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2026年7月1日，中國對外投資領域迎來歷史性時刻－《國務院關於對外投資的規定》（國務院令第837號，簡稱「837號令」 ）正式施行。 ODI境外投資新規正式施行！國務院837號令全面解讀，企業出海必看 2026年7月1日，中國對外投資領域迎來歷史性時刻－《國務院關於對外投資的規定》（國務院令第837號，簡稱「837號令」 ）正式施行。這是 我國對外投資領域的重要基礎行政法規 ，標誌著對外投資監管從部門規章層級正式提升至行政法規層級。 對於正在佈局或計劃出海的企業而言，瞭解837號令的核心變化，已成為必修課。 一、為什麼要出台837號令？ 長期以來，我國對外投資監管主要依賴發改委 《企業境外投資管理辦法》 （11號命令）、商務部 《境外投資管理辦法》 （3號令）等部門規章。這種「拼盤式」監管有三個突出問題： · 法律位階偏低 ，在海外投資仲裁缺乏足夠法律支撐； · 規則分散碎片化 ，各部門口徑不盡一致； · 關鍵領域存在製度空白 ，如個人境外投資、安全審查等面向。 例如，專案核准或備案、境外投資備案以及跨國資金登記，本身就涉及不同主管機關；如果專案進一步涉及技術出口、資料出境、國有資產或稅務事項，則需要分別適用相關領域的監管規定。 837號令的出台，是在國務院行政法規層級建立統一的對外投資管理框架，將先前分散在不同監管領域的要求進行更有系統的銜接。 換句話說： 企業今後不能只問“ODI備案有沒有辦下來”，而要進一步問： “整個境外投資項目，從立項、資金出境到境外運營和退出，是否都符合監管要求？” 二、837號令核心變化：六大要點值得關注 1. 監管對象擴大：個人首次被明確納入 這是最值得關注的變革之一。 先前11號令與3號令的適用範圍均限於“境內企業”，個人境外投資長期缺乏明確的法律依據。 837號令第二條明確將 「中國境內的企業、其他組織和居民個人」 全部納入投資者範圍。第三十三條進一步授權發改委、商務部製定居民個人對外投資的具體管理辦法。 這意味著，個人境外投資已正式進入對外投資頂層制度框架。對於過去透過BVI、開曼、SPV等安排進行境外投資的居民個人而言，後續具體監管規則值得持續關注。 此外，對投資者在港澳台地區的投資，參考本規定執行；對境外再投資、境外金融市場投資的管理，也納入本規定架構。 2. “核准—備案—報告” 等義務進一步統一，從事前監管轉向全過程監管 這是新規中非常值得企業管理階層關注的一點。 837號命令並未取消或取代傳統的ODI備案體系，而是將發改委、商務部、外匯局三部門的核准/備案製度 上升為國家法定義務 。 核准制 ：涉及敏感產業或敏感國家的境外投資，需報請國務院投資主管機關核定。 備案製 ：非敏感產業的一般性境外投資實施備案管理。 報告製 ：已備案項目發生重大事項變更（如投資主體、投資金額、股權架構、經營內容等），還需依適用規定履行相應報告、變更或其他程序。 傳統理解中，企業往往把境外投資合規的重點放在兩個階段： 項目能否完成核准或備案，以及資金能否順利匯出境外。 837號令則進一步強調「全過程監管」 。 專案完成投資後，境外企業的治理結構、內部控制、安全生產、風險管理、突發事件處置、員工及資產安全等事項，都成為持續需要關注的內容。 新規第十六條明確要求，投資者及其境外投資企業應完善治理結構，並建立合規經營、內部控制、安全生產及突發事件處置等製度。 因此：ODI不應再被理解為「一次性手續」 。 對於已完成境外投資的企業而言，後續營運、重大變更及退出安排，同樣屬於境外投資合規管理的一部分。 3. 科技、數據、人員跨境成為重點 不少企業過去進行海外佈局時，首先想到的是： “錢怎麼出去？” 837號令實施後，企業還需要同步考慮另外幾個問題： “技術能不能出去？” “數據能不能出去？” “人員和技術服務安排是否涉及受限事項？” 新規第十三條明確禁止投資人透過 「跨境派遣技術人員、組織人員赴境外工作、跨境提供技術指導、安排人員跨境培訓」 等方式，向境外轉移國家禁止或限制出口的貨物、技術、服務及相關數據。 第十四條進一步將資金匯兌、貨物及技術進出口、跨境服務貿易、跨境資料流動、人員出入境、經營者集中、出口管制、網路安全、稅務及國有資產監管等事項納入相關法規的銜接範圍。 這項條款對高科技企業影響尤為深遠。 以往許多企業認為「只要不直接出口設備，派人去指導」不算技術出口，現在這類安排的合規風險明顯上升。科技、AI、半導體、高端製造、金融科技、生物醫藥等領域的企業，必須將技術和數據合規審查 前置到專案立項階段 。未來進行海外投資時，投資部門、法務、財務、稅務、資料安全及業務團隊之間，需要更早形成協同。 「公司能不能設」與「業務能不能真正搬過去」 ，可能是兩個不同的問題。 4. 境外投資安全審查權重提升 第十五條明文規定，國家健全境外投資安全審查制度，對影響或可能影響國家安全的境外投資及相關資產、權益的轉讓、處分進行安全審查。 這意味著，對某些涉及關鍵技術、重要資料、核心資源或其他國家安全因素的交易而言，企業不能僅從「註冊主體在哪裡」「交易合約在哪裡簽署」判斷監管風險。 境外投資監管越來越關注交易的經濟實質、資產權益及風險本身。 因此，在複雜跨境架構中，單純增加香港、BVI、開曼等中間持股主體，並不代表原本適用的監管要求自然消失。 新規實施後， 安全審查已成為與核子準備案並行的獨立監管程序 。對於涉及關鍵技術、重要數據、戰略資源、關鍵基礎設施的項目，企業必須單獨評估安全審查風險。 5. 違規處罰大幅升級 這是最讓企業感到壓力的改變。 837號令第二十七條設定了前所未有的梯級處罰： 違規情形 可能後果 未依規定履行核准案，或提交虛假資料、隱瞞真實資訊 命令改正、沒收違法所得，並可處投資額1‰—5‰罰款 拒不改正 可責令停止投資、限期處分股份或資產，並處投資額5‰—10‰罰款 相關直接責任人員 可處2萬元—5萬元罰款 嚴重違規後的後續影響 相關部門可3年內不受理新的核准備案申請，或限制1—3年進行對外投資 先前ODI違規的後果主要是警告、命令整改等行政措施，幾乎沒有財產性處罰，也很少追究個人責任 。新規實施後，違規不僅會導致企業面臨巨額罰款，企業之外，直接負責的主管人員和其他直接責任人員亦可能面臨個人處罰。 6. 海外權益保護機制首次系統建立 837號令並非只有「管」的一面，也首次在法律層級系統建構了海外權益保護框架： 投資障礙調查 （第二十三條）：遭遇目的國投資障礙時，國務院有關部門可進行調查並採取因應措施。 反歧視反制 （第二十四條）：可依據《反外國制裁法》將相關組織、個人列入反制清單。 領事保護 （第二十條）：駐外外交機構有義務為中國公民和組織提供領事保護與協助。 三、企業需要關注什麼？ 1. 「先上車後補票」已成歷史 新規實施後，未備案即開展境外投資（ 「搶跑」）、虛假申報、隱瞞真實資訊等行為，將面臨高額罰款及業務限制。 「先設立海外公司、後補ODI備案」的營運模式風險極高。 2. 多層SPV架構需重新檢視 在真實性審查、安全審查及複雜境外架構下，監管關注已越來越不限於表層持股主體，可能進一步關注投資架構、資產權益、技術資料以及實際控制關係。單純依靠BVI、開曼多層架構實現「避稅」或規避監管的做法，合規門檻已顯著提高。 3. 技術、數據、人員跨境流動需審慎評估 涉及技術人員派遣、跨境技術指導或培訓的企業，不能僅將其視為普通人事安排，而應同步評估其中是否涉及受管制技術、服務或資料的跨境轉移。 4. 年度報告與持續合規 新規要求投資人在境外投資完成後，需依規定提交專案完成情形報告；境外企業需每年透過外匯局系統申報存量權益資料。 ODI不是「一次性」工作，而是需要長期合規管理的持續義務。 5. 企業出海，建議把這5項檢查前置 837號命令下，比較值得建立的並不是一份單純的「ODI材料清單」 ，而是一套境外投資合規檢查機制。 檢查維度 企業應重點考慮 投資架構 誰是實際投資主體？ 直接投資還是多層持股？ 各層架構是否有合理商業目的？ 資金路徑 投資資金來源是否真實、合法？ 資金如何出境？ 後續利潤、分紅及退出資金如何安排？ 科技與數據 是否涉及受管制技術、重要數據、跨境系統或技術人員輸出？ 境外經營 地方公司治理、反商業賄賂、勞動用工、稅務、環保及內部控制是否完善？ 重大變化與退出 增資、減資、股權轉讓、業務變更或專案終止後，是否需要辦理相應變更、申報或註銷程序？ 核心思路只有一個： 把「合規」放到投資決策之前，而不是等到銀行要求文件、交易交割或監理問詢時才開始補救。 新規提出的監管方向，本身也非常明確——分類分級實施全過程監管，並在加強風險控制的同時推動投資便利化。 寫在最後 837號令的核心邏輯可以概括為四個關鍵字： 鼓勵、規範、安全、保護 。 國家依然大力支持企業“走出去”，但“走出去”的門檻已經全面升級。從前大家更重視審批能否通過、資金能否順利出境；現在考驗的是 綜合合規能力 ──國家安全、技術管控、資料安全、海外風險應對，缺一不可。 對於已經佈局海外或計劃出海的企業而言，趁早吃透規則、完成自查整改，才能在接下來的國際化佈局中走得更遠、更遠。 參考資料： 《國務院關於對外投資的規定》（中華人民共和國國務院令第837號） ，《企業境外投資管理辦法》（國家發展與改革委員會令第11號） ，《境外投資管理辦法》（商務部令2014年第3號） [完結 - ODI境外投資新規正式施行！國務院837號令全面解讀，企業出海必看 ] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The article is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

The topics discussed in this monthly newsletter for Licensed Corporations are as follows: ComplianceOne Newsletter – September 2026 The topics discussed in this monthly newsletter are as follows: Market News Record year for investment product sales in Hong Kong with robust demand for FICC-related products: SFC-HKMA joint survey 2025 New synopsis by Julia Leung: Remarks at Media Briefing on SFC’s Strategic Action Plan Enforcement News - Intermediaries SFC bans Mok Cheuk Ling for 42 months SFC reprimands and fines Zheng Da International Financial Holding Limited HKD 7 million and suspends its responsible officer for regulatory breaches Enforcement News - ListCo SFC suspends dealings in Cloudbreak Pharma Inc. shares over suspected IPO rigging SFC suspends dealings in Silver Grant International Holdings Group Limited shares over suspicious diversion of over HKD 1 billion in loan proceeds to its then-major shareholder and related party Regulatory Updates SFC enhances guidance for authorised funds with exposure to private market assets SFC and AFRC extend regulatory cooperation to financial reporting of licensed firms and funds under new MoU Circular to Intermediaries Roadmap for Implementing the Hong Kong Investor Identification Regime for the Exchange-traded Derivatives Market SFC, Securities Commission Malaysia announce Single Submission Arrangement to streamline simultaneous listings in Malaysia and Hong Kong Markets News 1. Record year for investment product sales in Hong Kong with robust demand for FICC-related products: SFC-HKMA joint survey 2025 On 8 September 2026, the Securities and Futures Commission ( SFC ) and Hong Kong Monetary Authority ( HKMA ) published their 2025 joint survey showing that sales of non-exchange-traded investment products reached a record high in 2025, supported by higher participation from clients and firms and strong demand for fixed-income, currency and commodity ( FICC )-related products. The number of clients completing at least one transaction and the number of intermediaries selling investment products both increased compared with the prior year, with growth especially pronounced among large firms. Collective investment schemes overtook structured products as the top-selling product type for the first time since 2020. Money market funds and currency-linked products were prominent in client allocations, while debt securities sales continued to expand, led by sovereign and investment-grade corporate bonds. The survey also highlighted increasing digitalisation of distribution, with online sales accounting for a material share of aggregate transaction amounts. Metric Latest (2025) YoY Change Sales of non-exchange-traded investment products HKD 9.9 T +63% Clients with ≥1 transaction >1.6 M +33% Licensed corporations & registered institutions selling investment products 452 +9% Large firms (selling investment products) 128 +27% Collective investment schemes ( CIS ) sales +85% Structured products sales +53% Money market funds (share of top 5 CIS sales by large firms) 88% Currency-linked product sales HKD 698 B +50% Debt securities sales (vs 2022) +43% vs 2022 Online sales (share of aggregate transaction amount) +21% As Mr HUI Kenneth said “The strong growth captured in this year’s survey is a clear testament to investor confidence in Hong Kong’s asset and wealth management industry. The HKMA will continue to adopt a balanced, proportionate regulatory approach, to ensure robust investor protection while fostering a positive customer experience and supporting the industry’s continued growth” . SIGNIFICANCE: The survey confirms sustained growth in client participation and product demand, particularly in CIS and FICC-related products. Licensed corporations ( LCs ) should review product offerings and distribution channels to align with these trends, while ensuring suitability assessments and risk disclosures remain robust as transaction volumes and online sales increase. 