Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.
Click a bar to drill down one level.
Where?
by authority- Securities and Futures Commission (SFC) €15.2m 46 % · 10 cases
- Hong Kong Monetary Authority (HKMA) €8.39m 25 % · 11 cases
- Securities and Futures Commission (SFC), Hongkong €5.44m 16 % · 7 cases
- Competition Tribunal (Hongkong), auf Antrag der Competition Commission €3.43m 10 % · 2 cases
- Shatin Magistrates' Courts, Hongkong (Anklage: Labour Department) €418,546 1 % · 2 cases
- Fanling Magistrates' Courts, Hongkong (Anklage: Labour Department) €79,028 0 % · 1 case
- West Kowloon Magistrates' Courts, Hongkong (Anklage: Labour Department) €56,920 0 % · 1 case
- Kwun Tong Magistrates' Courts, Hongkong (Anklage: Environmental Protection Department) €8,683 0 % · 1 case
- Eastern Magistrates' Courts, Hongkong (Anklage: Environmental Protection Department) €8,584 0 % · 1 case
- Privacy Commissioner for Personal Data (PCPD), Hongkong – 0 % · 7 cases
- 1 more€0
What for?
by area of lawAll areas of law
- Capital markets and financial supervision €20.4m 62 % · 16 cases
- Money laundering and terrorist financing €8.39m 25 % · 11 cases
- Competition law €3.43m 10 % · 5 cases
- Health and safety and employment law €554,494 2 % · 4 cases
- Information security and cyber €235,595 1 % · 1 case
- Environment and sustainability €17,267 0 % · 2 cases
- Data protection – 0 % · 7 cases
Who?
by sectorAll sectors
- Financial services and insurance €29m 88 % · 27 cases
- Other €2.77m 8 % · 3 cases
- Manufacturing and mechanical engineering €659,106 2 % · 1 case
- Energy and utilities €348,309 1 % · 1 case
- Construction and real estate €223,452 1 % · 5 cases
- Retail and e-commerce – 0 % · 3 cases
- Media and online platforms – 0 % · 3 cases
- Automotive – 0 % · 1 case
- Healthcare – 0 % · 1 case
- Public sector – 0 % · 1 case
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 4 | €1.44m |
| 2023 | 10 | €6.4m |
| 2024 | 6 | €3.33m |
| 2025 | 12 | €18.6m |
| 2026 | 14 | €3.29m |
46 cases
17 Sep 2026 China Power International Development Limited, Towngas - China Power (HK) Integrated Energy Company Limited, A. Kourage Limited u. a. (4 Unternehmen)Fatal electric shock at Science Park: four companies pay 3,137,250 HKD €348,309
On 17 September 2026 the Shatin Magistrates' Courts (a Hong Kong magistrates' court), on prosecutions brought by the Labour Department (Hong Kong's labour authority), fined four companies for breaches of the Factories and Industrial Undertakings Regulations, the Factories and Industrial Undertakings (Electricity) Regulations and the Construction Sites (Safety) Regulations (Hong Kong workplace safety rules). The case concerned a fatal accident on 10 September 2023 at Hong Kong Science Park, in which a worker received an electric shock while carrying out electrical work. China Power International Development Limited and Towngas - China Power (HK) Integrated Energy Company Limited pay 908,000 HKD each, A. Kourage Limited 904,250 HKD and Skynet Engineering Company Limited 417,000 HKD, 3,137,250 HKD in total.
In electrical work several companies involved can be criminally liable at the same time – workplace safety must be coordinated among all parties.
Electrical safety in installation and construction work
- Authority / court
- Shatin Magistrates' Courts, Hongkong (Anklage: Labour Department)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- Factories and Industrial Undertakings Regulations; Factories and Industrial Undertakings (Electricity) Regulations; Construction Sites (Safety) Regulations
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Energy and utilities
- Published
- 17 Sep 2026
Original amount 3,137,250 HKD, converted at the ECB reference rate of 17 Sep 2026.
- HKSAR Government (Labour Department): Contractors fined for violation of safety legislation (17.09.2026) Press release of an authority
- Labour Department: Press Releases (Liste) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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4 Sep 2026 In Construction LimitedHong Kong: HKD 640,000 fine for In Construction after fatal crane accident €70,237
In Construction was fined HKD 640,000 for breaches of the Factories and Industrial Undertakings Ordinance and the regulations on lifting appliances and safety management. On a foundation construction site in Tai Po on 30 September 2025, a female worker had been trapped between the rear end of a slewing crawler crane and the railing of a steel platform and later died.
A crane's slewing zone must be cordoned off, especially on confined platforms where railings create a crushing point.
Securing the danger zone of slewing cranes
- Authority / court
- Shatin Magistrates' Courts, Hongkong (Anklage: Labour Department)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- Factories and Industrial Undertakings Ordinance; Factories and Industrial Undertakings (Lifting Appliances and Lifting Gear) Regulations; Factories and Industrial Undertakings (Safety Management) Regulation
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Construction and real estate
- Published
- 4 Sep 2026
Original amount 640,000 HKD, converted at the ECB reference rate of 4 Sep 2026.
- Contractor fined for violation of safety legislation (4 September 2026) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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28 Jul 2026 Luk Fook Securities (HK) LimitedLuk Fook Securities: HKD 2.1m fine for weak cybersecurity ahead of ransomware attack €235,595
Luk Fook Securities (HK) was publicly reprimanded and fined 2,100,000 HKD because inadequate cybersecurity controls might have contributed to a ransomware attack on 19 September 2022 hitting numerous core servers and to full recovery taking until 7 October 2022; during that time clients could not trade via the app or internet platform. Findings included missing firewall protection, outdated operating systems and antivirus software, weak access and password controls with credentials stored unencrypted, insufficient controls over remote access and external devices, inadequate data backup and a last security training session in 2018.
Basic cyber hygiene – patching, access and password controls, backups and regular staff training – is a regulatory obligation for financial firms.
Ransomware defence, password security and security awareness training
Missing or inadequate training played a role in the decision.
- Authority / court
- Securities and Futures Commission (SFC)
- Area of law
- Information security and cyber · Security measures and risk management
- Legal basis
- s. 194 SFO (Cap. 571); Code of Conduct GP 2, GP 3, GP 7, paras. 12.1, 18.5 und Schedule 7; Guidelines for Reducing and Mitigating Hacking Risks Associated with Internet Trading
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Root-cause review with an independent reviewer, strengthened controls, no evidence of client loss, cooperation, clean disciplinary record.
- Published
- 28 Jul 2026
Original amount 2,100,000 HKD, converted at the ECB reference rate of 28 Jul 2026.
- SFC press release 26PR118: SFC reprimands and fines Luk Fook Securities (HK) Limited $2.1 million for inadequate cybersecurity control (28.07.2026) Press release of an authority
- SFC Statement of Disciplinary Action zu 26PR118 Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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27 Jul 2026 China Industrial Securities International Asset Management LimitedSFC: HKD 6.8m fine for CISIAM over missed red flags in a private fund €761,367
The SFC publicly reprimanded China Industrial Securities International Asset Management (CISIAM) and fined it HKD 6.8 million because, between August 2019 and September 2020, the manager of a private fund set up for the insurer Tahoe Life acquired complex structures with notes linked to bonds of a related company at the request of the insurer's chief investment officer, without identifying and properly examining the red flags. CISIAM also failed to observe the fund's investment restrictions and objectives and did not manage its risks effectively. In setting the penalty, the SFC also took into account management fees of around HKD 1.9 million received from the fund.
