Shuo Blockchain

In this conversation, Hong Kong accountant Xiao Yaohe and Wu Shuo shared the latest progress in investment immigration cases and related policy trends of his clients. On February 7, 2025, a customer used Ethereum worth HK$30 million as asset proof and applied for investment immigration to the Hong Kong Investment and Promotion Agency to proof of investment immigration. In October 2024, a customer who used Bitcoin as proof of assets was also approved, which was the first case in Hong Kong to apply for investment immigration approval using cryptocurrency as assets. The related customers are basically from mainland China.

Mr. Xiao is the deputy managing partner of Hongyuan Accounting Firm Co., Ltd. and has more than 25 years of experience in the accounting and auditing industry. He has served as chief accountant and administrative manager in listed companies and multinational corporations on the Stock Exchange of Hong Kong.

Audio transcription is done by GPT and there may be errors. Listen to the full podcast:

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https://www.xiaoyuzhoufm.com/episodes/67a740e8d74435e4a3e2cfbb

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https://youtu.be/LRuUjwNqJ9I

Please introduce these two cases where cryptocurrencies are used as asset proof for investment immigration

Xiao Yaohe: There are two temporary cases where customers who use cryptocurrencies to prove their assets are successful. The first case was in October 2024, using Bitcoin. This is the second success story, using Ethereum (ETH). There are two other things currently being done.

In the investment immigration program, the government or our accountant needs to submit a report that proves that a person has HK$30 million in assets. Like Bitcoin or cryptocurrency (Crypto) can also be used as an asset, and it is recognized.

So this investment immigration plan does not require you to invest in Hong Kong. Is it okay to hold assets worth HK$30 million?

Xiao Yaohe: This is just the first step. First, the applicant needs to prove that he owns HK$30 million in assets, no matter where these assets are -whether in Hong Kong, domestic, Africa, or Australia. After proving that the assets are correct, pass the first level, you need to bring the funds to Hong Kong for investment, and you must invest in designated assets. Simply put, invest in stocks, bonds, etc. of listed companies. You have to invest your funds in Hong Kong.

Currently, these two customers, one uses Bitcoin and the other uses Ethereum, have passed the first step of capital verification, proving that they have HK$30 million in assets. The second step below is that they need to bring HK$30 million in investment to Hong Kong within half a year.

Is this investment only investing in stocks, not assets such as Bitcoin and Ethereum ETFs?

Xiao Yaohe: The original intention of this investment immigration plan is mainly to require speculators to invest in Hong Kong's stock market, capital market and bond market, which is the most important. If you want to invest through other methods, such as the ETF you mentioned, it is barely possible.

Because there is a way, first you need to invest HK$30 million in a limited partnership fund you open yourself. This company is 100% owned by you, and you can supervise the company, but there are no clear requirements for how to invest within the company.

Whether this HK$30 million can be invested in Bitcoin ETFs issued locally in Hong Kong is still uncertain. If HSBC sells this product to you, they must register at the Investment Promotion Office and be able to provide a certificate that can be proved. If they can issue certificates, it is equivalent to a product that can be invested in.

So the process of investing in immigration is to first prove that there are 30 million Hong Kong dollars in assets (bitcoin and Ethereum can be used), and the Hong Kong government will issue them a two-year visa?

Xiao Yaohe: No, the investment needs to be completed within half a year, and the visa will be issued after completion. The term is two years, and the visa will be renewed after two years. When renewing, you need to prove that the investment is still continuing. Every year you need an accountant to issue a report to prove that the total investment is not less than HK$30 million and to ensure that you have not transferred other investments after the investment. But it doesn't matter whether the investment is a loss.

Cryptocurrency assets can be proven by putting in cold wallets or large exchanges such as Binance, and both methods are feasible.

Recalling the case of the Hong Kong government 's first approval of cryptocurrency assets

Xiao Yaohe: Customers who use cryptocurrency as assets to apply for investment immigration are basically from the mainland. There shouldn’t be many cases of investment immigration related to other cryptocurrencies, because in October 2024, I called the Investment Promotion Office and asked them if there were any similar cases, and they said no. So I was the first one at that time.

The first case was in October 2024. They said at the time that they had never dealt with similar cases and told me, "It doesn't matter, you do it first, let's discuss it internally." Then about a month later, the first case was successfully approved. I did not participate in their communication, mainly because they were discussing this matter internally.

In addition to Bitcoin and Ethereum, will the Hong Kong government admit other currencies such as USDT?

Xiao Yaohe: In fact, there is no official response, and there is no clear official statement that it means that which currencies and which ones do not recognize are all crossing the river by feeling the stones. You can try other currencies, but we currently offer two success stories. But from my point of view, the key is the liquidity of these cryptocurrencies and whether they have a very reliable market value.

However, some comments pointed out that in Singapore, cryptocurrencies can always be used as proof of assets, and the difficulty is that customers cannot provide proof of the initial investment funds for cryptocurrencies.

AiYing Compliance article stated that the biggest difficulty is indeed the proof of funding (SOF). There is a classic contradiction in the cryptocurrency circle - "You can take out the coins, but you can't explain the money." Early players had many "black history": many people got coins through mining, over-the-counter transactions or even "friend gifts" in their early years, and they could not produce bank statements or transaction records at all. The exchange's "burst" dragged its back: platforms such as FTX and Binance have encountered compliance problems, and some users' historical data is lost or not recognized by regulators. Anonymity is a double-edged sword: although blockchain is transparent, it is difficult to directly link the wallet address and real identity, and it is difficult for accountants and the Immigration Bureau to trace the source of funds. For example: A big dealer spent 1 million Hong Kong dollars to buy Bitcoin in 2017, and now it is worth 10 million Hong Kong dollars. But the transfer records of that year have long disappeared, or they are using cash transactions. How do you prove that the 100,000 yuan is legal income? If you can't explain this, the immigration application will be disappointed. Therefore, it is recommended to leave evidence from the first day: transfer records of buying coins, exchange bills, tax proofs, and even a handwritten receipt are better than nothing.