2. New synopsis by Julia Leung: Remarks at Media Briefing on SFC’s Strategic Action Plan On 23 September 2026, the SFC posted a synopsis of CEO Ms Julia LEUNG’s remarks at a media briefing on the SFC’s Strategic Action Plan. In her remarks, Ms LEUNG outlined the SFC’s strategic priorities to support Hong Kong’s development as an international financial centre, including strengthening market resilience, advancing digital transformation, and deepening regional and international connectivity. She emphasised the SFC’s focus on maintaining high regulatory standards while fostering innovation and sustainable growth in the asset and wealth management sector. SIGNIFICANCE: The synopsis signals the SFC’s strategic direction and regulatory priorities for the coming period. LCs should monitor how these priorities translate into specific policy initiatives, supervisory expectations and licensing requirements, particularly in areas such as digitalisation, cross‑border activities and product innovation. Enforcement News - Intermediaries 3. SFC bans Mok Cheuk Ling for 42 months On 11 September 2026, the SFC prohibited Ms MOK Cheuk Ling, a former licensed representative of Sun Hung Kai Investment Services Limited ( SHKIS ) and Sun Hung Kai Commodities Limited ( SHKCOM ) (collectively, SHK ), from re‑entering the industry for 42 months, from 11 September 2026 to 10 March 2030. The SFC found that, between 2009 and 2021, Mok traded on a discretionary basis in the accounts of seven clients of SHK without obtaining their written authorisation and without disclosing these arrangements to her firm, contrary to its policy. Mok also provided false or misleading account information to two clients between 2015 and 2020, and furnished false account statements to three clients in 2021, including inflated balances and fabricated trade details. The SFC regarded Mok as not fit and proper, noting that her conduct spanned over 12 years, caused client losses of close to HKD 3 million, and that she partially compensated some clients with over HKD 1.2 million of her own funds. *For details, please refer to the statement of disciplinary action. SIGNIFICANCE: The case reinforces the SFC’s focus on written client authorisations for discretionary trading, proper disclosure to firms, and the integrity of account information and statements. LCs should ensure that discretionary arrangements are documented, approved and monitored in line with internal policies, and that client access credentials and account reporting controls are robust. Individuals should note that prolonged misconduct, client losses and falsification of account information can lead to substantial industry bans even where partial compensation is made. 4. SFC reprimands and fines Zheng Da International Financial Holding Limited HKD 7 million and suspends its responsible officer for regulatory breaches On 29 September 2026, the SFC has reprimanded and fined Zheng Da International Financial Holding Limited ( Zheng Da ) HKD 7 million for serious AML/CFT and regulatory failures between 01 December 2021 and 30 September 2023, and suspended the licensed of its Responsible Officers, Mr ZHONG Hao, for seven months. Material Deficiency Details No due diligence on Customer Supplied Systems (CSSs) 160 clients used automated systems for futures order placement, Zheng Da conducted zero testing or due diligence, exposing itself to unlicensed activity, nominee accounts, unauthorized access and ML risks. Inadequate client deposit scrutiny 8 accounts showed deposit inconsistent with declared financial profiles; despite claiming RO Zhong made enquiries, no records existed, failing to address ML/TF red flags. Failed ongoing monitoring No effective system to detect suspicious trading; 176 instances of identical buy/sell futures orders by the same client within the same second at the same price went undetected. Systemic control failures Overall systems and controls were inadequate to comply with the AMLO, AML Guideline and Code of Conduct. SIGNIFICANCE: This case shows the SFC’s AML regime is now rigorously enforced at both the institutional and individual level, especially where technology-driven trading meets weak oversight. LCs must treat CSS onboarding, deposit monitoring, and trade surveillance as core licensing obligations, not back-office formalities. Enforcement News - ListCo 5. SFC suspends dealings in Cloudbreak Pharma Inc. shares over suspected IPO rigging On 10 September 2026, the SFC directed the Stock Exchange of Hong Kong Limited ( SEHK ) to suspend dealings in the shares of Cloudbreak Pharma Inc. ( Cloudbreak ) ( HK Stock Code: 02592 ) under section 8(1) of the Securities and Futures (Stock Market Listing) Rules, with effect from 9:00 AM that day. The SFC stated that it has serious concerns that Cloudbreak’s initial public offering ( IPO ) may have been rigged to create an artificial impression of demand for the company’s shares. The suspension was considered necessary or expedient to maintain an orderly and fair market in Cloudbreak’s shares and to protect the interests of the investing public while the SFC’s investigation continues. The SFC indicated that it will not make further comments while the investigation, commenced under section 182(1) of the Securities and Futures Ordinance, is underway. Cloudbreak has been listed on the Main Board of the SEHK since 03 July 2025. SIGNIFICANCE: The suspension underscores the SFC’s willingness to intervene swiftly where there are serious concerns of IPO misconduct that may distort price formation and demand. Market participants, including sponsors, intermediaries and investors, should be mindful that suspected rigging activity can trigger trading suspensions and extended regulatory scrutiny. LCs involved in IPO distribution or market-making should reinforce controls around order allocation, client due diligence and monitoring of unusual subscription or trading patterns. 6. SFC suspends dealings in Silver Grant International Holdings Group Limited shares over suspicious diversion of over HKD 1 billion in loan proceeds to its then-major shareholder and related party On 25 September 2026, the SFC directed SEHK to suspend trading in Silver Grant International Holdings Group Limited ( Silver Grant ) ( HK Stock Code: 0171 ) with effect from 9:00 AM that day, citing serious concerns under Section 8(1) of the Securities and Futures (Stock Market Listing) Rules. The action follows an SFC investigation which found that between March 2021 and December 2023, the company granted approximately HKD 2 billion in unsecured loans, of which over HKD 1 billion, around 63%, was indirectly routed through rapid onward transfers to its then-major shareholder and a related party. The SFC’s investigation further revealed that Silver Grant’s due diligence and credit assessments in relation to these loans were inadequate, and the company was unable to provide any satisfactory commercial explanation for the transactions. Given the significance of these concerns and the failure to address them, the SFC determined that a trading suspension was necessary to protect the investing public and maintain an orderly and fair market. The SFC’s investigation is still ongoing. SIGNIFICANCE: The SFC treats connected-party lending and related -party transactions as a serious red-line especially where large unsecured loans are extended to insiders or their associates without proper commercial rationale, the SFC will intervene swiftly, and any LC involved with the issuer (whether as sponsor, financial adviser, asset manager or broker) faces significant reputational and supervisory exposure. Furthermore, with the SFC’s broader 2026 enforcement posture, where disclosures are unconvincing and investor protection is at stake, the SFC will use its suspension powers proactively rather than waiting for a final investigation outcome. Regulatory Updates 7. SFC enhances guidance for authorised funds with exposure to private market assets On 03 September 2026, the SFC issued a circular setting out enhanced disclosure requirements for SFC‑authorised funds with exposure to private credit and private equity. The SFC noted that some funds may obtain indirect exposure to private market assets through layered structures and complex instruments that may lack transparency, while retail investors may have limited familiarity with these assets and their risks. Fund managers must provide a clear, sufficiently complete and balanced picture of the characteristics, nature and risks of a fund’s private market exposures. The SFC may also subject such funds to enhanced scrutiny and classify them as complex products with heightened distribution requirements where appropriate. For existing funds with potential private market exposure, fund managers are expected to review and update offering documents as soon as practicable. Area Before After Regulatory Focus Private-market exposure addressed mainly through general rules: 15% NAV limit for unlisted/non-market traded investments, general risk disclosure, and case-by-case SFC review Explicit, tailored guidance on private credit + private equity, including direct and indirect exposure Business Development Companies ( BDCs ), Collateralised loan obligation ( CLOs ), other financial derivative instruments. Disclosure in Offering doc General risk factors: “private assets may be illiquid/ hard to value”. Enhanced disclosures on: - Extent and means of access - Nature/characteristics of underlying assets - Specific risks and impact on NAV/redemptions/valuation. Key facts statement must reflect this too. Complex-product test No dedicated private-market threshold. Complexity assessed under existing complex product principles. More than 50% of NAV in aggregate direct + indirect private market assets of the fund’s NAV. Below 50% NAV may still designate as complex based on liquidity, leverage, or opacity. Distribution Obligation Complex-product rules applied if product already met existing complex product definition. Private-market funds crossing threshold face suitability obligation irrespective of solicitation/ recommendation, stronger distributor competency expectations, target-market alignment. SIGNIFICANCE: The circular tightens disclosure expectations for retail funds with private market exposure. Fund managers should review portfolio holdings and offering documents to ensure exposures and risks are clearly and accurately described. Where total direct and indirect exposure reaches or exceeds 50% of NAV, funds may be classified as complex products, triggering enhanced suitability and distribution obligations. 