A fund manager must independently assess an investor's instructions and must not implement unusually complex structures without a clear commercial rationale unchecked.
Recognising red flags in investor-driven fund arrangements
Missing or inadequate training played a role in the decision.
- Authority / court
- Securities and Futures Commission (SFC), Hongkong
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- Section 194 Securities and Futures Ordinance (Cap. 571); General Principle 2 Code of Conduct; Paragraphen 1.2(d), 3.1 und 3.11.1 Fund Manager Code of Conduct; Abschnitt VIII Management, Supervision and Internal Control Guidelines
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial measures (new policies on risk management and dubious investment arrangements, compliance training), cooperation with the SFC and an otherwise clean disciplinary record.
- Published
- 27 Jul 2026
Original amount 6,800,000 HKD, converted at the ECB reference rate of 27 Jul 2026.
- SFC reprimands and fines China Industrial Securities International Asset Management Limited $6.8 million (26PR116) Press release of an authority
- Statement of Disciplinary Action – China Industrial Securities International Asset Management Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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27 Jul 2026 Bright Smart Securities International (H.K.) LimitedBright Smart Securities: HKD 2.8m fine for inadequate wash-trade controls €313,504
Bright Smart Securities International (H.K.) was publicly reprimanded and fined 2,800,000 HKD because between November 2023 and September 2025 its controls did not prevent 615 clients from executing 1,021 pairs of wash trades (trades without a change in beneficial ownership) in 736 shares and warrants. Monitoring was mostly after the event and manual, and several wash trades by one client on the same day counted as a single occurrence. Similar deficiencies had been identified and raised repeatedly before but were not fully remedied in any instance.
Trade surveillance must intercept wash trades automatically before execution; after-the-event manual reviews are not enough for recurring patterns.
Detecting and preventing wash trades
- Authority / court
- Securities and Futures Commission (SFC)
- Area of law
- Capital markets and financial supervision · Market abuse and insider dealing
- Legal basis
- s. 194 SFO (Cap. 571); Code of Conduct GP 2, para. 4.3
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- Enhanced systems and a commitment to an independent effectiveness review, cooperation.
- Published
- 27 Jul 2026
Original amount 2,800,000 HKD, converted at the ECB reference rate of 27 Jul 2026.
- SFC press release 26PR117: SFC reprimands and fines Bright Smart Securities International (H.K.) Limited $2.8 million (27.07.2026) Press release of an authority
- SFC Statement of Disciplinary Action zu 26PR117 Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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17 Jun 2026 Kangaroo Limited (Keeta)Keeta gives binding commitment to open up its restaurant contracts Order
On 17 June 2026 the Competition Commission (Hong Kong's competition authority) accepted a commitment from Kangaroo Limited, which operates the Keeta food delivery platform in Hong Kong and is a subsidiary of Meituan. The authority was concerned that clauses in Keeta's agreements with partner restaurants made access harder for new and small platforms and softened competition – a possible breach of the First Conduct Rule (the ban on anti-competitive agreements). Keeta had already amended the agreements voluntarily (cooperation with platforms of up to 10% market share without losing incentives, easier switching, no bar on lower prices on the restaurants' own channels and on rival platforms); with the acceptance, these changes are legally binding and enforceable by the authority until 28 December 2026.
Platforms should proactively align their exclusivity and price parity clauses with the standards the authority has already imposed on their competitors.
Exclusivity and price parity clauses of online platforms
- Authority / court
- Competition Commission (Hongkong)
- Area of law
- Competition law
- Legal basis
- Competition Ordinance (Cap. 619), s. 6 (First Conduct Rule); Annahme einer Verpflichtungszusage nach s. 60
- Action
- Order
- Status of proceedings
- final
- Sector
- Media and online platforms
- Published
- 17 Jun 2026
- Competition Commission: Competition Commission accepts commitment offered by Keeta (17.06.2026) Press release of an authority
- Competition Commission: Notice regarding the Commission's acceptance of a commitment from Keeta in the Online Food Delivery Platform case (EC/12LD), 17.06.2026 Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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22 May 2026 China Harbour Engineering Company LimitedChina Harbour Engineering: 78,000 HKD for discharge into water control zone €8,584
In April 2026 China Harbour Engineering Company Limited was fined 78,000 HKD at the Eastern Magistrates' Courts (a Hong Kong magistrates' court) under the Water Pollution Control Ordinance (Hong Kong's water pollution law) because the company had discharged waste or polluting matter into a water control zone on 14 July 2025; the prosecution was brought by the Environmental Protection Department (Hong Kong's environmental authority). It was the highest fine among the 40 environmental convictions the department published for April 2026.
Discharges into waters must be authorised in advance and monitored continuously – a single incident is enough for a criminal conviction in Hong Kong.
Water protection and authorised discharges
- Authority / court
- Eastern Magistrates' Courts, Hongkong (Anklage: Environmental Protection Department)
- Area of law
- Environment and sustainability · Emissions and permits
- Legal basis
- Water Pollution Control Ordinance (Einleitung von Abfall oder verunreinigenden Stoffen in eine water control zone)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Construction and real estate
- Published
- 22 May 2026
Original amount 78,000 HKD, converted at the ECB reference rate of 22 May 2026.
- Environmental Protection Department: EPD convictions in April (2026) – Liste der Verurteilungen Enforcement database of an authority
- HKSAR Government (EPD): EPD convictions in April (22.05.2026) Press release of an authority
- Environmental Protection Department: EPD convictions in April Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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23 Apr 2026 PricewaterhouseCoopers Hong KongPwC Hong Kong: HKD 1bn compensation for Evergrande shareholders under SFC agreement Other
Under an agreement with the Securities and Futures Commission (SFC, Hong Kong's securities regulator), PricewaterhouseCoopers Hong Kong has undertaken to set aside 1,000,000,000 HKD to compensate independent minority shareholders of China Evergrande Group; in return the regulator will take no further action, without any admission of liability. China Evergrande's audited revenue was allegedly overstated by 44.79% for 2019 and 69.03% for 2020, and PwC Hong Kong, as auditor, was allegedly concerned in the dissemination of false information, allegedly did not maintain its independence and allegedly acquiesced in management's manipulation of audit samples and site inspections.
Auditors who tolerate manipulation of their audit procedures face a considerable risk of having to compensate investors.
Independence and professional scepticism in auditing
- Authority / court
- Securities and Futures Commission (SFC)
- Area of law
- Capital markets and financial supervision · Market abuse and insider dealing
- Legal basis
- s. 277 SFO (Cap. 571) (Auffassung der SFC, von PwC HK nicht anerkannt)
- Action
- Other
- Status of proceedings
- final
- Sector
- Other
- Published
- 23 Apr 2026
Checked against the official source on 3 Oct 2026 · Direct link
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23 Apr 2026 Yau Yat Chuen Garden City Club LimitedRansomware via remote maintenance access: enforcement notice against private club Order
In a ransomware attack on the membership management system of Yau Yat Chuen Garden City Club Limited, a private, non-profit recreational club, reported on 31 October 2025, data of 9,045 current and former members and supplementary card holders were affected, including identity card or passport numbers. The attacker exploited a known vulnerability in outdated remote access software of the external service provider and reached the server, which had been left logged in, without further authentication; antivirus software and firewall were outdated, and personal data had been kept longer than necessary. In its investigation report published on 23 April 2026 the PCPD (Privacy Commissioner for Personal Data, Hong Kong's data protection authority) found breaches of DPP 4(1) and DPP 2(2) and served an enforcement notice.
