Kristi Swartz

Advising Dubai Virtual Assets Regulatory Authority (VARA) on drafting of digital asset regulations for the region. The regime covers all aspects of digital assets, including crypto-currencies and NFTs, as well as providing a framework for various digital asset-related services such as custodians, crypto-exchanges and DeFi.

 Advising Hong Kong’s first Securities and Futures Commission licensed equity crowdfunding platform on its successful Securities and Futures Commission licensing applications for type 1 (dealing in securities) and type 4 (advising on securities) regulated activity.

Advising a Hong Kong licensed online lending platform on its review and restructuring in compliance with the SFC regulations. This included balancing the Money Lender’s Ordinance alongside the Securities Futures Ordinance ("SFO") (Collective Investment Schemes) and HKMA requirements for Deposit Taking Authorities.

Advising a global remittance company following its acquisition by a major PRC-based technology firm on its proposed offering of US-based virtual bank accounts to customers in Hong Kong.

Advising a major cryptocurrency exchange on their proposed market entry strategy in Japan including regulatory licenses and policy advice on market entry strategy and current appetite for additional licensees in the Japan market.

Advising a UK-headquartered alternative payments company offering prepaid debit cards for online transactions. Advised on the role of its Hong Kong operations in servicing the Asian market. Conducted a review of the client’s operating model and relationships with merchants and customers and analyzed the and Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).

Advising a global payment specialist on intra-group transfer of shares in a wholly owned subsidiary as part of its corporate reorganization of its US, European and Hong Kong subsidiaries and affiliates.

Advising a FinTech company on its proposed issuance of its Hong Kong Dollar-linked stablecoin.

Advising a digital private wealth platform on the acquisition of Hong Kong regulated entity holding Securities and Futures Commission licences for type 4 (advising on securities) and type 9 (asset management) regulated activity.

Advising a multinational technology company on its regulatory and compliance policy for its fraud protection service implemented for e-commerce payment transactions by various regulatory bodies, including the Customs & Excise Department, Securities and Futures Commission, Hong Kong Monetary Authority and Office of the Privacy Commissioner for Personal Data in consideration of money services, credit rating services and sharing of transactional data.