8. SFC and AFRC extend regulatory cooperation to financial reporting of licensed firms and funds under new MoU On 28 September 2026, the SFC and the Accounting and Financial Reporting Council ( AFRC ) signed a revised MoU replacing the 24 February 2021 version. The new MoU extends regulatory cooperation beyond listed-entity financial reporting to cover the financial and compliance reporting of SFC-LCs, SFC-licensed virtual asset service providers ( VASPs ), SFC-authorized collective investment schemes, and registered open-ended fund companies ( OFCs ), plus the audit/assurance work done for these entities. Under the MoU, the two regulators formalize: · Case referrals between SFC and AFRC on auditor conduct, licensed-firm reporting failures, fund/OFC reporting issues; · Information sharing subject to statutory confidentiality; · Coordinated Investigations/Inspections via a task force for significant cases; · Prior consultation/notice where AFRC investigates auditors serving Licensed Person, licensed VASP, Authorized CIS or Registered OFC; and · Capacity building/joint training on accounting, audit and compliance-reporting standards. As Ms LEUNG Julia, CEO, said, “ This MoU strengthens regulatory backing for our collaboration with the AFRC, ensuring our supervision evolves with market dynamics. Deepening our regulatory cooperation across financial sub-sectors is essential to upholding the quality of financial reporting and bolstering the confidence of global investors in Hong Kong’s regulatory system ”. For details of Dr WONG Kelvin’s speech, please click here . SIGNIFICANCE: Since the MoU provides for coordinated investigations and no unnecessary double action principles, a LC under SFC review may simultaneously face scrutiny of its auditor. LCs should expect a tighter documentary demands, joint interviews, and aligned messaging requirements. 9. Circular to Intermediaries Roadmap for Implementing the Hong Kong Investor Identification Regime for the Exchange-traded Derivatives Market On 30 September 2026, the SFC issued a circular setting out the implementation for the Hong Kong Investor Identification Regime – Derivatives Market ( HKIDR-DM ). It requires LCs and registered institutions that provide derivatives brokerage or conduct proprietary trading, collectively as Relevant Regulated Intermediaries ( RRIs ) to collect Client Identification Data ( CID ) for every relevant trading exchange-traded derivatives and map it to the Broker Client Account Number ( BCAN ). It extends the existing securities-market investor ID model to exchange-traded derivatives-futures options and stock options traded via the Hong Kong Futures Exchange Limited ( HKFE ) and HKEX. Core Obligations of RRIs as per Code of Conduct Paragraph 5.6A 1 Assign a BCAN to each relevant client 2 Collect CID of each relevant client 3 Submit BCAN-CID Mapping files to HKEX’s central repository 4 Tag the BCAN on every exchange-traded derivatives order. 5 Obtain express client consent from individual clients for collection/ transfer of personal data; corporate clients do not need privacy consent. 6 Apply data-privacy and security controls; participate in testing/ market rehearsals. Standard Requirement for CID Individuals Full Name, ID-issuing jurisdiction, ID type, ID number Corporates Full Name, Jurisdiction, ID Type (BR Certificate), ID number Trusts/ funds Trustee CID or asset manager/ fund CID Joint Accounts CID for all named holders under the same BCAN. RRIs must obtain express client consent for personal-data use covering SFC-specified purposes, submit BCAN-CID mapping files via HKEX’s Electronic Communication Platform, tag orders with BCAN, and join end-to-end testing/ market rehearsals before go-live which sets to be on Q2 of 2028. SIGNIFICANCE: The SFC’s road map of the HKIDR-DM is less a policy surprise and more an inevitability. Hong Kong is simply extending the transparency model already used in the securities market into futures, options and stock options. The SFC want order-level visibility, and intermediaries are the data pipeline. 10. SFC, Securities Commission Malaysia announce Single Submission Arrangement to streamline simultaneous listings in Malaysia and Hong Kong On 30 September 2026, the SFC and the Securities Commission Malaysia ( SC ) have launched the Single Submission Arrangement implementing the July 2026 MoU on a simplified dual-IPO framework. A company seeking a primary listing on either the Main Board of SEHK or Bursa Malaysia MAIN Market, with a simultaneous secondary listing on the other market, now needs only: · One listing application submission, and · One listing document accepted across both markets. The arrangement adds dedicated dual-listing review teams, a single coordinated communication channel through the primary-listing regulator, and aligned regulatory review timelines. Its purpose is to cut duplication and compliance costs at the IPO stage while preserving each jurisdiction’s listing, disclosure, and investor-protection standards. SIGNIFICANCE: This arrangement makes Hong Kong-Malaysia dual listing more practical and is expected to reduce duplication and compliance costs at IPO application stage. However, LCs must still carry full conduct, due diligence, and regulatory-standard obligations. It is important to note that this arrangement is NOT a waiver of substantive requirements for LCs involved in capital markets, IPOs, sponsorship, corporate finance advisory, underwriting, legal/compliance, and cross border fundraising. Hong Kong and Malaysia eligibility, prospectus/disclosure, and core shareholder-protection standards still apply. [End of ComplianceOne Newsletter – September 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

The topics discussed in this monthly newsletter for insurance are as follows: ComplianceOne Insurance Newsletter – January 2026 The topics discussed in this monthly newsletter are as follows: Market News HKFI Reports Interest from Insurers in Re-domiciling to Hong Kong IA Reports High Claims Settlement Progress for Wang Fuk Court Fire Incident (宏福苑火災) with 85% of Claims Processed IA Hosts Panel Discussion on Marine Insurance Opportunities as Hong Kong Strengthens Its Maritime Hub Status IA Statistics Show 32.5% Growth in Total Gross Premiums in first three quarters of 2025 Enforcement News Hong Kong Police Arrest Four Suspects in Connection with 22 Suspected Staged Traffic Accidents Involving Insurance Fraud Market News 1. HKFI Reports Interest from Insurers in Re-domiciling to Hong Kong On 15 January 2026, the Hong Kong Federation of Insurers (“ HKFI ”) indicated that around three insurance companies, primarily those registered in Bermuda, have expressed interest in re-domiciling to Hong Kong under the company re-domiciliation regime introduced in May 2025. This follows successful precedents set by major insurers. The legislation for implementation of company re-domiciliation regime, passaged on 14 May 2025, and gazetted on 23 May 2025 (See Companies (Amendment (No.2) Bill 2024 – Progress of the bill ) Manulife International Life Insurance (Hong Kong) Completed its re-domiciliation from Bermuda to Hong Kong in December 2025, becoming the first insurer to do so. Notice of Re-domiciliation Completion - Manulife AXA China Region Insurance Company (Bermuda) Limited Announced its successful re-domiciliation to Hong Kong on 26 January 2026, effective immediately, and was renamed AXA China Region Insurance Company (Hong Kong) Limited (安盛金融保險（香港）有限公司). The process aligned with the regime, reinforcing AXA's long-term commitment to the Greater China region. AXA plans to update its Macau branch name in the week starting 2 February 2026. Notice of Re-domiciliation Completion - AXA SIGNIFICANCE: The re-domiciliation benefits include streamlined regulatory compliance (e.g., avoiding dual Bermuda and Hong Kong requirements), simplified financial reporting, and enhanced alignment with Hong Kong's stable regulatory environment. The growing interest from approximately three additional insurers, combined with completed re-domiciliations by Manulife and AXA, demonstrates Hong Kong's increasing attractiveness as a domicile for international insurance groups amid global economic shifts. 2. IA Reports High Claims Settlement Progress for Wang Fuk Court Fire Incident (宏福苑火災) with 85% of Claims Processed On 3 February 2026, the Insurance Authority (“ IA ”) announced that around 85% of insurance claims arising from the fire at Wang Fuk Court have been successfully settled. The IA has been actively coordinating with insurers and monitoring the claims handling process since the incident to support affected policyholders. Key statistics: Total claims processed 1,032 (representing 85% of all claims), involving nearly HK$510 million in settlements. General insurance claims 1,030 total claims; 863 settled (84%), amounting to approximately HK$450 million. Long-term insurance claims 188 total claims; 169 settled (90%), amounting to approximately HK$60 million. The remaining unsettled claims primarily require on-site inspections and detailed damage assessments. The IA continues to follow up closely with the Hong Kong Federation of Insurers to ensure fair and efficient resolution in line with the principle of treating customers fairly. Mr Clement Cheung, Chief Executive Officer of the IA, stated: “The IA is aware that a majority of claims have been successfully settled based on the principle of treating customers fairly, and the remaining claims call for on-site inspections and damage assessments. We will continue to follow up actively with the Hong Kong Federation of Insurers.” 