Service providers' remote maintenance access belongs in an organisation's own security concept: current software, additional authentication and no servers left permanently logged in.
Service providers' remote access, patch management and retention periods
- Authority / court
- Privacy Commissioner for Personal Data (PCPD), Hongkong
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Personal Data (Privacy) Ordinance, Data Protection Principles 4(1) und 2(2); Enforcement Notice
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Other
- Published
- 23 Apr 2026
Checked against the official source on 3 Oct 2026 · Direct link
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14 Apr 2026 Sun Shine Decoration Limited, Wai Tat Aluminium & Glass Engineering Company LimitedHong Kong: HKD 730,000 in fines for two contractors after fatal fall €79,028
The court fined Sun Shine Decoration HKD 500,000 and Wai Tat Aluminium & Glass Engineering HKD 230,000, HKD 730,000 in total, for breaches of the Factories and Industrial Undertakings Ordinance and the Construction Sites (Safety) Regulations. The case arose from a fatal accident on 16 May 2025 at a house in Kwu Tung, in which a worker fell into the swimming pool of the neighbouring house while fixing insulation boards on a metal canopy.
Work on roofs and canopies requires fall protection planned in advance, even at residential houses, and every company involved can be held liable for breaches.
Fall protection when working on roofs and canopies
- Authority / court
- Fanling Magistrates' Courts, Hongkong (Anklage: Labour Department)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- Factories and Industrial Undertakings Ordinance; Construction Sites (Safety) Regulations
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Construction and real estate
- Published
- 14 Apr 2026
Original amount 730,000 HKD, converted at the ECB reference rate of 14 Apr 2026.
- Contractors fined for violation of safety legislation (14 April 2026) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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23 Feb 2026 Chevalier (Construction) Company LimitedHong Kong: HKD 80,000 fine for Chevalier (Construction) for breaching a noise permit €8,683
Chevalier (Construction) was fined HKD 80,000 in January 2026 because on 23 February 2025 the company carried out prescribed construction work in breach of the conditions of its construction noise permit. It was the heaviest single fine among the 34 convictions reported by the Environmental Protection Department for January 2026.
A noise permit only protects a site as long as its conditions on hours and equipment are actually observed.
Complying with noise permit conditions on construction sites
- Authority / court
- Kwun Tong Magistrates' Courts, Hongkong (Anklage: Environmental Protection Department)
- Area of law
- Environment and sustainability · Emissions and permits
- Legal basis
- Noise Control Ordinance (Bauarbeiten entgegen den Bedingungen einer Construction Noise Permit)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Construction and real estate
- Published
- 23 Feb 2026
Original amount 80,000 HKD, converted at the ECB reference rate of 23 Feb 2026.
- EPD convictions in January 2026 (Liste der Verurteilungen) Enforcement database of an authority
- EPD convictions in January (23 February 2026) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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9 Feb 2026 Kylin International (HK) Co., LimitedSFC: HKD 9m fine for Kylin International over fund management failures €968,909
The SFC publicly reprimanded Kylin International (HK) and fined it HKD 9 million for failures as investment manager or consultant of six sub-funds of a Cayman Islands fund from August 2018. The SFC found that conflicts of interest arising from six loans by the firm or a director to four sub-funds were neither managed nor disclosed, reconciliations, valuations and audits were missing, investors were wrongly told that the suitability requirement did not apply, KYC and suitability controls were inadequate and anti-money laundering records were missing. The firm ceased its regulated activities at the end of 2023; its licence was revoked at its request in January 2025.
Loans from a manager or its senior management to funds under management are a conflict of interest that must be managed and disclosed to investors.
Conflicts of interest and investor information in private fund management
- Authority / court
- Securities and Futures Commission (SFC), Hongkong
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- Section 194 Securities and Futures Ordinance (Cap. 571)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial measures after an SFC review in late 2020, cessation of regulated activities and an otherwise clean disciplinary record.
- Liability of senior managers
- Measures against individuals are not set out here.
- Published
- 9 Feb 2026
Original amount 9,000,000 HKD, converted at the ECB reference rate of 9 Feb 2026.
- SFC reprimands and fines Kylin International (HK) Co., Limited $9 million for fund management failures (26PR19) Press release of an authority
- Statement of Disciplinary Action – Kylin International (HK) Co., Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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21 Jan 2026 Hip Seng Builders LimitedHong Kong: fines for Hip Seng Builders after fatal electrocution raised to HKD 521,000 €56,920
After a fatal accident on 19 August 2023 at a construction site in Chek Lap Kok, in which a worker received an electric shock while carrying out electrical work on a false ceiling, Hip Seng Builders had been fined HKD 261,000 on 23 January 2025. On the prosecution's application, the court reviewed the sentence and on 21 January 2026 increased the fines to HKD 521,000. The conviction was under the Factories and Industrial Undertakings Ordinance and two regulations on construction site and electrical safety.
Electrical work on construction sites requires isolation and testing before work starts; Hong Kong prosecutors actively challenge sentences they consider too lenient.
Electrical safety during installation work on construction sites
- Authority / court
- West Kowloon Magistrates' Courts, Hongkong (Anklage: Labour Department)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- Factories and Industrial Undertakings Ordinance; Construction Sites (Safety) Regulations; Factories and Industrial Undertakings (Electricity) Regulations
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Construction and real estate
- Published
- 21 Jan 2026
Original amount 521,000 HKD, converted at the ECB reference rate of 21 Jan 2026.
- Court makes review decision on sentencing for violating occupational safety and health legislation (21 January 2026) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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6 Jan 2026 Saxo Capital Markets HK LimitedSaxo Capital Markets HK: HKD 4m fine over crypto products sold to retail clients €438,731
Saxo Capital Markets HK was publicly reprimanded and fined 4,000,000 HKD because between November 2018 and November 2022 retail clients, too, could trade on its online trading platform 32 complex virtual asset-related products which under the regulators' circulars were reserved for professional investors (1,446 transactions by 130 retail clients and six professional investors). The firm neither assessed clients' knowledge nor provided sufficient information and warnings; the detection rules adopted from its parent group had not identified the products as crypto-related.
Group-wide product filters do not replace a firm's own local product due diligence, especially for crypto products subject to distribution restrictions.
Distribution of complex crypto products via online platforms
- Authority / court
- Securities and Futures Commission (SFC)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- s. 194 SFO (Cap. 571); Code of Conduct; Guidelines on Online Distribution and Advisory Platforms; SFC-Rundschreiben vom 01.11.2018 und HKMA/SFC-Rundschreiben vom 28.01.2022
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Self-report, voluntary compensation of clients, cessation of regulated activities, cooperation and acceptance of the findings, otherwise clean disciplinary record.
- Published
- 6 Jan 2026
Original amount 4,000,000 HKD, converted at the ECB reference rate of 6 Jan 2026.
