Strict Adherence to Global Regulatory Frameworks
The business model of AQCAN EX fully complies with the regulations of Hong Kong and other major global jurisdictions. We operate **without requiring** specific financial licenses based on the following grounds:
Compliance Basis in Hong Kong:
* **Not subject to MSO licensing:**
According to Hong Kong’s *Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO)*, only “money changing” and “remittance” services require an MSO license. Since we do not deal with currency exchange or cross-border remittances and only provide API routing, we are exempt.
* **Not subject to VASP licensing:**
Under the *Hong Kong 2023 Virtual Asset Service Providers (VASP) Ordinance*, VASP licenses apply to “virtual asset trading platforms” or “custodians.” AQCAN EX neither operates a trading platform nor offers custody services, and is therefore exempt.
* **Not subject to payment system licenses:**
According to the *Payment Systems and Stored Value Facilities Ordinance*, licenses are required for entities accessing local payment systems or issuing stored value facilities. Since AQCAN EX does not connect to local payment systems, no license is needed.
Global Jurisdictions – General Principles:
* **EU/UK:**
Under the *Payment Services Directive 2 (PSD2)*, pure API aggregators are not considered “payment institutions” and are exempt from licensing.
* **USA:**
State-level Money Transmitter Licenses (MTL) apply only to entities handling funds. Middleware providers aggregating licensed API gateways are typically exempt.