3. IA Hosts Panel Discussion on Marine Insurance Opportunities as Hong Kong Strengthens Its Maritime Hub Status On 26 January 2026, the IA organized a panel discussion at the Asian Financial Forum (“ AFF ”) titled "Charting Future Seas: Hong Kong's Maritime Development Opens New Blue Oceans for the Insurance Industry." The session, held during the AFF, explored how Hong Kong's development as an international maritime hub creates opportunities for marine insurance. The AFF serves as Asia's premier exchange platform, bringing together global leaders from government, finance, and business to discuss the global economy from an Asian perspective. The discussion was moderated by Mr. LIU Zhongjian, Executive Director (Policy and Legislation) of the IA. He emphasized that marine insurance is an indispensable element supporting Hong Kong's status as an international financial, shipping, and trading center. In the context of a complex and changing global trade landscape, Hong Kong's marine insurance sector needs to adopt a more strategic and forward-looking approach. Panel experts identified three key elements for promoting sustainable development in marine insurance: Cultivating talent to ensure a stable and continuous supply of professionals in marine risk management. Addressing technological innovations in shipping and digitalization of global supply chains to maintain competitiveness. Enhancing synergies among diverse services within Hong Kong's marine insurance ecosystem. For more details on the AFF agenda and the IA's panel are available on the Asian Financial Forum website . SIGNIFICANCE: This panel underscores the IA's proactive role in positioning Hong Kong as a leading maritime and marine insurance hub amid evolving global trade dynamics. By focusing on talent, technology, and ecosystem collaboration, the initiative aims to unlock new growth avenues for the insurance industry, enhance risk management capabilities in shipping and trade, and align with national strategic priorities. It reflects Hong Kong's commitment to diversifying its financial services beyond traditional sectors and capitalizing on its strategic location to attract international marine insurance business. 4. IA Statistics Show 32.5% Growth in Total Gross Premiums in first three quarters of 2025 On 23 January 2026, the IA published the provisional statistics for the first three quarters of 2025 (January to September 2025). The data reflects robust performance across both long-term and general insurance sectors, with total gross premiums reaching HK$6,370 billion, representing a significant year-on-year increase of 32.5%. Long Term Business (excluding retirement scheme business) : New office premiums surged 55.9% to HK$2,645 billion, driven primarily by non-linked individual business at HK$2,515 billion (up 55.2%). Within this, participating business rose 60.1% to HK$2,263 billion. Linked individual business increased 75.7% to HK$127 billion. Approximately 50,000 qualifying deferred annuity policies were issued, contributing HK$32 billion (1.2% of individual business total). In-force long-term business revenue premiums totaled HK$5,541 billion (up 36.6%), with claims and benefits paid amounting to HK$2,794 billion (up 3.4%). Total long-term assets grew to HK$52,841 billion, with net assets at HK$7,317 billion. General Business : Gross premiums reached HK$829 billion (up 10.5%), net premiums HK$560 billion (up 8.3%). Claims paid totaled HK$380 billion (down 0.9%). Overall operating profit stood at HK$101 billion (up 50.5%), supported by underwriting profit of HK$35 billion (up 63%). Direct business and reinsurance segments both showed positive growth and profitability trends. For more details, please refer to the summary of the provisional statistics is at Annex . SIGNIFICANCE: These provisional figures demonstrate the resilience and strong momentum of Hong Kong's insurance sector in 2025, with substantial growth in new business premiums and overall premiums. The performance highlights increasing demand for protection-oriented and participating products, reinforcing Hong Kong's position as a leading insurance hub in Asia. The data also provides valuable insights for insurers, intermediaries, and policyholders on market trends ahead of full-year 2025 results. Full details, including annex summaries, are available on the IA website. Enforcement News 5. Hong Kong Police Arrest Four Suspects in Connection with 22 Suspected Staged Traffic Accidents Involving Insurance Fraud Hong Kong Police have arrested four individuals (three men and one woman, aged 37 to 69) on suspicion of conspiracy to defraud related to 22 staged or falsified traffic accidents. The arrests occurred in early February 2026 as part of an investigation into a multi-year "crash-for-cash" insurance fraud operation. (Source: South China Morning Post) Key details of the Case Among the arrested are a married couple alleged to be central to the scheme, who reportedly posed variously as drivers, passengers, or pedestrians struck by private cars or taxis over a period of four to five years. Two local doctors were also detained in connection with the case, suspected of involvement in facilitating false claims. A taxi registered to the wife was impounded during the operation. All four suspects remain in custody while investigations continue. Police have linked these incidents to broader concerns over organized insurance fraud, including exaggerated or fabricated injury claims submitted to insurers for compensation payouts. The Stage Traffic Accidents Scheme in Hong Kong This development coincides with a recent surge in reported traffic-related scams, with over 100 suspected cases now under review (including referrals from the insurance industry and public reports). Some involve minor bumps, no collisions, or delayed high-value civil claims, often involving repeated claimants, shared law firms, or medical providers. Authorities, including the HKFI have warned drivers and insurers to remain vigilant and report suspicious patterns promptly. SIGNIFICANCE: Staged traffic accidents represent a persistent and evolving threat to Hong Kong’s insurance sector, contributing to inflated motor insurance claims, higher premiums for honest policyholders, and erosion of market trust. This recent crackdown demonstrates proactive law enforcement collaboration to disrupt organized syndicates, which often involve coordinated roles across drivers, medical professionals, and claimants. Insurers are encouraged to strengthen fraud detection through enhanced verification of claims (e.g., reviewing patterns in injury reports, late filings, or repeat participants), internal controls, and referral of suspicious cases to police. The arrests underscore the financial and reputational risks of such misconduct, reinforcing the need for robust anti-fraud measures amid rising "new-generation" variants of crash-for-cash schemes. [End of ComplianceOne Insurance Newsletter – January 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. 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近年中港兩地金融監管機構對證券期貨業的合規審查力度顯著升級，兩地均聚焦於「跨境管道風險」與「開戶源頭治理」，旨在遏制非法金融活動並防範系統性洗錢風險。 天匯合規：合規提示 《綜合整治非法跨境證券期貨基金經營活動實施方案》 及 《開立帳戶及與客戶維持關係時應採取的監控措施》 之影響分析 (2026年5月) 免責聲明: 本文件內所載的內容及建議，純屬本公司內部意見及指引，僅供內部參考及評估之用。 本文件並不構成專業或正式的法律意見。本公司不會就本文件之內容承擔任何法律責任。持牌法團在參考或使用本文件時，應根據自身情況及最新監管要求作出獨立判斷，並建議在有需要時尋求合資格律師或專業顧問的獨立法律意見。 本公司保留隨時修改或更新本文件的權利，恕不另行通知。 目錄 I. 背景及概要 II. 《通函》 及 《整治方案》 的摘要 III. 《通函》下處理內地個人投資者帳戶之要求及注意事項 IV. 《通函》之影響分析 V. 《整治方案》下之行動建議 VI. 總結 VII. 我們如何提供協助 I. 背景及概要 近年中港兩地金融監管機構對證券期貨業的合規審查力度顯著升級，兩地均聚焦於「跨境管道風險」與「開戶源頭治理」，旨在遏制非法金融活動並防範系統性洗錢風險。中港兩地金融監管機構共同在2026年5月22日發佈重大監管措施，向市場投下震撼彈。 在香港市場方面，香港證監會於檢視12家證券經紀行的開戶作業手法後發出 《開立帳戶及與客戶維持關係時應採取的監控措施》通函 (“ 通函 ”)。結果顯示部分持牌法團在盡職審查及持續監察上存在重大缺失，包括在 開戶流程中接受可疑或偽造文件 ，以及 未有對與海外中介人的跨境代理關係作出有效管理 。另外，由於在檢視中識別出的可疑或偽造文件大多涉及內地投資者 [1] ，因此香港證監會在通函中亦列載了在 開立及管理內地投資者的投資帳戶時所須採取的額外措施 。同時，香港金管局亦有發 通知 予香港銀行提示業界需留意上述通函並按相同標準加強對內地投資者的監控及審批等。 在中國內地市場方面，在總結2022年底對中國境外機構的跨境整頓經驗後，中國證監會（“ 中證監 ”）在同日亦發佈了 《綜合整治非法跨境證券期貨基金經營活動實施方案》 (“ 整治方案 ”)。此舉旨在根除中國境外機構未經批准、擅自或利用中國境內關聯或合作主體在中國境內招攬客戶，並通過網站、應用程式 (“ APP ”) 向中國境內投資者非法提供中國境外證券開戶及交易服務等的行為。有鑑於此，整治方案強調全鏈條治理，亦旨在於兩年整治期中全面清理非法存量業務，將違規經營活動逐出中國內地市場。 兩地監管在同一天發布重大監管措施並非偶然。香港證監會在其通函中明確提及中國證監會的整治方案，要求持牌法團在向香港境外投資者提供服務時，必須同時遵守香港及適用司法管轄區（即中國）的所有相關法律及監管規定，並且不得從事或協助任何非法活動。某程度上，這反映兩地監管的緊密合作。 [1] 內地投資者 - 指根據持牌法團的紀錄或在開立投資帳戶時，使用中華人民共和國簽發的居民身份證及／或護照作為身分證明文件的個人投資者。 II . 《通函》 及 《整治方案》 的摘要 A. 《通函》下持牌法團的監管要求摘要 完善開戶文件及帳戶審查程序 a) 如收到香港證監會的要求，需外聘顧問在三個月內按照香港證監會訂明的範圍及方法進行開戶核查 (“ 開戶核查 ”)； b) 就算沒有收到香港證監會的要求，也應盡快進行內部核查，以偵測是否曾接納可疑或偽造文件開戶。