- SFC press release 26PR1: SFC reprimands and fines Saxo Capital Markets HK Limited $4 million (06.01.2026) Press release of an authority
- SFC Statement of Disciplinary Action zu 26PR1 Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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11 Dec 2025 EFG Bank AGSFC: reprimand and HKD 10.85m fine for EFG Bank over deficient product due diligence €1.19m
The SFC publicly reprimanded EFG Bank AG and fined it HKD 10,850,000 because, between January 2015 and December 2020, the bank failed to take special product features into account in its due diligence on 322 bonds, updated its policies late after the complex product regime took effect and in some cases served customers without the required information and warning statements. In addition, due diligence records were missing for 141 bonds, and the bank did not report the failures to the SFC immediately. The bank will apply an enhanced complaint handling procedure for customers who acquired one of 351 potentially affected products.
Firms distributing complex products must document their product due diligence in full, update policies immediately when rules change and report identified failures to the regulator without delay.
Product due diligence and customer information when distributing complex investment products
- Authority / court
- Securities and Futures Commission (SFC), Hongkong
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- Section 196 Securities and Futures Ordinance (Cap. 571); Code of Conduct for Persons Licensed by or Registered with the SFC; Management, Supervision and Internal Control Guidelines
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Mitigating circumstances
- Remedial measures on product due diligence, cooperation with the HKMA and the SFC, and commitment to an enhanced complaint handling procedure for affected customers.
- Published
- 11 Dec 2025
Original amount 10,850,000 HKD, converted at the ECB reference rate of 11 Dec 2025.
- SFC reprimands and fines EFG Bank AG $10.85 million for regulatory breaches and internal control failures (25PR205) Press release of an authority
- Statement of Disciplinary Action – EFG Bank AG Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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13 Nov 2025 Tung Tai Securities Company LimitedTung Tai Securities: HKD 900,000 fine after fraud via spoofed email instructions €99,681
Tung Tai Securities was reprimanded and fined 900,000 HKD because between September 2019 and February 2020, acting on instructions from a bogus email address resembling the genuine one, it sold an overseas client's shares and transferred the proceeds of 3,301,740 USD to three overseas bank accounts not designated by the client. Red flags such as transfers rejected by several banks were ignored, and effective controls to protect client assets from theft and fraud were lacking.
Sale and payment instructions received by email must be confirmed through an independent, pre-registered channel, especially for transfers to new beneficiary accounts.
Fraud using spoofed email instructions (business email compromise)
- Authority / court
- Securities and Futures Commission (SFC)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- s. 194 SFO (Cap. 571); Code of Conduct GP 2, GP 3, GP 8, paras. 4.3, 11.1(a); Management, Supervision and Internal Control Guidelines Part VII
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Compensation of the client, improved order-handling and execution procedures, independent review of controls, cooperation, otherwise clean disciplinary record.
- Published
- 13 Nov 2025
Original amount 900,000 HKD, converted at the ECB reference rate of 13 Nov 2025.
- SFC press release 25PR192: SFC reprimands and fines Tung Tai Securities Company Limited HK$900,000 (13.11.2025) Press release of an authority
- SFC Statement of Disciplinary Action zu 25PR192 Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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20 Oct 2025 UBS AGUBS: HKD 8m fine for years of misclassifying professional investors €883,431
UBS AG was publicly reprimanded and fined 8,000,000 HKD in Hong Kong because, from 2009 to July 2022, its automated process for classifying professional investors rested on a misinterpretation of the minimum portfolio requirement for certain joint accounts. From July 2018 to July 2022 alone, 560 joint accounts were misclassified; securities of 23 of these accounts were lent in 9,190 lending transactions without valid authority, and 94 accounts carried out 500 transactions in products reserved for professional investors. In August 2021 the regulator had already fined UBS 9.8 million HKD, among other things for similar failings.
Automated client classifications must be validated against the wording of the rules, especially for special cases such as joint accounts.
Correct classification of professional investors and distribution restrictions
- Authority / court
- Securities and Futures Commission (SFC)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- s. 196 SFO (Cap. 571); s. 4 Securities and Futures (Client Securities) Rules; s. 11(3A) Securities and Futures (Contract Notes, Statements of Account and Receipts) Rules; Securities and Futures (Professional Investor) Rules; Code of Conduct
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Repeat case
- yes
- Mitigating circumstances
- Look-back review and remediation after self-reporting, cooperation, commitment to an enhanced complaint handling procedure for potentially misclassified clients.
- Published
- 20 Oct 2025
Original amount 8,000,000 HKD, converted at the ECB reference rate of 20 Oct 2025.
- SFC press release 25PR167: SFC reprimands and fines UBS AG $8 million for professional investor misclassification (20.10.2025) Press release of an authority
- SFC Statement of Disciplinary Action zu 25PR167 Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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8 Sep 2025 Instinet Pacific LimitedSFC: HKD 8m fine for Instinet Pacific over unreported cross trades €875,254
The SFC publicly reprimanded Instinet Pacific and fined it HKD 8 million because, between December 2012 and March 2018, the broker failed to report 8,817 pairs of cross trades between clients and an affiliated company, worth around HKD 25.9 billion, to the Stock Exchange of Hong Kong as required by Rule 526 of the Exchange Rules. There were neither internal rules on reporting such trades nor any review of the reporting process.
Every reporting obligation towards an exchange or regulator needs written ownership and regular checks that reports are actually being made.
Reporting obligations towards the exchange in securities trading
- Authority / court
- Securities and Futures Commission (SFC), Hongkong
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Section 194 Securities and Futures Ordinance (Cap. 571); Rule 526 Rules of the Exchange (SEHK); General Principles 2 und 7 sowie Paragraph 12.1 Code of Conduct
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Mitigating circumstances
- The firm ceased the relevant trade flows on its own initiative and cooperated with the SFC.
- Published
- 8 Sep 2025
Original amount 8,000,000 HKD, converted at the ECB reference rate of 8 Sep 2025.
- SFC reprimands and fines Instinet Pacific Limited $8 million for failure to report cross trades to the Stock Exchange (25PR140) Press release of an authority
- Statement of Disciplinary Action – Instinet Pacific Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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28 Aug 2025 Deutsche Bank AktiengesellschaftDeutsche Bank: HKD 23.8m fine in Hong Kong over fee and disclosure errors €2.62m
Deutsche Bank AG was publicly reprimanded and fined 23,800,000 HKD in Hong Kong. Clients were overcharged fees of about 5 million USD in management fees on 39 accounts, 10,988 EUR at 92 customers and 493 USD at 32 customers, because agreed discounts were not applied, floating rate debt instruments were wrongly valued and fund prices were not updated. 261 single stock and 1,590 industry research reports lacked disclosure of investment banking relationships. 40 ETFs were given too low a product risk rating. The proceedings stemmed from the bank's self-reports.
Agreed fee discounts, valuation data from external vendors and disclosures in research reports need regular reconciliation so that system errors do not persist for years.
Fee billing, valuation data and disclosure in research reports
- Authority / court
- Securities and Futures Commission (SFC)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- s. 196 SFO (Cap. 571); Code of Conduct GP 2, GP 7, paras. 2.1, 12.1, 16.5(d)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Culpability
- negligent
- Mitigating circumstances
- Self-reports, root-cause analysis, remediation and stronger controls, refund of overcharged fees, breaches found by the regulator to be inadvertent and without intent, cooperation and acceptance of the findings.
- Published
- 28 Aug 2025
Original amount 23,800,000 HKD, converted at the ECB reference rate of 28 Aug 2025.
