The Hong Kong Securities and Futures Commission (SFC) has issued
a circular that sets forth comprehensive guidelines and
expectations for licensed corporations (LCs) regarding the
responsible use of generative artificial intelligence language
models (AI LMs).
This circular, accompanied by an appendix detailing a
non-exhaustive list of risk factors, aims to ensure the responsible
adoption and management of AI LMs. The full circular can be accessed here.
Scope and Applicability
The circular is applicable to all LCs that offer services or
functionalities powered by AI LMs or use AI LM-based third-party
products in relation to their regulated activities, irrespective of
whether the AI LM is developed internally, by a group company, an
external service provider, or sourced from open platforms. The
SFC's directive underscores the importance of a risk-based
approach, allowing LCs to tailor their compliance efforts based on
the materiality and risk level of specific AI