就所識別出的客戶，應發出事先書面通知，告知將暫停任何新交易及計劃在六個月內關閉有關帳戶； c) 應禁止已識別的客戶日後在持牌法團或其關聯公司開立投資帳戶；及 d) 開戶時應向潛在客戶說明提交偽造文件的嚴重後果，並由管理層對開戶文件進行審核後才可批准開戶。 關閉零結餘不動投資帳戶 a) 如收到香港證監會的要求，需在三個月內識別所有零結餘不動投資帳戶 (“ 不動戶核查 ”)； b) 就已識別的帳戶，應通知客戶需要確認KYC 及 CDD的資料仍然反映現況及相關，以及完成第3b點中提及的銀行帳戶措施，否則將暫停為其展開任何新交易，以及會在六個月內關閉有關帳戶；及 c) 如已識別的帳戶同時亦屬使用可疑或偽造文件開戶的帳戶，則應發出事先書面通知，告知將暫停任何新交易及計劃在六個月內關閉有關帳戶，以及禁止該客戶日後在持牌法團或其關聯公司開立投資帳戶。 內地投資者開立投資帳戶之額外措施 ( 僅限個人客戶，公司或機構客戶不適用 ) a) 需取得客戶的書面聲明，確認以下各項： 所有用以支持投資活動及相關結算的資金均來自 內地以外 的合法來源； 沒有因曾使用可疑或偽造文件而令帳戶遭到任何持牌法團或銀行關閉或暫停； 承諾如其書面聲明中的資料出現任何更改，會在七個營業日內通知持牌法團；及 明白持牌法團可能會按執法機構或監管機構的要求，披露該投資者的個人及其他相關資料； b) 要求該客戶使用以其名義在香港持牌銀行或在合資格司法管轄區的銀行持有的銀行帳戶，作結算及提存之用；及 c) 若其後發現該客戶的資金來源屬不合法，或違反內地任何資本管制法規，應發出事先書面通知，告知將暫停任何新交易及計劃在六個月內關閉有關帳戶，以及禁止該客戶日後在持牌法團或其關聯公司開立投資帳戶。 完善收集客戶識別資訊及客戶住址的程序 a) 需遵守從身分證明文件收集個人客戶識別資訊的排序表規定，即身分證明文件的優先次序應為香港身份證，國民身分證明文件及護照； b) 在接納客戶提供的身分證明文件前，應採取合理步驟，如向客戶取得陳述及保證，以確認客戶沒有持有次序較高的身分證明文件；及 c) 應審查客戶地址是否存在異常情況，例如多個明顯無關連的客戶使用同一住址等。 完善海外中介人跨境代理關係 [1] 之盡職審查及持續監察 a) 在與海外中介人建立跨境代理關係前，應瞭解中介人的性質、聲譽、牌照或註冊狀況及所受到的監管，其相關客戶的類別，以及預期的交易性質、交易量及交易額； b) 應按照在開戶盡職審查時獲得有關海外中介人的資訊定期進行持續監察，以識別預警跡象； c) 應採取額外措施，如要求海外中介人提供交易的相關資料，以減低潛在洗錢風險；及 d) 如洗錢風險無法被充分減低，應避免與該海外中介人建立關係。 B. 中國證監會的《整治方案》摘要 禁止中國境外機構未經國務院證劵監督管理機構批准下，擅自在中國境內或跟境內協助方合作開展證劵期貨基金業務相關的營銷招攬活動 [2] 及 提供相關開戶、處理交易指令、資金劃轉等交易服務 [3] ； 對整治對象作出嚴懲及巨額罰款，並在為期2年的集中整治期內，禁止作為整治對象的中國境外機構為存量投資者在中國境內提供買入交易、轉入資金等服務，僅允許單向賣出並轉出資金的交易。集中整治期滿後，在確保客戶財產安全及落實其帳戶處置安排的前提下，中國境外機構必須關閉中國境內網站、交易軟件及配套服務器，並停止為存量投資者在中國境內進行任何交易；及 禁止中國境內相關主體協助未經批准的中國境外機構開展營銷活動或提供交易服務，以及為其提供網站、交易軟件開發運營、客戶服務、經營網絡平台及自媒體等支持服務。 匯轉帳環節的客戶身份盡職調查及交易資訊保存職責，加大非法走資違規行為的查處力度以加強打壓非法走資。 [1] 海外仲介人跨境代理關係 － 指透過海外中介人（不論是否有聯屬關係）向投資者提供證券交易（包括首次公開招股認購）、期貨合約交易或槓桿式外匯交易服務，即構成跨境代理關係。 [2] 營銷招攬活動 － 指包括在中國境內營運網站及交易軟件、發布營銷資訊、推送投資資訊、開展返利營銷活動及宣傳推介和誘導認購境外股票等 [3] 開戶、處理交易指令、資金劃轉等交易服務 － 指包括在中國境內通過網站、交易軟件及配套服務器等跨境接收和傳輸開戶申請及交易指令等。 III . 《通函》下處理內地個人投資者帳戶之要求及注意事項 帳戶類別 監管要求 注意事項 新開立之內地投資者帳戶 硬性規定： 取得客戶的書面聲明 綁定指定香港／合資格司法管轄區的海外銀行 建議執行： 檢查內地投資者的資金來源合法性 (例如是否有合法的境外收入來源，如工作或業務收入等) 用面對面方式為內地投資者進行開戶時，應要求內地投資者提供香港入境小票，以證明其入境紀錄 現有內地投資者帳戶 (含零結餘不動投資帳戶) 硬性規定： 如收到香港證監會的要求，應進行開戶核查 (檢查開戶文件之真偽) 及不動戶核查 (識別零結餘不動投資帳戶) 對核查中識別出來的帳戶，根據本文第2章 - 《通函》中第1點 及 第2點處理 就不動戶需要重啟的情況，必須取得客戶的書面聲明 及綁定指定香港／合資格司法管轄區的海外銀行 建議執行 ： 就算未有收到香港證監會的要求，也應在切實可行的情況下進行開戶核查及不動戶核查 對識別出來的帳戶，按上段方式處理 就需要重啟的帳戶，檢查內地投資者的資金來源合法性 對其他非內地投資者帳戶也應每年進行一次不動戶核查，及在通知客戶後決定是否重啟或關閉帳戶 如屬中證監的整治對像，那必須有序地清除存量內地客戶 IV. 《通函》之影響分析 監管要求 目的 影響 完善開戶文件及帳戶審查程序 打擊內地投資者使用偽造文件開戶 合規成本攀升： 持牌法團需要花額外行政成本、技術成本及人力成本加強檢查及進行"回溯式"審核等。 關閉零結餘不動投資帳戶 打擊洗錢活動，大部分呈現分層交易活動模式的帳戶通常在資金被悉數提取後會一直閒置。此外，部分該等帳戶被發現由提供偽造文件開戶的內地投資者所持有 內地投資者開立投資帳戶之額外措施 加強壓制及打擊內地投資者非法走資 內地客源進一步收縮，影響業務收入： 雖未有明文禁止香港銀行或持牌法團為內地客戶提供服務，但香港銀行及持牌法團仍需加強對內地投資者之帳戶審批及檢查內地投資者資金來源之合法性，因此內地投資者於香港開立金融帳戶變得更困難。依賴內地客源的持牌法團需積極考慮開拓其他客源或合法渠道。 完善海外中介人跨境代理關係之盡職審查及持續監察 打擊與新西蘭或越南等海外持牌券商合作的香港持牌法團透過跨境代理關係降低開戶門檻及洗錢監控，藉此為內地投資者開立虛假帳戶參與香港IPO市場及接受虛擬貨幣出入金。 需跟不達標的海外券商IPO業務合作需終止： 香港券商需對海外券商進行更嚴格的盡職調查並審慎考慮跟不達標準的海外中介人終止合作關係，否則將面臨監管判罰。 V . 《整治方案》下之行動建議 任何跟中國境內中介機構甚至個人合作之持牌法團都建議立即檢示是否有進行以下行為，因其可能構成在境內非法招攬或提供金融投資服務予內地投資者，隨時會收到中證監的通知並成為整治對象及施加罰款。 檢查事項 潛在風險 行動 是否有內地網站，於內地平台經營社交媒體／網誌或平台等（例如：小紅書，抖音，微博，微信公開朋友圈），及有於內地平台上架交易軟件及APP等。 就算內容上未有指明目標客戶是內地投資者，只要屬內地平台，仍可被視為有意圖非法招攬內地投資者。 建議在審慎評估內地法規風險後，盡快下架有關網站，社交媒體／網誌或平台以及軟件或APP等。 是否有跟任何內地中介合作以提供行銷招攬，運營網站及交易軟體／平台等。 被視為非法招攬內地投資者，提供金融服務等。 即時終止所有合作關係。 是否設有或跟境內中介合作設置境內聯繫或服務點等，以提供境外金融服務查詢或聯繫。 被視為有非法招攬內地投資者，提供金融服務等。 即時終止所有境內聯繫或服務點。 前線員工是否有經營個人內地社交媒體／網誌或平台以推薦金融服務或產品等，甚至私下跟內地中介機構及個人有合作轉介內地投資者等。 如持牌法團未有合適的監控措施，仍可能需負上連帶責任。 即時提供相關培訓，在員工守則上明確禁止此等行為及要求員工簽署聲明。 如有跨境業務活動需求，建議檢視或更新內部跨境業務活動指引／措施以說明員工在中國境內可進行之業務活動。 只要在境內未有相關牌照或許可的情況下推薦或介紹境外金融服務或投資產品等，即可構成在境內非法開展證券期貨基金業務相關行銷招攬活動。 透過培訓及指引確保員工知悉在中國境內出差時的注意事項。如對中國境內可進行之活動／行為有任何疑問，建議可進一步咨詢內地專業法律意見。 VI. 總結 中國監管的整治方案對外方面：透過重拳處罰、殺雞儆猴，形成寒蟬效應，令香港持牌法團不敢貿然以非法方式招攬內地投資者。對內方面：進一步加強外匯管制監控，打壓境內投資者違法走資行為。上述舉措亦無疑為香港金融市場的發展蒙上陰霾，因內地資金實為香港金融市場的重要一環。 綜合兩地監管「雙管齊下」，我們認為對香港持牌法團的核心影響可歸納為四個層面： 合規成本攀升： 內部核查、帳戶關閉、開戶標準提升等要求帶來顯著的合規成本增加； 內地客源收縮： 內地客戶開戶門檻提高； 業務轉型壓力： 依賴非法內地資金或客源的商業模式面臨根本性調整； 內地法規、監管執法風險上升： 內地監管對於境外金融機構在境內重大違規持「零容忍」態度並可施加嚴懲，持牌法團及其高級管理層所面臨合規責任及風險加重。 在此監管新格局下，香港持牌法團須即時實踐對內地投資者的新監管措施並密切關注市場反應以調整業務策略及開拓新渠道等，在確保業務經營的合規性與可持續性下繼續支持香港金融市場的發展。 VII. 我們如何提供協助 我們的團隊由經驗豐富的專業人士組成，在合規、風險管理，以及政策審閱與制定方面擁有深厚的專業知識，能精準識別通函中的監管預期與貴司現行政策及程式之間的差距。我們深諳監管要求的複雜性，並能提供量身定制的解決方案及分析等，以滿足貴司的特定需求並填補任何重大缺陷。我們的專業知識可確保貴司遵守監管標準，並全面提升合規實踐水準。 如有任何疑問，歡迎隨時與我們的合規支援團隊聯繫。 [完結 - 天匯合規：合規提示 |《綜合整治非法跨境證券期貨基金經營活動實施方案》及《開立帳戶及與客戶維持關係時應採取的監控措施》 之影響分析 - (2026年5月)] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The article is for general information purpose only and is not intended to constitute legal or other professional advice. 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ComplianceOne Consulting Limited (ComplianceOne) is very proud to announce that our client, KUAIPAY HK LIMITED, successfully obtained the Money Service Operator License (MSO License) issued by the Hong Kong Customs and Excise Department in August 2026! Success Case Sharing | ComplianceOne Assists "KUAIPAY HK" in Successfully Obtaining Hong Kong Money Service Operator (MSO) License!(2026.08) [Good News] Warm Congratulations to KUAIPAY HK LIMITED on Successfully Obtaining the Hong Kong MSO License! ComplianceOne Consulting Limited (ComplianceOne) is very proud to announce that our client, KUAIPAY HK LIMITED, successfully obtained the Money Service Operator License (MSO License) issued by the Hong Kong Customs and Excise Department in August 2026! This license application took 14 months (June 2025 to August 2026). Under the full guidance and support of ComplianceOne's professional team, KUAIPAY HK successfully passed the stringent compliance review and evaluation by Customs, embarking on a new milestone in global cross-border payments and fintech development! Client Background & Strong Mainland Licensed Qualifications Strong Alliance & Strategic Synergy: KUAIPAY HK LIMITED established a local office in Hong Kong, dedicated to providing high-quality, safe, and convenient cross-border payment and currency exchange services to global individual and corporate clients. Backing of Top-Tier Mainland Payment License: KUAIPAY HK has achieved strategic synergy with leading Chinese mainland e-payment enterprise—99Bill Corporation ("99Bill"). Established in 2004, 99Bill is among the first batch of renowned payment enterprises to receive the Payment Business License (License No.: Z2000831000014) issued by the People's Bank of China. It possesses comprehensive service qualifications including internet payments, mobile phone payments, and nationwide bank card acquiring services, cumulatively serving over 400 million individual users and 6.5 million business partners. Relying on strong industrial synergy and compliance capabilities, KUAIPAY HK will continue to expand into global markets such as Southeast Asia, Europe, and the Americas. Hong Kong MSO Industry Trends & Compliance Challenges Since 2019, the Hong Kong Customs and Excise Department has significantly tightened regulation and oversight of Money Service Operators (MSOs): Sharp 70% Drop in Licensed Entities: The number of local licensed institutions has dropped sharply from over 2,500 in early 2020 to just over 600 today. Technology-Driven Transformation: Most institutions failed to renew their licenses primarily due to loopholes in Anti-Money Laundering (AML) policies, insufficient staffing, and a lack of compliance tools. At the same time, the industry is accelerating its transformation from traditional models into tech-driven, standardized international cross-border payment operations. ComplianceOne's Comprehensive Advisory Services As a professional consulting team holding the highest market share in Hong Kong and having cumulatively handled over 200 MSO license applications and renewals, ComplianceOne provided KUAIPAY HK with end-to-end professional services, including: One-Stop MSO License Application Consultancy: Providing pre-compliance advice regarding senior management "Fit and Proper Person" criteria, business processes, and operating premises regulations. Carefully reviewing and drafting the Business Plan and Anti-Money Laundering and Counter-Financing of Terrorism Policy (AML/CFT Policy) according to the latest Customs guidelines. Submitting applications to Customs on behalf of the client, assisting with site visits, and following up on Customs inquiries throughout the entire process until approval. Pre-Meeting Training with Customs & Competence Assessment Mock Exam Questions: Offering an exclusively developed 7-module Competence Assessment mock question bank to help clients deeply master regulatory requirements. Providing training prior to Customs interviews and breaking down "Frequently Asked Questions" to ensure interview performance aligns with regulatory expectations. Dedicated AML/CFT Compliance Training: Providing KUAIPAY HK and its staff with no less than 2 hours of professional compliance training (covering due diligence, risk-based principles, suspicious transaction identification, etc.) and issuing certificates of completion. About ComplianceOne Relying on rich experience in the financial services industry, ComplianceOne has repeatedly earned praise from regulatory authorities and officers. Whether it is new MSO license applications, license renewals, AML training, or mock exam system support, ComplianceOne can safeguard your business development! If you have any MSO license or compliance consultation needs, please feel free to contact us at any time!