- SFC press release 25PR132: SFC reprimands and fines Deutsche Bank Aktiengesellschaft $23.8 million (28.08.2025) Press release of an authority
- SFC Statement of Disciplinary Action zu 25PR132 Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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26 Aug 2025 The Hongkong and Shanghai Banking Corporation LimitedSFC: HKD 4.2m fine for HSBC over faulty disclosures in research reports €461,939
The SFC publicly reprimanded The Hongkong and Shanghai Banking Corporation (HSBC) and fined it HKD 4.2 million because, between 2013 and 2021, the bank failed to disclose, or disclosed incorrectly, its investment banking relationships with the companies covered in research reports on Hong Kong-listed securities. The cause was deficiencies in recording and mapping data across systems; an estimated more than 4,200 reports were affected. Following a self-report, the HKMA investigated jointly with the SFC.
Mandatory conflict-of-interest disclosures in research reports are only as reliable as the underlying reference data, whose reconciliation across systems must be checked regularly.
Disclosure of conflicts of interest in investment research
- Authority / court
- Securities and Futures Commission (SFC), Hongkong
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Section 196 Securities and Futures Ordinance (Cap. 571); Paragraph 16.5(d), General Principles 2, 3 und 7 sowie Paragraph 12.1 Code of Conduct
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Mitigating circumstances
- No evidence of client losses, root-cause review, enhancement of systems and controls, and cooperation with the HKMA and the SFC.
- Published
- 26 Aug 2025
Original amount 4,200,000 HKD, converted at the ECB reference rate of 26 Aug 2025.
- SFC reprimands and fines HSBC $4.2 million for disclosure failures in research reports (25PR129) Press release of an authority
- Statement of Disciplinary Action – The Hongkong and Shanghai Banking Corporation Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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21 Aug 2025 Kwong's Art Jewellery Trading Company Limited, My Jewelry Management LimitedJewellery companies: data of around 79,400 people stolen – enforcement notices Order
At Kwong's Art Jewellery Trading Company Limited and its retail subsidiary My Jewelry Management Limited, which run their IT systems jointly, an attacker (reported in November 2024) obtained the credentials of an administrator account by brute force, exfiltrated the database and deleted it; around 79,400 individuals were affected, including customers and current and former employees. In its report published on 21 August 2025 the PCPD (Privacy Commissioner for Personal Data, Hong Kong's data protection authority) found breaches of DPP 4(1), among other things because the account of a departed employee had not been deleted in time, server operating systems were outdated and security policies and security assessments were lacking. Both companies were served enforcement notices to remedy the deficiencies and prevent further contraventions.
Delete the accounts of departing staff immediately, keep servers up to date and protect administrator access against brute-force attacks.
Access management for leavers, patch management and protection of administrator accounts
- Authority / court
- Privacy Commissioner for Personal Data (PCPD), Hongkong
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Personal Data (Privacy) Ordinance, Data Protection Principle 4(1); Enforcement Notices
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Retail and e-commerce
- Published
- 21 Aug 2025
Checked against the official source on 3 Oct 2026 · Direct link
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22 Jul 2025 Indian Overseas Bank, Hong Kong BranchIndian Overseas Bank (Hong Kong): HKD 8.5m penalty and orders over monitoring failings €925,553
The Hong Kong branch of Indian Overseas Bank was reprimanded, ordered to pay a pecuniary penalty of 8,500,000 HKD and required to carry out a look-back review of its transaction-monitoring alerts, submit a remedial plan and have its effectiveness assessed by an external adviser. Between May 2021 and January 2024 alerts were not properly followed up, unusual transactions of ten customers were not examined and documented, and senior management did not steer anti-money laundering controls effectively; a competent compliance officer, clear responsibilities and adequate training were lacking.
A monitoring system only protects the bank if senior management ensures that its alerts are handled by competent staff.
Handling monitoring alerts and senior management responsibility for anti-money laundering
Missing or inadequate training played a role in the decision.
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- s. 21(2)(a), (b), (c) AMLO (Cap. 615); Schedule 2 ss. 5(1)(c), 19(3), 23 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- No previous disciplinary record under the AMLO, cooperation with the regulator.
- Liability of senior managers
- The regulator found that senior management did not take a clear leadership role in anti-money laundering and did not appoint a competent compliance officer; the decision contains no measures against individuals.
- Published
- 22 Jul 2025
Original amount 8,500,000 HKD, converted at the ECB reference rate of 22 Jul 2025.
- HKMA press release: Monetary Authority takes disciplinary actions against three banks for contraventions of AMLO (22.07.2025) Press release of an authority
- HKMA Statement of Disciplinary Action Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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22 Jul 2025 33 Financial Services LimitedHKMA: reprimand and HKD 1.6m for 33 Financial Services over gift card failures €174,222
The HKMA reprimanded the licensed stored value facility provider 33 Financial Services and ordered it to pay a pecuniary penalty of HKD 1.6 million. Between December 2019 and August 2023, a group made up of one corporate and five individual customers bought more than 49,000 gift cards for around HKD 25 million without the firm sufficiently establishing the purpose and nature of the business relationship; for ten customers whom it knew to be buying on behalf of businesses, those businesses were not subjected to due diligence. The firm also failed to ensure that business partners verified and documented the identity of non-Hong Kong resident customers in person.
Gift cards are no exception: anyone evidently buying for a business brings that business in as a customer, and outsourced identity checks must be monitored.
Customer due diligence when selling gift and stored value cards
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- Sections 33Q(2)(a) und 33Q(2)(b)(iii), Section 8Q Payment Systems and Stored Value Facilities Ordinance (Cap. 584) i. V. m. Section 6(2)(b) Part 2 Schedule 3; Guideline on AML/CFT (For Stored Value Facility Licensees)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- yes
- Mitigating circumstances
- Remedial measures to improve controls and cooperation with the HKMA.
- Published
- 22 Jul 2025
Original amount 1,600,000 HKD, converted at the ECB reference rate of 22 Jul 2025.
- Monetary Authority takes disciplinary action against 33 Financial Services Limited for contravention of the PSSVFO Press release of an authority
- Statement of Disciplinary Action – 33 Financial Services Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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28 Apr 2025 Interactive Brokers Hong Kong LimitedSFC: HKD 4.2m fine for Interactive Brokers HK over securities lending without authority €476,704
The SFC publicly reprimanded Interactive Brokers Hong Kong and fined it HKD 4.2 million because, between December 2017 and October 2020, the broker lent securities listed on the Hong Kong stock exchange belonging to 7,911 clients on the basis of expired standing authorities. Owing to a programming error, the renewal notices had not been sent. This breached the Securities and Futures (Client Securities) Rules and the Code of Conduct.
Automated processes for client authorities need independent checks that deadlines and renewals are actually met.
Handling client securities and expiry of client authorities
- Authority / court
- Securities and Futures Commission (SFC), Hongkong
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- Section 194 Securities and Futures Ordinance (Cap. 571); Sections 7 und 10 Securities and Futures (Client Securities) Rules; General Principles 7 und 8, Paragraphen 11.1(a) und 12.1 Code of Conduct
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Culpability
- negligent
- Mitigating circumstances
- Self-report and remedial action, conduct not deliberate, no evidence of client loss, cooperation and acceptance of the findings.
- Published
- 28 Apr 2025
Original amount 4,200,000 HKD, converted at the ECB reference rate of 28 Apr 2025.
