On October 26, 2026, secondary trading began in the ChinaAMC HKD Digital Money Market Fund and ChinaAMC USD Digital Money Market Fund on an SFC-licensed virtual asset trading platform. The Hong Kong regulator’s announcement says trading in the existing authorised funds is available around the clock.
The SFC describes the approval as the world’s first secondary trading of tokenised public funds on an SFC-licensed platform. The announcement names the funds but leaves the trading venue unnamed. It gives no launch-day spreads or trading volume. Holders now have an additional way to buy and sell fund interests outside the primary subscription and redemption process.
The launch puts the SFC’s April framework into operation. Its requirements for pricing, liquidity and disclosure draw on Hong Kong’s exchange-traded fund rules and licensed virtual asset platforms. They address the gap between a secondary market that stays open continuously and the dealing arrangements of the underlying fund.
Buying a token is not redeeming at NAV
The secondary-trading circular permits retail investors to use on-screen automatic order matching on licensed platforms. Before a platform can execute a client’s trade, the account must hold sufficient capital or fungible product holdings to cover it. Investors trade through a funded platform account, subject to the platform’s existing trading rules and risk controls.
The execution price can differ from the value of the fund’s portfolio. Platforms must alert investors when a proposed trade deviates significantly from real-time or near-real-time indicative net asset value per unit. Each product’s features must reasonably determine the threshold for that alert. Investors get the comparison with the portfolio estimate before accepting the quoted trade.
Platforms must also tell investors they can subscribe or redeem in the primary market at NAV. That route has normal dealing windows, possible liquidity-management tools and forward pricing. A holder who chooses redemption can receive the next calculated NAV, which may be above or below the secondary-market price visible when the holder decides to exit.
Online interfaces must display both indicative NAV and the last official NAV. They must give the sources for those values and say how often they update. The circular says indicative NAV is typically updated at least every 15 seconds during trading hours. Before onboarding clients for these products, platforms and connecting brokers must obtain confirmation that they understand the secondary-trading risks.
Liquidity depends on market makers
Product providers must use their best endeavours to arrange at least one market maker for each product. At least one market maker must give no less than three months’ notice before terminating its arrangement. Providers must monitor trading and liquidity, keep in contact with market makers and prepare contingency plans.
Platforms must supervise market makers separately. They must assess their competence and resources, then monitor performance against agreed terms. Those terms must include commitments on bid-ask spreads, quote sizes, how long orders remain available and participation rates. A continuously open market alone tells a holder neither the price nor the size available when they need to sell.
The circular requires explicit disclosure that trading may be thin and prices may carry large premiums or discounts to NAV, particularly outside normal Hong Kong financial-market hours and over weekends. It also identifies price fragmentation across trading channels and reliance on market makers. These secondary-market risks sit alongside the investment risks of the fund itself.
Providers must connect the primary and secondary markets operationally. Subject to limited exceptions, they must appoint licensed or registered distributors expected to process third-party creation and redemption requests. Providers must also arrange transfers with platforms in both directions: tokens created in the primary market must be able to trade in the secondary market, and tokens bought there must be able to return to the primary route for redemption.
Providers must immediately notify the SFC if primary or secondary dealing stops, or if market making ceases, is disrupted or is suspended. They must inform investors as soon as practicable. The notification must assess the impact and include remedial action and a contingency plan. These reporting obligations apply to market-maker disruptions as operating events, beyond any change in the displayed spread.
Existing portfolios, different dealing classes
ChinaAMC’s HKD fund documentation describes a portfolio of short-term deposits and high-quality money-market instruments. It targets returns in Hong Kong dollars in line with prevailing money-market rates. Alongside the underlying investment exposure, the documentation lists blockchain, digital-asset security, cybersecurity, delay, operational and platform risks.
The product page distinguishes a Tokenized Class (Primary only) from a Tokenized Class (Primary and Secondary). Conversion from the former to the latter currently carries no conversion fee. Whether an existing holding can trade directly depends on the dealing rights of its class. The page names Standard Chartered Bank (Hong Kong) as tokenisation agent, digital platform operator, token custodian and administrator. Those service roles leave the secondary trading venue unidentified.
The USD fund’s September factsheet reports fund size of USD 567.81 million as of September 30, 2026. The figure covers the fund at that date, not the amount placed into secondary trading or launch-day turnover. The factsheet names Standard Chartered Trustee (Hong Kong) as custodian and Standard Chartered Bank (Hong Kong) as administrator and registrar.
The USD fund is actively managed, with primarily dollar-denominated instruments and concentration risk in Greater China and the United States. It does not track an index. ChinaAMC explicitly describes it as an investment fund, not a bank deposit. Holders remain exposed to the portfolio and its management when tokenisation changes the way their ownership can be transferred.
The SFC also describes prospective links to tokenised deposits through its work with the Hong Kong Monetary Authority under Project Ensemble. It says those capabilities could improve settlement and asset mobility. The regulator will monitor trading before considering a broader product scope. Its announcement gives no timetable for that expansion.