The topics discussed in this monthly newsletter for Licensed Corporations are as follows: ComplianceOne Newsletter – January 2026 The topics discussed in this monthly newsletter are as follows: Regulatory Updates SFC and HKMA jointly consult on standard calculation periods under OTC derivative Clearing Rules SFC directs IPO sponsors to promptly conduct internal reviews to rectify serious deficiencies in the preparation of new listing documents Reminder of statutory obligations during SFC inspections to comply with section 180 of the Securities and Futures Ordinance Market News In Memory of David Webb – a corporate governance activist Forum of Speech SFC and UAE’s Capital Market Authority sign milestone MoU to strengthen cross-border digital asset collaboration Writing the Next Chapter for Hong Kong’s REIT Market- New speech by Alexandra Yeong on HK REITS Cross Agency Steering Group announces Strategic Priorities for 2026-2028 Enforcement News - Intermediaries SFC Reprimands and Fines Saxo Capital Markets HK Limited $4 Million for Failures in Distributing Unauthorised VA-Related Products SFC Suspends WONG Chi Fai for 27 Months and CHOI Sau Wai for 7 Months Over Undisclosed Personal Trading in Suspected Ramp-and-Dump Case Regulatory Updates 1. SFC and HKMA jointly consult on standard calculation periods under OTC derivative Clearing Rules The SFC and HKMA issued a joint consultation on standardizing the calculation periods for each year under the Clearing Rules for over-the-counter (“ OTC ”) derivative regulatory regime. Current Approach to accommodate additional Calculation Periods Since 2016, implementation of the mandatory clearing introduced four Calculation Periods (“ CPD ”) within the Clearing Rules at consistent six-month intervals with aims to: ensure timely identification of new dealers entering the OTC derivative market, or any prescribed persons (e.g. a licensed corporation under the SFC) which have met the Clearing Threshold; mitigate the risk of market participants manipulating their positions during the specific CPDs to avoid clearing obligation; following the consultations in 2018 and 2021, sixteen additional CPDs were incorporated in the Schedule 2. Proposed Approach to accommodate additional Calculation Periods beyond 2026 In assessing the need to adjust the three key elements related to CPDs, namely, (i) the three-month duration, (ii) the frequency of CPDs per calendar year, and (iii) the Prescribed Day (which occurs seven months after the end of each CPD); it is indicated in the observations that two CPDs per calendar year with three-month duration prove to be effective; while maintaining the Clearing Thresholds at USD20 billion. A Summary of the Proposed Approach to the Schedule 2 of the Clearing Rule Calculation Period Clearing Threshold Prescribed Day From 1 March 2027 onwards, 1 March to 31 May in a year USD20 billion 1 January in the following year From 1 March 2027 onwards, 1 September to 30 November in a year USD20 billion 1 July in the following year SIGNIFICANCE: This formulaic approach would provides prescribed persons with certainty that future Calculation Periods can be determined based on the established methodology, without reliance on adding new calculation periods to Schedule 2 to the Clearing Rules from time to time; and will not incur any operational changes the prescribed person have to comply relating to Clearing Rules. 2. SFC directs IPO sponsors to promptly conduct internal reviews to rectify serious deficiencies in the preparation of new listing documents The SFC set forth a circular highlighting the issues related to deficiencies in the preparation of listing documents, potential misconduct and significant mismanagement of resources of over-engagement in new listing applications. Some key takeaways of the deficiencies found: in reviewing recent listing applications, the SFC and SEHK found that some sponsors did not have a thorough understanding of their listing applicants, implying due diligence works on the applicants were not sufficient; strained resources status of the sponsors with over-reliance on external professional parties, while the sponsor principals are not capable of supervising their transaction teams, and the staff team involved is not equipped with requisite knowledge, and experience in IPOs arrangement; In the light of the findings, the SFC and SEHK have come up with the following rectification measures: joint letters were sent to 13 sponsors, requiring them to complete comprehensive reviews within three months on the deficiencies identified as well as the resources status to discharge their sponsor work; requiring all sponsors to submit the followings: - within two weeks, the names and number of appointed Principals and the number of active listing engagements; in order to ensure if the sponsors have adequate resources to carry out the duties; - within one week, a list of individuals engaged in IPO sponsor work and also those who have not yet passed the HKSI LE Paper 16 within three years or within six months after their first engagement in such work; onsite thematic inspections are expected on those concerned principals and sponsors; sponsors providing materially incomplete or unsatisfactory responses to the regulators, the vetting process may be suspended; engaged individuals who do not meet the eligibility criteria are now subject to tightened examination requirements; SIGNIFICANCE: The deficiencies findings reveal the facts that licensed corporations are thinning out their resources and straining personnel competence for undertaking business which they are not so well-acquainted or financial capable to handle. In the eyes of the regulators, as Ms. Julia Leung has said, “ The gatekeeping role of sponsors in the listing process is critical to maintaining the quality of Hong Kong’s capital market and sustaining investor confidence in new listings that will hold up through all market cycles. That role may have been eroded in their eager pursuit of deal volume . ” 3. Reminder of statutory obligations during SFC inspections to comply with section 180 of the Securities and Futures Ordinance The SFC found in its routine inspections that some licensed corporations (“ LC ”) engaged in unsatisfactory practices and behaviours which appeared to stem from a misunderstanding of the SFO or a lack of awareness regarding the LCs’ statutory obligations. According to the section 180 of the SFO “ Supervision of intermediaries and their associated entities”, it empowers the SFC to supervise licensed intermediaries and their associated entities by entering premises, inspecting records, and making inquiries to ensure compliance with financial and conduct requirements like onsite inspections. What are the malpractices of the findings by SFC? obstructing inspection arrangements: e.g. intending to postpone and delay; disputing the inspection without good reason: arguing over the areas and scope of samples evading responses: delaying in responses and providing misleading information; submitting false/distorted information: providing information which is ambiguous, inaccurate; actively disrupting the inspection process: intentionally disrupting the inspection process; unprofessional conduct toward inspectors: adopting an uncooperative attitude to take the inquiries seriously. Expected Standards & Statutory Obligations of LCs toward the SFC access to information & answers: LC should provide access to records / documents as required under section 180 of the SFO; maintenance & retrieval of records: maintain proper business records at all times for ready retrieval to SFC as required under Securities and Futures (Keeping of Records) Rules; availability of Responsible Officers (ROs): ensuring two ROs for each regulated activities and their availability during SFC visits; fitness & properness of LCs: adhering to the General Principles stated in the Code of Conduct for licensed persons; engagement of external representative: the LCs should realize their ultimate accountability and responsibilities to SFC for any information provided by outsourced external representatives on their behalf. Consequence of failure to cooperate or non-compliance The SFC takes any breaches of section 180 of the SFO seriously, and will not hesitate to exercise its powers under the SFO to take appropriate regulatory actions, such as: Supervisory interventions, which may include, but not limited to: imposing conditions on the LC to limit its business of regulated activities, e.g. no onboarding of new clients; fully evaluating the fitness and properness of the LC and its management personnel Enforcement actions, which may include, but not limited to: initiating criminal proceedings for contravention of the stipulated requirements; taking appropriate disciplinary actions; SIGNIFICANCE: As a licensed corporation, together with its licensed persons like Responsible Officers, licensed representatives, should bear in mind and get acquainted with not only the codes and guidelines which governing their behaviours to certain expected standards, a cooperative attitude in collaboration with the SFC upon any requests or inquiries should be ascertained to express their competence and fitness to remain licensed. Market News 4. In Memory of David Webb – a corporate governance activist David Webb was a renowned Hong Kong-based corporate governance activist, and an investor, who contributed his long-devoted efforts in advocating transparency in the stocks market, with his valuable research work and findings. David’s Key Roles and Contributions As an activist investor and market watchdog: the most well-known contribution was his publication of a list of " 50 Hong Kong stocks not to own " on 15 May 2026, within which he highlighted some bubble stocks subject to SFC concentration risk warnings, and aroused alerts to investors to stay away from these troubled stocks. His devoted efforts to advocate for greater transparency and improved corporate/economic governance; always known as one of Hong Kong's most vocal activist investors, and his investigations into corporate misconducts triggered regulatory concerns. He always stood out with brave to safeguard the interests of retail investors at large against non-performing managements of the listed stocks. As Founder of Webb-site.com : David moved to Hong Kong in 1991 as an investment banker, taking advantage of his professional insights, he founded the Webb-site.com w hich was a free online platform providing stock market news, data, and analyses for market participants. Appraises to this data base is considered as “second to none”! Later Years and Legacy Diagnosed with metastatic prostate cancer in 2020, David scaled down his research work. He passed away peacefully on January 13, 2026, at age 60 in Hong Kong, survived by his wife and two children. And in February 2026, the closure of Webb-site.com was announced and public release of its database, putting an end to David’s legend. RIP: David's enduring impact lies in his fearless market oversight through Webb-site.com , persistence in upholding the transparency in Hong Kong's financial markets; and most praised for his endeavour to speak for the retail investors! Forum of Speech 5. SFC and UAE’s Capital Market Authority sign milestone MoU to strengthen cross-border digital asset collaboration The SFC has entered into a landmark Memorandum of Understanding ( MoU ), with and the Capital Market Authority (“ CMA ”) of the United Arab Emirates ( UAE ), earmarking a further commitment to promoting international cooperation under its ASPIRes Roadmap . Key takeaways of the comments on the MOU from senior executives in the forum an unprecedented collaboration with overseas regulator with mutual consultation, information exchange to enhance cross-border regulatory cooperation on digital asset-related matters; an industry roundtable on digital asset innovation between the SFC and the CMA senior executives from the digital asset industry to discuss on the digital asset ecosystem; upholding a shared objective to enable responsible innovation while upholding market integrity and strong investor protection; the MoU provides support for responsible financial innovation for HK and UAE in fostering sustainable growth of HK’s vibrant and secure digital asset ecosystem; SIGNIFICANCE: This MoU marks an emblem in transnational financial collaboration, positioning Hong Kong and the UAE as progressive, well-regulated digital asset hubs. It demonstrates a mutual commitment to responsible innovation, enhanced supervisory coordination, and the establishment of global standards that underscore transparency, integrity, and investor confidence in the digital asset ecosystem. 