- SFC reprimands and fines Interactive Brokers Hong Kong Limited $4.2 million for regulatory breaches (25PR57) Press release of an authority
- Statement of Disciplinary Action – Interactive Brokers Hong Kong Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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27 Jan 2025 Hang Seng Bank LimitedHang Seng Bank: HKD 66.4m fine over selling practices and excessive charges €8.1m
Hang Seng Bank was publicly reprimanded and fined 66,400,000 HKD. Relationship managers had induced 46 clients, whose fund transactions in 2016/2017 were recorded as their own choice, to trade excessively often with short holding periods; between 2014 and 2018, 388 clients without established knowledge of derivatives bought derivative funds in 629 transactions; and between 2014 and 2023 the bank improperly retained benefits, overcharged fees and inadequately disclosed trailer fees (at least 22.4 million HKD). The bank has compensated affected clients and refunded the amounts overcharged.
Client transactions flagged as the client's own choice and fee billing need independent control, otherwise mis-selling and overcharging go undetected for years.
Investment advice: suitability, excessive trading and fee transparency
- Authority / court
- Securities and Futures Commission (SFC)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- s. 196 SFO (Cap. 571); Code of Conduct for Persons Licensed by or Registered with the SFC
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Compensation of clients and refund of benefits, internal and independent reviews after self-reporting, cooperation with the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC) and acceptance of the findings, no previous disciplinary record.
- Published
- 27 Jan 2025
Original amount 66,400,000 HKD, converted at the ECB reference rate of 27 Jan 2025.
- SFC press release 25PR14: SFC reprimands and fines Hang Seng Bank Limited $66.4 million (27.01.2025) Press release of an authority
- SFC Statement of Disciplinary Action zu 25PR14 Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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20 Jan 2025 Hong Kong Commercial Cleaning Services Limited, Man Shun Hong Kong & Kln Cleaning Company LimitedCleaning cartel in public housing tenders: company penalties of 22.26 million HKD €2.77m
In January 2025 the Competition Tribunal (Hong Kong's specialist competition court) imposed allegedly agreed penalties on two cleaning companies that, from at least May 2016 to August 2018, exchanged confidential bid information in 17 tenders of the Hong Kong Housing Authority (the public housing authority) for cleaning services at public housing estates (contract value around 180 million HKD) – price fixing under the First Conduct Rule (the ban on anti-competitive agreements); the case came to light through a complaint from a group that included cleaners at a housing estate. Hong Kong Commercial Cleaning Services Limited received 10,960,000 HKD, and Man Shun Hong Kong & Kln Cleaning Company Limited received 11,300,000 HKD on 20 January 2025. The amount and the facts have not been confirmed against the primary source.
Where competitors share offices, servers or staff, strict information barriers are needed – otherwise the exchange of bid data becomes a cartel.
Information exchange between competitors in public tenders
- Authority / court
- Competition Tribunal (Hongkong), auf Antrag der Competition Commission
- Area of law
- Competition law · Cartels and collusion
- Legal basis
- Competition Ordinance (Cap. 619), s. 6 (First Conduct Rule), s. 91 (Beteiligung), s. 93(1) (pecuniary penalty), ss. 101–102 (Disqualifikation)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Mitigating circumstances
- Cooperation discount of 9% for Hong Kong Commercial Cleaning (admission only after the trial dates had been fixed, less than five months before trial); for Man Shun a cooperation discount of 15% (admission before any witness statements were filed) and a further 20% reduction because the full penalty would have undermined its viability; payment in four and eight quarterly instalments respectively.
- Liability of senior managers
- Measures against individuals are not set out here.
- Published
- 20 Jan 2025
Original amount 22,260,000 HKD, converted at the ECB reference rate of 20 Jan 2025.
- Competition Tribunal: Competition Commission v. Hong Kong Commercial Cleaning Services Ltd and Others, CTEA 2/2021, [2025] HKCT 1, Reasons for Judgment 14.02.2025 Court decision
- Competition Commission: Competition Commission welcomes Tribunal's orders in cleansing service cartel case (20.01.2025) Press release of an authority
- Competition Commission: Hong Kong Commercial Cleaning Services admits liability and agrees to over HK$10 million penalty (09.12.2024) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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6 Dec 2024 China CITIC Bank International LimitedHKMA: HKD 4m fine for China CITIC Bank International over misconfigured rules €485,944
The HKMA imposed a pecuniary penalty of HKD 4 million on China CITIC Bank International because, in the transaction monitoring system it used from November 2015, 13 of 33 detection rules and two core model rules were not implemented as intended until July 2018, so fewer alerts were generated. For 12 of 30 sampled customers, the bank did not examine the background and purpose of unusual transactions. The HKMA identified the lack of a maker-checker control over system values and inadequate acceptance testing as root causes.
The parameters of a monitoring system belong under maker-checker control and must be tested against the business requirements before going live.
Maker-checker controls and testing when configuring monitoring systems
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Section 21(2)(c) Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Sections 5(1)(c) und 19(3) Schedule 2 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial action, no previous disciplinary record under the AMLO and cooperation with the HKMA.
- Published
- 6 Dec 2024
Original amount 4,000,000 HKD, converted at the ECB reference rate of 6 Dec 2024.
- Monetary Authority takes disciplinary action against China CITIC Bank International Limited for contraventions of the AMLO Press release of an authority
- Statement of Disciplinary Action – China CITIC Bank International Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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8 Nov 2024 Fubon Bank (Hong Kong) LimitedHKMA: HKD 4m fine for Fubon Bank (Hong Kong) over transaction monitoring gaps €477,640
The HKMA imposed a pecuniary penalty of HKD 4 million on Fubon Bank (Hong Kong) because, between April 2019 and July 2022, the bank lacked effective procedures for changes to its transaction monitoring: data transfer from the core banking system was poorly controlled, acceptance tests were ineffective, and there were no procedures for following up a sharp fall in alerts from June 2019 or for regularly reviewing the scope of monitoring. Transactions of around 64,000 customers were not properly scrutinised, and for around 1,500 of them no trigger event review took place after dormant business relationships were reactivated.
A sudden fall in monitoring alerts is itself a warning sign and must be investigated after every system change.
Change management and plausibility checks in transaction monitoring
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Section 21(2)(c) Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Sections 19(3) und 5(1) Schedule 2 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Self-report, cooperation, remediation of the deficiencies and no previous disciplinary record.
- Published
- 8 Nov 2024
Original amount 4,000,000 HKD, converted at the ECB reference rate of 8 Nov 2024.
- Monetary Authority takes disciplinary action against Fubon Bank (Hong Kong) Limited for contravention of the AMLO Press release of an authority
- Statement of Disciplinary Action – Fubon Bank (Hong Kong) Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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30 Aug 2024 a Hong Kong e-wallet providerE-wallet provider (Hong Kong): HKD 875,000 penalty for customer due diligence gaps €101,209
The e-wallet provider, a stored value facility licensee, must pay a pecuniary penalty of 875,000 HKD. From August 2016 to October 2021 it lacked adequate control systems to repeat customer due diligence upon trigger events and to apply enhanced due diligence in situations presenting a high risk of money laundering and terrorist financing. The company had self-reported the failings.
Wallet providers must reliably turn trigger events into a fresh customer review and treat high-risk cases separately.
Customer due diligence for e-wallets: trigger events and high-risk cases
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- ss. 8Q, 33Q(2)(a) PSSVFO (Cap. 584); Schedule 3 Part 2 s. 6(2)(b) PSSVFO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Self-report, remedial measures, no previous disciplinary record, cooperation.
