Compare
Side-by-side financial licensing comparison
Use this table to orient the first licensing discussion. Then use the tools and official links to test the route against your exact facts.
Asset managementBrokerage/dealingInvestment advisoryFintechFamily officeCross-border business
| Jurisdiction | Main regulator | Common route | Typical applicants | Key individuals | Capital/resources | Timeline | Difficulty | Public register | Best for | Watch-outs |
|---|---|---|---|---|---|---|---|---|---|---|
| Hong Kong | Securities and Futures Commission | SFC licensed corporation for Type 1 dealing in securities; SFC licensed corporation for Type 4 advising on securities | Asset managers serving professional investors; Securities brokers and introducing brokers; Investment advisers and research providers | Licensed representatives for regulated functions; At least two responsible officers for each regulated activity | Capital and liquid capital expectations depend on regulated activity, whether client assets are held, and other SFC financial resources requirements. | Typically 4 to 8+ months after a serious application pack is ready. | High | Open | Managers and intermediaries needing a respected Asia base with deep capital markets connectivity and a clear SFC regulated activity framework. | Do not treat Type 9 as a substitute for all dealing or advisory activity without checking the actual workflow. Actively marketing into Hong Kong can matter even where services are provided from outside Hong Kong. Responsible officers in name only are a practical red flag. |
| Singapore | Monetary Authority of Singapore | MAS Capital Markets Services licence for fund management; MAS CMS licence for dealing in capital markets products | Fund managers serving accredited or institutional investors; Broker-dealers and product distributors; Corporate finance advisers | Appointed representatives for regulated activities conducted on behalf of CMS licensees or exempt financial institutions; Fit and proper assessment for directors, representatives, substantial shareholders, and key persons | Capital and financial resource expectations depend on activity, client type, custody, and the specific licence or exemption path. | Typically 4 to 9+ months depending on route and readiness. | High | Open | Asia-focused managers, private markets firms, and fintech or capital markets businesses that can operate with disciplined client classification and governance. | Do not rely on an exemption without mapping the exact entity, activity, client, and marketing facts. Representative status and individual conduct controls are not afterthoughts. Fund management, fund distribution, and advice can create different regulatory questions. |
| United Kingdom | Financial Conduct Authority | FCA Part 4A authorisation for investment firms; Managing investments or portfolio management permissions | Discretionary investment managers; Wealth and stockbroking firms; Investment advisers | Senior Manager Function approval where a controlled function applies; Certification for relevant staff under SM&CR where applicable | Capital and prudential requirements depend on the permissions, MiFID/MIFIDPRU status, client asset position, and business model. | FCA service standards distinguish complete and incomplete applications; practical timelines often run 4 to 10+ months. | Very high | Open | Firms that need a UK regulatory footprint, institutional credibility, or access to UK clients and markets with mature governance. | A consultant can help, but the FCA still expects the firm to understand and own its application. SM&CR is not just an HR exercise; it shapes accountability evidence. Consumer-facing and client asset models can materially increase scrutiny. |
| United States | SEC / FINRA / state securities regulators | SEC investment adviser registration through IARD and Form ADV; State investment adviser registration where SEC registration is not available or required | Registered investment advisers and exempt reporting advisers; Broker-dealers and introducing brokers; Private fund advisers | Investment adviser representatives may require state registration depending on facts; Broker-dealer registered representatives require firm sponsorship, CRD filing, exams, and registration | Adviser capital rules are usually state-specific or tied to custody and other facts; broker-dealers face SEC net capital and FINRA membership expectations. | SEC adviser registration can become effective in about 45 days if complete; FINRA new member review may run up to 180 calendar days for substantially complete applications. | Very high | Open | Firms needing access to US investors, US securities transaction business, or a US adviser footprint, with careful adviser versus broker-dealer analysis. | Investment adviser and broker-dealer are not interchangeable labels. State registration can matter even when the commercial plan feels national. Compensation tied to securities transactions is often a broker-dealer red flag. |
| Australia | Australian Securities and Investments Commission | Australian financial services licence for financial services business; Authorised representative of an AFSL holder | Investment managers and managed account providers; Financial product advisers; Dealers, custodians, and market participants | Responsible managers with appropriate competence and organisational capacity; Authorised representatives where services are provided under another licensee | Financial resource expectations depend on authorisations, financial products, client money/custody, and licensee obligations. | Often 4 to 8+ months depending on authorisations and proof quality. | High | Open | Managers and advisers that need an Australian footprint and can evidence responsible managers, product authorisations, and client-type controls. | Authorised representative status is not the same as holding your own AFSL. Retail advice introduces additional adviser registration and conduct questions. AFSL conditions and financial product authorisations should be checked, not assumed from the firm name. |