6. Writing the Next Chapter for Hong Kong’s REIT Market- New speech by Alexandra Yeong on HK REITS In as speech delivered in a luncheon by Ms. Alexandra Yeong, Interim Head, Investment Products, at the Hong Kong REITS Association (“ HKREITA ”) provides a comprehensive overview of the future trajectory of Hong Kong’s REIT market, and the roles of the regulator in navigating the development. Some key takeaways for the readers Enhancing market competitiveness and regulation a wide range of new measures have been launched to attract new REIT listings, enhance market liquidity, broaden investor base and facilitate secondary offering with an ultimate aim to fostering the growth of REIT market in HK, including: Grant scheme and stamp duty waiver (i) extend the grant scheme for REITs for three years to MAY 2027 (ii) to waive the stamp duty for the transfer of REIT units since DEC 2024 REIT Connect (i) REIT Connect is expected to significantly increase our REIT market liquidity and broaden investor base, and a number of local and overseas REIT issuers have already expressed interests in launching their REITs in Hong Kong upon the launch of REIT Connect. (ii) Rapid growth and diversification in the China Mainland REIT (“C‑REIT”) market, including an international-sponsored retail C‑REIT; this signified a key milestone in the internationalization and diversification of the C-REIT market and offered a model for greater offshore participation in the massive market. (iii)The SFC further assured that early implementation of this major initiative remains a top priority. New REIT Channel and streamlined measures (i) A dedicated “REIT Channel” be launched in October allowing new REIT applicants to consult the SFC confidentially on listing applications, (ii) The SFC has also streamlined its authorization process so that, under normal circumstances, new REIT applications can be approved within four weeks from take-up. (iii) For secondary offerings, documentary requirements have been streamlined so that documents focus on offer-specific information, without the need for any updated portfolio valuations or accountants’ reports on condition that ongoing disclosure and reporting requirements are already in place, thus shortening preparation time and enhancing time-to-market. Facilitating corporate activities and privatization (i) Following an October 2024 consultation, the proposal of the Government and SFC to introduce a statutory scheme of arrangement and compulsory acquisition mechanism for REITs; with an aim to facilitate Hong Kong REITs to expand through mergers and acquisitions and to conduct privatization and corporate restructuring in a clear and orderly manner, while strengthening investor protection. Strengthening global partnerships and international collaboration Beyond REIT Connect, the SFC has also been engaging with other international markets like Saudi Arabia to explore more potential collaboration opportunities, there were also bilateral meeting on exchanging views on dual listing of investment products such as ETFs and REITS. SIGNIFICANCE: As a concluding remark, Ms. Alexandra Yeong reinstated that “ the SFC will continue to work closely with the Government, industry participants and all stakeholders to foster the growth of the Hong Kong REIT market, and reinforce its position as a trusted platform for capital formation and long-term value creation. ” 7. Cross Agency Steering Group announces Strategic Priorities for 2026-2028 In the 12 th meeting in Jan 2026, the Green and Sustainable Finance Cross‑Agency Steering Group (“ Steering Group ”) set out its strategic priorities for 2026-2028 to further strengthen Hong Kong’s role as a competitive and future‑ready sustainable finance centre. Built on the solid foundation of the 2023-2025 plan, the Steering Group’s strategic priorities for the next three years are anchored around two key pillars : (1) Consolidate and strengthen efforts to solidify Hong Kong as a sustainable finance centre through: strengthening the sustainability disclosure ecosystem, and the effective use of technology; expanding and deepening sustainable finance markets; strengthening external engagement; supporting talent development with capacity building initiatives (2) Develop Hong Kong’s strengths in emerging areas scaling transition finance with practical guidance, using tools and reference to case studies; while encouraging wider industry adoption of transition planning; supporting adaptation finance by building market readiness, identifying capability gaps, and supporting product innovation and development, while strengthening physical risk assessment capabilities. SIGNIFICANCE: Comments from the CEO of SFC, Ms. Julia Leung, and Chief Executive of the HKMA, Mr. Eddie Yue highlighted the significance of these updated 2026-2028 priorities: l underscore the ongoing commitment to ensuring Hong Kong remains globally aligned, forward‑looking, and responsive to market needs. l reinforce the groundwork for building a robust sustainable finance ecosystem, while positioning Hong Kong to capture the emerging opportunities in Asia’s transition to a low-carbon and climate-resilient economy Enforcement News - Intermediaries 8. SFC Reprimands and Fines Saxo Capital Markets HK Limited $4 Million for Failures in Distributing Unauthorised VA-Related Products On 6 January 2026, the SFC reprimanded and fined Saxo Capital Markets HK Limited (CE: AVD061 ) (“ SCMHK ”) $4 million for significant regulatory breaches related to the distribution of virtual asset (“ VA ”) funds not authorised by the SFC and VA-related products (collectively “ VA Products ”) on its online trading platform (the “ Online Platform ”). SCMHK ceased carrying on regulated activities on 28 February 2025* Relevant Period and Key Breaches (1 November 2018 to 25 November 2022) : During this over four-year period, SCMHK permitted retail clients to trade 32 VA Products on the Online Platform, executing 1,446 transactions involving six individual professional investors (“ PIs ”) and 130 retail clients. All products were complex, including 21 exchange-traded derivative VA Products. These VA Products should only have been offered to PIs per the SFC's 2018 Circular (" Distribution of virtual asset funds ") and 2022 Joint Circular (" Joint circular on intermediaries’ virtual asset-related activities "). SCMHK failed to: Assess clients' knowledge of investing in VA Products; Provide sufficient VA-specific information and warning statements; Implement specific product due diligence procedures for VA Products (relying instead on deficient group-level protocols from its parent company that failed to identify VA exposure); Ensure adequate policies and controls to supervise the Online Platform and meet regulatory standards for VA Product distribution; Confirm suitability of complex VA Product transactions for clients; Provide sufficient details on the nature, features, and risks of VA Products, along with appropriate warnings; For 87 clients (82 retail and five individual PIs) trading the 21 exchange-traded derivative VA Products, conduct adequate enquiries or gather sufficient information to assess derivatives knowledge and characterise clients accordingly. For more details of the background, please refer to the Statement of Disciplinary Action . SIGNIFICANCE: In determining the sanction, the SFC considered mitigating factors, including the prolonged nature of the failures (over four years), SCMHK's self-reporting of misconduct, voluntary client compensation for losses from VA Product trading, cessation of regulated activities, full cooperation with the SFC (accepting findings and facilitating early resolution), and its otherwise clean disciplinary record. This action represents a landmark enforcement in Hong Kong's regulation of virtual assets, marking one of the first major fines against a licensed intermediary for breaches in VA Product distribution. It underscores the SFC's strict expectations for robust due diligence, suitability assessments, client knowledge checks, and platform supervision in handling complex and high-risk VA Products, particularly in online environments. Even with remediation and cooperation, the substantial fine highlights zero tolerance for prolonged failures that expose retail investors to unauthorised products, reinforcing the need for intermediaries to align controls with evolving SFC guidance on virtual assets to protect investors and maintain market integrity. 9. SFC Suspends WONG Chi Fai for 27 Months and CHOI Sau Wai for 7 Months Over Undisclosed Personal Trading in Suspected Ramp-and-Dump Case On 26 January 2026, the SFC announced disciplinary actions against two licensed representatives involved in serious breaches related to undisclosed personal securities trading. The cases are interconnected, arising from an SFC investigation into a suspected Ramp-And-Dump Scheme (唱高散貨). Participants of the Case Mr WONG Chi Fai (Principal Offender) Mr WONG Chi Fai (" WONG "), a former licensed representative for Type 1 and Type 2 regulated activities, suspended for 27 months from 23 January 2026 to 22 April 2028. WONG’s actions circumvented staff dealing policies, prevented effective monitoring of frequent day trading and short-term margin trading, and demonstrated wilful and dishonest conduct. Ms CHOI Sau Wai (Facilitator) Ms CHOI Sau Wai (" CHOI "), a former licensed representative for Type 1 and Type 2 regulated activities, suspended for seven months from 23 January 2026 to 22 August 2026. CHOI’s conduct exposed the client to risks from WONG’s personal trading, exposed GSSL to potential liability if the client disputed the trades, and hindered the firm’s compliance obligations. Key Breaches Name Timeline Key Breach Remarks WONG Chi Fai July 2019 to January 2022 At Fulbright Securities Limited and Fulbright Futures Limited : Conducted approximately 1,300 securities transactions worth $670 million in a securities account held in the name of his relative at Glory Sun Securities Limited (“ GSSL ”, formerly China Goldjoy Securities Limited), without disclosure or approval. Repeatedly falsely declared to Fulbright that he had no beneficial interest in external securities accounts. January 2015 to December 2018; with concealment from May 2011 At Open Securities Limited (OSL, formerly TC Concord Securities Limited): Executed approximately 10,000 personal trades worth $2.8 billion through another relative-held account without required approval, making false declarations to conceal his financial interest and control. CHOI Sau Wai October 2019 to January 2022 Knowingly allowed and facilitated WONG to operate and execute personal trades in a client’s securities account at GSSL without the client’s written authorisation or written consent from WONG’s employer (“ Fulbright ”). This enabled the 1,300 transactions worth $670 million over more than two years, breaching GSSL’s internal policies and the Code of Conduct for Persons Licensed by or Registered with the SFC. For more details of the background, please refer to the: Statement of Disciplinary Action - WONG Chi Fai ; and Statement of Disciplinary Action - CHOI Sau Wai . SIGNIFICANCE: These linked enforcement actions underscore the SFC’s strong commitment to addressing undisclosed personal trading and unauthorised account access, especially when such conduct may facilitate market manipulation schemes like ramp-and-dump. WONG’s multi-firm, long-term misconduct and CHOI’s knowing facilitation in a client account highlight critical lapses in staff dealing controls, disclosure obligations, and intermediary supervision. The differentiated suspension periods, longer for the primary actor and shorter for the facilitator, reflect a proportionate yet firm response, reinforcing that licensed persons must strictly comply with authorisation requirements, accurate declarations, and employer policies. This serves as a clear deterrent to dishonest behaviour that jeopardises client protection, firm compliance, and overall market integrity. [End of ComplianceOne Newsletter – January 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1104, 11/F, 299QRC, 287-299 Queen's Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