- Published
- 30 Aug 2024
Original amount 875,000 HKD, converted at the ECB reference rate of 30 Aug 2024.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 30 Aug 2026 · Direct link
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5 Jul 2024 a Hong Kong commercial bankCommercial bank (Hong Kong): HKD 10m penalty for breaches of due diligence duties €1.18m
The commercial bank must pay a pecuniary penalty of 10,000,000 HKD because it breached due diligence duties under the AMLO in various periods between April 2012 and April 2019. Among other things, up to July 2017 it did not verify the identity of 609 persons whom 477 corporate customers had registered as authorisers in its corporate internet banking, did not complete trigger-event reviews for 23 customers, failed to identify suspicious transactions when reviewing transaction-monitoring alerts for 15 customers and did not establish the source of wealth and funds of high-risk customers; record-keeping and procedural failings came on top.
Persons who approve payments on behalf of corporate customers also belong in identity verification.
Customer due diligence in corporate banking and handling of monitoring alerts
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- s. 21(2)(c) AMLO (Cap. 615); Schedule 2 ss. 5(1)(a), 5(1)(c), 15(a), 19(3), 20(3) AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial measures and improved AML controls, no previous disciplinary record under the AMLO, cooperation.
- Published
- 5 Jul 2024
Original amount 10,000,000 HKD, converted at the ECB reference rate of 5 Jul 2024.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 5 Jul 2026 · Direct link
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19 Apr 2024 a Taiwanese commercial bank (Hong Kong branch)HKMA: HKD 9m fine for Taiwanese commercial bank over unreviewed alerts €1.08m
The HKMA imposed a pecuniary penalty of HKD 9 million on the Hong Kong branch of a Taiwanese commercial bank. Between April 2012 and July 2018 most alerts generated by the transaction monitoring system introduced in 2011 went unreviewed; after discovering this in 2018, the bank reviewed more than 2,200 customers and retrospectively filed 304 suspicious transaction reports on 504 customers. In addition, recipient names were missing from a number of cross-border wire transfers between March and July 2018.
A new monitoring system is no substitute for oversight: whether its alerts are actually reviewed must be checked continuously.
Handling of transaction monitoring alerts
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Section 21(2)(c) Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Sections 5(1)(c), 19(3), 12(3) und 12(5) Schedule 2 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- The bank identified and reported the deficiencies itself, took remedial measures, had no previous disciplinary record under the AMLO and cooperated in the proceedings.
- Published
- 19 Apr 2024
Original amount 9,000,000 HKD, converted at the ECB reference rate of 19 Apr 2024.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 19 Apr 2026 · Direct link
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2 Apr 2024 a Hong Kong state-owned technology park companyRansomware at technology park company: PCPD finds breaches and serves enforcement notice Order
After a ransomware attack in August 2023 on the technology park company, which is wholly owned by the Hong Kong government, data of 13,632 individuals were affected; data samples appeared on the dark web. On 2 April 2024 the PCPD (Privacy Commissioner for Personal Data, Hong Kong's data protection authority) found breaches of the data security duty (DPP 4(1)) and the retention limit (DPP 2(2)): brute-force attacks went undetected, remote access ran without multi-factor authentication, security audits were insufficient, the security policy lacked specificity, and data of 5,292 unsuccessful job applicants and former employees had been kept beyond the retention period. By enforcement notice, the company must among other things introduce multi-factor authentication, commission independent security audits every year and delete data held beyond the retention periods.
Multi-factor authentication for remote access and consistent deletion once retention periods expire limit both the damage and the liability in a cyberattack.
Ransomware, multi-factor authentication for remote access and retention periods
- Authority / court
- Privacy Commissioner for Personal Data (PCPD), Hongkong
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Personal Data (Privacy) Ordinance (Cap. 486), Data Protection Principles 4(1) und 2(2); Enforcement Notice nach s. 50(1)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Public sector
- Published
- 2 Apr 2024
Checked against the official source on 7 Oct 2026 · Company name anonymised since 2 Apr 2026 · Direct link
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29 Dec 2023 two Hong Kong food delivery platformsTwo food delivery platforms loosen exclusivity ties with partner restaurants Order
On 29 December 2023 the Competition Commission (Hong Kong's competition authority) accepted commitments from two food delivery platforms – the Hong Kong company of the first platform and the Hong Kong company of the second platform together with its parent company. Their agreements with partner restaurants contained exclusivity and pricing clauses which, in the authority's view, made it harder for new or small platforms to enter the market and could therefore breach the First Conduct Rule (the ban on anti-competitive agreements). The platforms must allow restaurants to work with platforms of up to 10% market share without losing the benefits granted to exclusive partners (such as lower commission rates), make switching easier and remove clauses that prohibit lower prices on the restaurants' own channels (and, for the first platform, on rival platforms); the first platform also drops the tie to its pick-up service, and the commitments run for three years.
Exclusivity and parity clauses used by platforms with market power are under competition-law scrutiny and should be reviewed regularly.
Exclusivity and price parity clauses of online platforms
- Authority / court
- Competition Commission (Hongkong)
- Area of law
- Competition law
- Legal basis
- Competition Ordinance (Cap. 619), s. 6(1) (First Conduct Rule); Annahme von Verpflichtungszusagen nach s. 60
- Action
- Order
- Status of proceedings
- final
- Sector
- Media and online platforms
- Published
- 29 Dec 2023
- Competition Commission (Hongkong), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 29 Dec 2025 · Direct link
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21 Dec 2023 an online marketplace (Hong Kong entity)PCPD: enforcement notice against online marketplace after scraping of user data Order
After data of 2.6 million of the marketplace's users worldwide, including 324,232 accounts in Hong Kong, had been offered for sale on an online forum, the PCPD found that the marketplace's Hong Kong entity had breached DPP 4(1). The cause was a vulnerability in an application programming interface introduced during a system migration in January 2022; there was no privacy impact assessment, no complete code review, no thorough security assessment, no written code review policy and no effective detection measures. The PCPD issued an enforcement notice even though the systems were run centrally by the group.
A local company remains responsible for data security even where the group runs the systems centrally; migrations need a prior impact assessment and security review.
Data protection and code review during system migrations
- Authority / court
- Privacy Commissioner for Personal Data (PCPD), Hongkong
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Data Protection Principle 4(1) Schedule 1 und Section 50(1) Personal Data (Privacy) Ordinance (Cap. 486)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Media and online platforms
- Mitigating circumstances
- Prompt data breach notification to the PCPD and affected users, cooperation with the investigation, voluntary acknowledgement of its deficiencies, and technical and organisational measures taken by the group after the incident.
- Published
- 21 Dec 2023
Checked against the official source on 7 Oct 2026 · Company name anonymised since 21 Dec 2025 · Direct link
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21 Dec 2023 a luxury fashion company in Hong KongPCPD: enforcement notice against luxury fashion company over health data in chat groups Order
A supervisor at the luxury fashion company shared a photo of an employee's medical diagnosis certificate in a work chat group of around 14 members and forwarded the employee's sick note to another group of around 10 members. The PCPD regarded this as use of health data for a new purpose without express consent and thus a breach of DPP 3(1). It issued an enforcement notice requiring policies, their inclusion in training, staff awareness measures and regular monitoring.
Sick notes and diagnoses belong only with those who need them for HR decisions, not in team chats.
Handling employees' health data in messaging groups
Missing or inadequate training played a role in the decision.
