Hong Kong  ·  Digital-Asset Regulatory Advisory

Compliance leadership for the regulated digital-asset economy.

Horizon Digital Compliance is a boutique advisory practice serving crypto exchanges, virtual-asset service providers, tokenised-product issuers, family offices, and traditional financial institutions across Hong Kong and Asia — providing senior regulatory strategy, MLRO and compliance leadership, and independent framework assurance.

Services

Senior compliance and regulatory expertise, delivered as advisory, project, or fractional leadership engagements.

Fractional Compliance Leadership

Interim or ongoing senior compliance capacity for firms that need experienced leadership without a full-time hire. Retainer-based arrangements tailored to firm size and regulatory complexity.

  • Fractional MLRO / Deputy MLRO / Head of AFC Advisory
  • Fractional Compliance Advisor to management
  • Interim Compliance Officer during licensing or transition periods
  • Type 1 / 4 / 9 licence uplift support
  • On-call regulatory strategy support for senior leadership
Monthly retainer, tailored to scope.

HK VATP, Custody & SFC Licensing

End-to-end support for firms pursuing SFC authorisation under Hong Kong's virtual-asset regime, preparing for the upcoming HK custody licensing framework, or expanding existing licence types. Applicant-side preparation, gap analysis, and regulator-engagement strategy.

  • VATP application preparation and review
  • Readiness assessment for the upcoming HK virtual-asset custodian regime
  • Fit-and-proper assessment preparation for ROs and MICs
Fixed-fee project engagement.

AFC Framework Design & Assurance

Design, review, or independent assurance of anti-financial-crime frameworks — from risk-based methodology through to control testing and remediation. Grounded in bank-standard second-line practice, adapted to the crypto operating environment.

  • AML/CFT policy and procedure design
  • Second-line quality assurance and control testing
  • SAR quality review programmes
  • Sanctions and Travel Rule frameworks for on-chain counterparties
  • Independent framework review and gap analysis
Fixed-fee project or monthly retainer.

Digital-Asset Regulatory Strategy

Substantive regulatory analysis and strategic advisory for firms launching new digital-asset products, entering new jurisdictions, or evaluating tokenised structures. Cross-jurisdictional coverage of Hong Kong, Singapore, EU (MiCA), Cayman, and the US.

  • Tokenised product regulatory design
  • Cross-border regulatory interpretation
  • Digital-asset custody and infrastructure diligence
  • Board-level briefings and governance papers
Day rates or fixed-fee project engagement.
About

Founded and led by Max Rebol, PhD.

Fifteen years across senior compliance and risk leadership in institutional financial services and digital-asset operating experience — combined in a single practitioner profile.

Six years leading second-line financial-crime and CDD assurance work inside SFC-licensed institutions in Hong Kong: Head of CDD Assurance, Asia-Pacific at DWS Group (Deutsche Bank Asset Management), and earlier FCC Manager at Morgan Stanley. Principal point of contact for direct regulatory engagement with the SFC and HKMA.

An earlier four years in compliance consulting — Stroz Friedberg (an Aon company) in Hong Kong and Control Risks in Shanghai — advising institutional clients on AML, KYC, and financial-crime compliance across Greater China and Asia-Pacific.

Nearly five years operating Harbour Industrial Capital (HIC), a Cayman-domiciled, CIMA-supervised institutional digital-asset venture fund, as its principal officer for compliance and regulatory affairs. Hands-on practitioner experience across the full digital-asset risk surface — on-chain custody and key management, smart-contract and protocol risk, blockchain analytics, tokenisation, and the operational and financial-crime perimeter of digital-asset service providers.

Co-founded PolkaPort East, the first Web3 Foundation Decentralised Futures grant awarded to an organisation in Asia. Elected by on-chain governance to a one-year term as Head Ambassador for the Polkadot Network.

Native German, fluent English and Mandarin. Regular keynote speaker at Hong Kong FinTech Week, Hong Kong Web3 Festival, and the China International Finance Forum.

Max Rebol, PhD — Founder, Horizon Digital Compliance

Regulatory experience

  • Hong Kong SFC (Type 1, 4, 9 institutions)
  • Hong Kong Monetary Authority (HKMA)
  • Cayman Islands Monetary Authority (CIMA)
  • Hong Kong VATP framework
  • EU MiCA / MiCAR

Credentials

  • CAMS — Certified Anti-Money Laundering Specialist (ACAMS)
  • PhD, International Relations — Fudan University, Shanghai
  • MSc, Development Management — London School of Economics
  • Polkadot Blockchain Academy, Founder's Track (Cyberport, HK)
  • TADS Award, Ecosystem Excellence in DeFi (2023)
  • Fellowship, Young Leaders Forum, CSIS

Languages

  • English (fluent)
  • German (native)
  • Mandarin Chinese (fluent)
  • Cantonese (limited)
Contact

To discuss an engagement, please get in touch.

Horizon Digital Compliance takes on a limited number of engagements to preserve depth of attention across each mandate.

Introductory conversations are complimentary. For substantive advisory questions requiring preparation or written analysis, a paid engagement is arranged from the outset.

Please include a brief description of the firm, the regulatory context, and the nature of the support you are looking for. Replies are typically within one to two business days.

Email max@hd-compliance.com
LinkedIn linkedin.com/in/maxrebol
Based in Hong Kong
Professional Standards

Professional indemnity

Advisory engagements are backed by professional indemnity insurance, providing clients with assurance that any risks arising from the engagement fall under adequate professional cover.

Confidentiality

All engagements are conducted under a Master Services Agreement and a mutual Non-Disclosure Agreement. Client information, documents, and regulatory correspondence remain strictly confidential.

Independence

Horizon Digital Compliance operates as an independent boutique and takes on a limited number of engagements to preserve depth of attention and avoid conflicts across the client base.