The Digital Asset Development Research Center (DADRC) released a comparison of senior personnel requirements of Asian virtual asset service providers on November 10, analyzing Taiwan side by side with Japan, South Korea, Hong Kong, and Singapore. DADRC pointed out that all five places include senior managers’ qualifications as approval conditions, but only Taiwan and Hong Kong specify seniority. Taiwan’s draft requires general managers to have 5 to 7 years of seniority, which is the clearest quantitative standard among the five places.

The supervision and risk management of virtual asset service providers is also the focus of the "11th Taiwan Blockchain AI Experts Annual Conference" from November 23 to 24. The annual meeting is hosted by the Taiwan Association of Blockchain Enthusiasts (TABEI) and held at Taipei Chengdu Public Enterprise Center. On the 24th, the "Institution Day" arranges stablecoins, digital asset custody, credit guarantees and tokenized securities. Interested readers canRegister online, see the agendaAnnual meeting official website。

According to the speaker list announced on the official website of the annual meeting, DADRC convener Xie Minghua was listed as a speaker; DADRC observer Dogris started the "Cross-border Flow of Tokenized Securities" session on the afternoon of the 24th, using the U.S. SEC Innovation Exemption as an example.

Taiwan’s basis is the draft of the “Management Rules for the Responsible Persons and Business Personnel of Virtual Asset Service Providers” announced by the Financial Supervisory Commission in November. According toDraft provisions announced by the Securities and Futures Commission, Article 6 stipulates that virtual asset service providers should have a general manager, and the qualifications and appointment procedures of the general manager are clearly stated.

Taiwan draft: General manager should have 5 to 7 years of experience and be reviewed before appointment

Article 6 of the draft lists three qualifications, and those who meet one of them are: a college degree or above, engaged in the virtual asset service business for more than 5 years, and have served as a manager of a virtual asset service provider or an equivalent position for more than 3 years; or have been engaged in the virtual asset service business for more than 7 years, and have served as a manager or an equivalent position for more than 3 years; or have other academic experience that is sufficient to prove professional knowledge and operation and management experience.

The draft also defines that "engaging in virtual asset service business" refers to engaging in solicitation, account opening, transaction execution, internal audit, legal compliance, risk management and other businesses for virtual asset service providers. Before hiring a general manager, the business operator must first submit the qualification certificate to the counter shopping center for review, and then transfer it to the Financial Supervisory Commission for review. Only those who pass the qualification can take up the post; if it is concurrently operated by a financial institution, it shall be handled in accordance with other laws and regulations.

The person in charge, substantial beneficiaries and business personnel also have negative qualifications. It is stipulated in Article 3 of the draft "Measures for the Establishment of Virtual Asset Service Providers" that was simultaneously announced. Those who have committed fraud or violated financial regulations such as the Money Laundering Prevention Law, the Terrorism Prevention Law, the Banking Law, the Securities and Exchange Law, and have been found guilty and have not reached a certain number of years shall not be allowed to serve.

Comparison of five places: Only Taiwan and Hong Kong have written qualifications

The practices of the other four places compiled by DADRC are as follows:

area Competent authorities and systems Senior staff requirements Taiwan Financial Supervisory Commission, "Virtual Asset Services Law" and Draft Personnel Management Rules The general manager has 5 to 7 years of experience, plus 3 years of managerial experience; prior review Hong Kong China Securities Regulatory Commission, virtual asset trading platform license system At least 2 responsible personnel, at least 1 of whom has more than 3 years of direct operation experience; technical experience can be recognized singapore Monetary Authority, Payment Services Act and Digital Token Service Provider Regime Directors and CEOs must be appropriately qualified and their appointments must be approved; relevant experience is required, and the number of years is undetermined. Japan Financial Services Agency, "Funds Settlement Act" Crypto Asset Exchange Industry Registration Written and on-site governance review, interviews with directors and senior executives; undetermined number of years South Korea Financial Services Commission and Financial Intelligence Analysis Service, "Specified Financial Information Act" reporting system Representatives, senior managers and major shareholders must not have financial crime records; the new system in August will add major shareholder qualifications and internal control reviews; the number of years is undetermined

DADRC believes that Taiwan lists the general manager’s business experience as an approval condition, pre-approval review, and negative qualifications cover fraud and money laundering. These three points are consistent with the international direction. Compared with Hong Kong, Taiwan requires the general manager of each industry to have seniority, while in Hong Kong, at least one of the responsible personnel must have 3 years of experience.

DADRC also noted that quantitative standards come at the cost of less flexibility. Taiwan's virtual asset service providers have only been included in supervision for a short period of time, and there are only a few candidates who meet the qualifications and managerial experience. Hong Kong recognizes experience with a technical background, and Singapore accepts relevant financial industry experience. Taiwan's draft only uses seniority working for virtual asset service providers.

DADRC’s three recommendations: expand accounting experience and clarify the third paragraph

First, expand the experience that can be adopted. DADRC recommends stating in the explanation column that the seniority during the period of completing money laundering prevention registration can be taken into account, and the business experience of overseas supervised service providers can also be included in the determination.

Second, announce the review principles for “Other Learning Experience” in Paragraph 3. For candidates with financial institution risk management, information security or core technology backgrounds, the required documents and review points are listed so that concurrent banks and new entrants have a clear path.

Third, make risk training an ongoing obligation for senior management. Article 11 of the draft already requires managers and business personnel to participate in pre-employment training within six months of taking office, and on-the-job training every two years thereafter; DADRC recommends setting up regular advanced courses for managers and general managers, covering private key management, market manipulation, money laundering patterns and crisis management.

DADRC Deputy CEO Guo Maoren said: "When customers hand over assets to virtual asset service providers, what they care most about is whether the operators understand the risks." He said that the threshold must be guarded against risks and that people must be found. "It is recommended that the competent authorities make the seniority calculation and the third paragraph review clear during the notice period, and then make risk training for senior managers an annual thing." Guo Maoren also talked about the risks of operating personnel in light of the Binance hacking incident in early November (Related reports).

This set of personnel rules is one of the eight sub-laws announced by the Financial Supervisory Commission in November. The same draft also stipulates the capital amount, margin and concurrent operation regulations of trading platforms (Related reports).

Event information

• Event name: The 11th Taiwan Blockchain Ai Champions Annual Conference
• Organizer: Taiwan Blockchain Enthusiasts Association (TABEI)
• Date: November 23 (Monday) to 24 (Tuesday), 2026
• Venue: International Conference Hall, 2F, National Chengchi University Public Enterprise Center (No. 187, Jinhua Street, Daan District, Taipei City)
• Registration link:accu.ps/vKm9aT
• Annual meeting official website:chain.tw

this article How many years of experience does an exchange general manager need? Research center compares the threshold of virtual assets personnel in Taiwan, Japan, South Korea and Hong Kong first appeared in Chain News ABMedia。