If the business nature consists of virtual assets, a VASP licence is required and it can be applied under the Virtual Asset Service Provider licensing regime regulated by the SFC in Hong Kong. If the exchange also provides security token (e.g. Solana, Cardano, Polygon) or products that are securities in nature (e.g. derivatives in crypto), such activities would be covered by the Securities and Futures Ordinance and a Type 1 and Type 7 license may be needed.
One of the licensing criteria is that the VASP applicant needs to be a company incorporated locally in Hong Kong. Since it’s the SFC who approves the VASP license, usually the regulated activity licence would be covered in the application process, especially if the requirements of the two licenses are similar.