The Circular of Hong Kong's SFC of Dec.11, 2017 is addressed to Licensed Corporations and Registered Institutions.
The SFC first acknowledges that Bitcoin Futures contracts have been allowed in the US. Those contract meet the criterias of "futures contract" under the definition of the Securities and Futures Ordinance(SFO). Therefore, even though the underlying assets of Bitcoin Futures are not regulated under the Securities and Futures Ordinance, Bitcoin Futures traded on and subject to the rules of those exchanges are regarded as "futures contracts" for the purposes of the SFO.
Accordingly, parties carrying on a business in dealing in Bitcoin Futures are required to be licensed unless an exemption applies. Service providers, intermediaries, marketing and advisory services might also be regulated activities.
Moreover the SFC notice an increase in cryptocurrency-related investment products such as cryptocurrency options, swaps and contracts for differences. Depending on their terms and features, some cryptocurrency-related investment products may be regarded as "securities" as defined under the SFO and therefore parties may be subject to the SFC's licensing, conducts and authorisation requirements. Otherwise, parties might be committing a criminal offence.