I tried to look up for this sort of exemption under SFO. But I wasn't able to find anything. Can you please check for the specifics and let us know here? Would be of great help! Thanks! Since its just friends and family, I think an easier option would be get a POA on their brokerage accounts and invoice them separately through an offshore company. IB HK currently allows up to 5 accounts on their Friends & Family platform in Hong Kong. But you cannot charge any fee to those accounts.
A year or so back I recall that Friends account website stated it wasn't available to IBHK, but don't see it anymore. IBHK confirmed that following doesn't apply here? I just feel that charging a fee separately instead of netting makes collection very troublesome and outright difficult. Friends and Family Account Structure A master account linked to individual client accounts. The master account is used for fee collection and trade allocations Also cannot identify any relevant exemptions besides possibly the Individual Professional Investors with $HK8mn+ which looks cumbersome to document (certified by a custodian or accountant? arghh..) https://www.charltonslaw.com/legal/...-license/Professional-Investor-Definition.pdf