- Authority / court
- Privacy Commissioner for Personal Data (PCPD), Hongkong
- Area of law
- Data protection · Employee data
- Legal basis
- Data Protection Principle 3(1) Schedule 1 Personal Data (Privacy) Ordinance (Cap. 486)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Retail and e-commerce
- Published
- 21 Dec 2023
Checked against the official source on 7 Oct 2026 · Company name anonymised since 21 Dec 2025 · Direct link
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18 Dec 2023 a Hong Kong e-money providerE-money provider: reprimand and HKD 1.575m penalty for AML and governance failings €185,000
The stored value facility licensee was reprimanded and must pay a pecuniary penalty of 1,575,000 HKD. From February 2019 to mid-July 2020 it lacked adequate transaction-monitoring controls under the AML guideline for SVF licensees, and from August 2016 to August 2020 it lacked sound governance, an effective risk management framework and a robust internal control system. The company therefore did not meet minimum criteria for its licence.
Payment and e-money providers must treat transaction monitoring, governance and internal controls alike as conditions of their licence.
Anti-money laundering and risk management in payment and e-money services
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- ss. 8Q, 33Q(2)(a), 33Q(2)(b)(iii) PSSVFO (Cap. 584); Schedule 3 Part 2 ss. 5(1)(d), 6(2)(b) PSSVFO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial measures (some at the regulator's request), no previous disciplinary record, cooperation.
- Published
- 18 Dec 2023
Original amount 1,575,000 HKD, converted at the ECB reference rate of 18 Dec 2023.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 18 Dec 2025 · Direct link
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21 Aug 2023 a Hong Kong corporate finance adviserCorporate finance adviser: HKD 20m fine and sponsor ban over due diligence failures €2.34m
The corporate finance adviser was publicly reprimanded, fined 20,000,000 HKD and may not act as a sponsor for listing applications on the Stock Exchange of Hong Kong for at least one year from 18 August 2023 and, beyond that, until the regulator is satisfied with its sponsor controls. Across six listing applications it filed as sponsor between 2015 and 2017, three applications each lacked adequate due diligence on material business issues, correct advice on listing eligibility or disclosure of material information in the draft prospectus, and for all six the due diligence work was not properly documented.
A sponsor must critically examine an issuer's core risks, ensure they are disclosed and document its review in a traceable way.
Due diligence duties of sponsors in initial public offerings
- Authority / court
- Securities and Futures Commission (SFC)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- s. 194 SFO (Cap. 571); Code of Conduct GP 2, GP 7, para. 12.1 und Kapitel 17 (u. a. paras. 17.1(b), 17.2, 17.3(b), 17.4, 17.6, 17.9(a), 17.10(c)); Corporate Finance Adviser Code of Conduct paras. 1.5, 2.3, 5.1, 5.7; Practice Note 21 der Listing Rules paras. 2 und 4
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- The firm's financial position (otherwise a heavier fine), commitment to an independent review of the sponsor business, cooperation, otherwise clean disciplinary record.
- Published
- 21 Aug 2023
Original amount 20,000,000 HKD, converted at the ECB reference rate of 21 Aug 2023.
- Securities and Futures Commission (SFC), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 21 Aug 2025 · Direct link
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15 Aug 2023 a Hong Kong branch of a Swiss private bankPrivate bank (Hong Kong): HKD 16m penalty for inadequate identity and customer checks €1.87m
The Hong Kong branch of a Swiss private bank must pay a pecuniary penalty of 16,000,000 HKD. Despite known red flags, from February 2016 to January 2018 it did not verify in a timely manner the identity of 147 customers transferred from another institution and of their beneficial owners; from April 2012 to October 2018 it also failed to adequately verify the beneficial owners of 33 higher-risk customers, did not terminate 23 of these relationships in time and omitted trigger-event reviews of unusually large transactions of 33 customers.
Anyone taking over a customer book from another institution must promptly carry out its own identity verification, including beneficial owners.
Identifying beneficial owners and handling transferred customer books
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- s. 21(2)(c) AMLO (Cap. 615); Schedule 2 ss. 3(1), 3(3), 3(4)(b), 5(1)(a), 19(3) AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial and enhancement measures, no previous disciplinary record under the AMLO, cooperation with the regulator.
- Published
- 15 Aug 2023
Original amount 16,000,000 HKD, converted at the ECB reference rate of 15 Aug 2023.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 15 Aug 2025 · Direct link
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14 Jun 2023 three Hong Kong mail inserter suppliersMail inserter cartel: Tribunal imposes 5,579,000 HKD on three suppliers €659,106
On 14 June 2023 the Competition Tribunal (Hong Kong's specialist competition court), on a joint application with the Competition Commission (Hong Kong's competition authority), imposed pecuniary penalties on three suppliers of mail inserters of the same brand that had fixed prices, shared markets and rigged bids between April 2018 and January 2019 (breach of the First Conduct Rule). The brand manufacturer's two Hong Kong companies (which formerly traded under the brand name) pay 1,399,000 HKD together, the second supplier 3,372,000 HKD and the third supplier 808,000 HKD, 5,579,000 HKD in total; in addition each pays 476,101 HKD in investigation costs plus legal costs. It was the first case in which all parties under investigation cooperated with the authority under its cooperation policy already at the investigation stage; in return the Commission refrained from pursuing the employees involved.
Disclosing a cartel early and cooperating with the authority substantially reduces the penalty and can shield a company's own employees from personal enforcement action.
Price fixing, market sharing and bid rigging in sales
- Authority / court
- Competition Tribunal (Hongkong), auf Antrag der Competition Commission
- Area of law
- Competition law · Cartels and collusion
- Legal basis
- Competition Ordinance (Cap. 619), s. 6 (First Conduct Rule), s. 93 (pecuniary penalty), s. 96 (Ermittlungskosten)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Mitigating circumstances
- Cooperation discounts of 25% (brand manufacturer, second supplier) and 28% (third supplier); liability and penalties agreed by consent.
- Published
- 15 Jun 2023
Original amount 5,579,000 HKD, converted at the ECB reference rate of 14 Jun 2023.
Checked against the official source on 7 Oct 2026 · Company name anonymised since 14 Jun 2025 · Direct link
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18 May 2023 a Hong Kong securities firmSFC: HKD 6m fine for securities firm over failures as placing agent €708,885
The SFC publicly reprimanded the securities firm and fined it HKD 6 million over its conduct as placing agent for the then majority shareholder of another company in November and December 2019. The firm entered into trades at prices that differed from the agreed placing price, transferred the shares to the purchasers without prior payment and carried out an unverified third-party instruction to transfer part of the shares free of charge. The SFC regarded this as grossly negligent.
An agent transferring a principal's assets must stay within the principal's instructions, secure payment before delivery and verify third-party instructions with the principal.
Limits of authority and protection of the principal's assets in share placements
- Authority / court
- Securities and Futures Commission (SFC), Hongkong
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- Section 194 Securities and Futures Ordinance (Cap. 571); Code of Conduct for Persons Licensed by or Registered with the SFC
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Culpability
- negligent
- Repeat case
- no
- Mitigating circumstances
- Insufficient evidence of dishonesty or recurrent misconduct; otherwise clean disciplinary record.
- Published
- 18 May 2023
Original amount 6,000,000 HKD, converted at the ECB reference rate of 18 May 2023.
- Securities and Futures Commission (SFC), Hongkong, Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 18 May 2025 · Direct link