The Hong Kong Securities and Futures Commission ( SFC) has observed that the use of external electronic data storage providers (EDSPs), including public and private cloud storage, by licensed corporations (LCs) has become increasingly prevalent1 . To address the increasing popularity of EDSPs, the SFC has published a circular (Circular) on October 30, 2019, setting out new requirements that LCs must comply with in storing and preserving the integrity of records or documents that LCs are required to keep under the Securities and Futures Ordinance (SFO) and the Anti-Money Laundering and Counter Terrorist Financing Ordinance (collectively, Regulatory Records) with EDSPs.