The topics discussed in this monthly newsletter for Licensed Corporations are as follows: ComplianceOne Newsletter – May 2026 The topics discussed in this monthly newsletter are as follows: Market News Hong Kong overtakes Switzerland as the World’s Top Offshore Wealth Centre Enforcement News SFC obtains disqualification orders against former directors of China Candy Holdings Limited SFC obtains two-year disqualification order against former financial controller and company secretary of Qunxing Paper Holdings Company Limited Movie producer Wong Pak Ming convicted of insider dealing in SFC’s prosecution SFC bans Nerico Brothers Limited’s former responsible officer, manager-in-charge and director Paul Wan Kai Leung for life over US$222 Million Client Asset Scandal SFC Raids Two more Chinese Brokerages in Widening IPO Probe Regulatory Updates SFC steps up measures to address forged documents, money laundering risks and account opening standards FTSB and SFC conclude consultations on Virtual asset advisory and management regimes SFC issues news guidance to help securities issuers prepare for upcoming uncertificated securities market regime Markets News 1. Hong Kong overtakes Switzerland as the World’s Top Offshore Wealth Centre For decades, Switzerland has been synonymous with offshore wealth and private banking, however this era has formally ended. According to the Boston Consulting Group (“ BCG ”)’s latest Global Wealth Report, Hong Kong has surpassed Switzerland in 2025 to become the world’s single largest destination for cross-border wealth. Assets booked in the city jumped 10.7% in the past year to a massive total reaching USD2.95 trillion. Switzerland comparatively had a 7.6% growth coming in at USD2.94 trillion. The drivers of this surge in growth can be attributed to the following events: a resurgent IPO market that returned Hong Kong to the top of global fundraising tables, a steady flood of capital from mainland China and market infrastructure reforms at the HKEX spanning equity financing, debt issuance and commodity trading. BCG’s analyst described Hong Kong’s rise as reflecting “the growing gravitational pull of Asian wealth and capital markets,” with cross-border flows becoming more concentrated in a smaller number of globally connected hubs.This momentum is expected to keep growing as denoted by BCG’s projection of annual cross-border wealth growth of approximately 9% for Hong Kong through 2030, suggesting the gap with competitors will widen rather than narrow. SIGN IFICAN CE: Wealth managers, private banks, external asset managers and financial institutions with regional ambitions this ranking is a commercial sign. The structural case for expanding cross-border wealth management operations in Hong Kong has arguably never been stronger. Firms that are watching cautiously from the sidelines should reconsider their capacity, product and positioning in the city before the next competitive cycle locks in market share. Enforcement News 2. SFC obtains disqualification orders against former directors of China Candy Holdings Limited When auditors flag discrepancies in company financial statements and management promises to fix them, independent directors cannot simply take those promises at face value. This was the central lesson delivered by the Court of First Instance this month, when it issued disqualification orders against four former directors of China Candy Holdings Limited (“ China Candy ”) (HK Stock Code: 8182 ), whose cash balances had been inflated by as much as 97% in its annual filings from 2016. The external control reviewers at China Candy identified problems in 2015 and 2016 regarding missing petty cash records, inconsistent management accounts and unresolved bank reconciliation gaps. The four directors, two executive chairpersons and two independent non-executives, confessed to passively relying on external professionals to identify and report potential red flags, which eventually led to the failure to properly scrutinise these issues and verify whether the proposed remedies had been implemented. As a result, their duties were abdicated by the court. Name Position P enalty Ms Yvonne HUNG (洪綺婉) Executive Director 33 months of disqualification Ms Li YUNA (李宇娜) Executive Director 24 months of disqualification Mr FANGUS Chu Wai Wa (朱偉華) Independent Director 12-month ban Mr ONG King Keung (王競強) Independent Director 12-month ban Following these sanctions the case is not over as the three alleged architects of the fraud, including the former chairman and CEO, are awaiting separate judgment following a hearing that concluded in March 2026. SIGNIFICANCE: Independent directors cannot outsource their oversight obligations to management or external advisers. When Internal control reviews surface issues, the senior management needs to track remediation to completion. Financial institutions should use this case to promptly review on how their senior management handle follow-through on audit and control findings 3. SFC obtains two-year disqualification order against former financial controller and company secretary of Qunxing Paper Holdings Company Limited This month, the SFC secured a two-year disqualification against Mr POON Tsz Hang, the former financial controller and company secretary of Qunxing Paper Holdings Company Limited (“ Qunxing ”), for disclosing false and misleading information regarding the annual turnover of Qunxing published in its financial statements from 2007 to 2011. Mr POON, the most senior finance office, held a unique vantage point from where the irregularities should have been visible. The SFC found that he failed to exercise basic oversight of the accounting and finance functions that reported to him. He also failed, in his company secretary role, to promptly escalate a critical restructuring event at a subsidiary that pointed to a sudden deterioration in the group’s finances. Furthermore, the company’s former chairman and his son were ordered by the Court back in 2018 to compensate investors, and HKD92 million was eventually distributed to approximately 27,000 eligible investors in 2023. Poon’s case represents the tail end of an enforcement effort that has now spanned nearly a decade. SIGNIFICANCE: Finance professionals in listed companies carry significant personal accountability. As the SFC has demonstrated it will pursue individuals’ years after misconduct occurs, CFOs and company secretaries should take note of the regulatory consequences of inadequate oversight and failure to escalate issues as they can lost beyond a company’s demise. 4. Movie producer Wong Pak Ming convicted of insider dealing in SFC’s prosecution Well-known film producer and chairman of Pegasus Entertainment Holdings, Mr WONG Pak Ming, was convicted for an insider dealing scandal this month following a 16-day criminal trial. Case Details In 2017, Mr WONG received serious, price-sensitive information about the sale of his controlling stake in the company, and within the same day received a HKD 10 million earnest payment from a prospective buyer. Immediately, upon receiving the earnest money, Wong transferred HKD 2 million to his sister, and advised her to buy over nine million Pegasus shares at prices well below Pegasus’ ensuing market price preceding the deal announcement. Based on the SFC’s calculations it was estimated that Wong’s sister earned more than HKD 1 million from these transactions. After a 16-day criminal trial at the Eastern Magistrate Court, Mr Wong was convicted of insider dealing whilst sentencing has been adjourned to June 9 th , 2026. The SFC commenced criminal proceedings against him in February 2025. Case Timeline Date 25 Aug 2017 25 Aug – 30 Aug 2017 25 Aug – 17 October 2017 25 October 2017 Event Mr. Wong received $10 million in earnest money. Transferred $2 million to his sister. Wong’s sister bought over nine million Pegasus shares below market price. Deal Announced SIGNIFICANCE: This case is a reminder that insider dealing does not require complex trading structures or anonymous offshore accounts. A simple word to family members backed by sensitive information is sufficient to constitute a serious criminal offence. Firms should ensure that information barriers are clearly communicated to senior individuals, and that personal trading policies explicitly address the prohibition on tipping family and friends. The SFC’s readiness to win criminal trials reinforces that consequences are not just regulatory, they are criminal. 5. SFC bans Nerico Brothers Limited’s former responsible officer, manager-in-charge and director Paul Wan Kai Leung for life over US$222 Million Client Asset Scandal The SFC has drawn a firm line under one of Hong Kong’s most egregious client asset scandals by permanently banning Mr Paul WAN Kai Leung, former responsible officer, manager-in-charge, and director of Nerico Brothers Limited (“ NBL ”) from the industry. Between mid-2020 and early 2021, NBL covertly used over USD 68 million of a single client’s funds for the firms gain, breaching the client agreement. The firm then went further, facilitating a fraudulent scheme misappropriating an additional USD 154 million of the same client’s money leading to a combined loss of more than USD 222 million. The orchestrator of this external scheme, Neo Ng Yu, had his firm’s license revoked and received a lifetime ban in separate proceedings. Furthermore, Mr WAN’s ban follows those already imposed on NBL’s director Jerff Lee Cheuk Fung and the connected principals of Amber Hill Capital in 2025. The SFC is systematically working through the management chain of this misconduct, making clear that a failure to prevent client asset misuse carries equal consequence as the perpetration of client asset misuse. SIGNIFICANCE: The effects of these actions send a powerful message to senior management: ignorance or passivity toward the misuse of client funds is not a valid exemption to avoid regulatory scrutiny. All responsible officers and managers must treat client asset protection as a front-line personal obligation, not a compliance department task. Regular independent reconciliation, escalation protocols, and board oversight of client asset controls are now considered as baseline requirements. 6. SFC Raids Two more Chinese Brokerages in Widening IPO Probe On May 27 the SFC cracked down on the investment banking sector. Enforcement officers raised the Hong Kong offices of CCB International (“ CCBI ”), local arm of China Construction Bank, and China Securities International (“ CSCI” )), a subsidiary of China Securities Co. Electronic devices and documents were seized for investigation into suspected misconduct linked to share offerings. The raids were notable as they represent a large-scale widening investigation rather than an isolated action. In March 2026, the SFC conducted what was described as one of the most significant enforcement sweeps of the investment banking sector in the past decade, targeting CITIC Securities and Guotai Junan International, during which eight individuals were arrested. The May raids followed 2 months later, targeting two more state-linked Chinese institutions. Following Hong Kong’s IPO boom, the city surged back to the top of global fundraising rankings, with a wave of new listings across mainland Chinese companies. The SFC has made clear that this boom cannot come at the cost of due diligence standards. The recent raids share the enforcement arm of this message. The SFC, CSCI and CCBI declined to comment and no formal charges have been filed and no fines announced at the time of writing. SIGNIFICANCE: Investment banks and underwriters active in Hong Kong’s ECM market should conduct internal audits of their IPO due diligence and listing advisory procedures. The SFC’s willingness to raid major state-linked institutions signals that firm size and market position provide no regulatory protection or special treatment. Financial institutions and licensed corporations that are proactive in self-reviewing and remediating errors will be better placed than those who wait to be investigated. Regulatory Updates 7. SFC steps up measures to address forged documents, money laundering risks and account opening standards On 22 May 2026, the SFC issued a circular outlining the expected controls for account opening and maintenance of client relationships. The China Securities Regulatory Commission has also specified relevant remediation plans for certain illegal cross-boundary securities, futures, and investment fund-related activities conducted in Mainland China. We have prepared an impact analysis on the expected controls for account opening and ongoing client relationship management. An SFC review of account opening practices across 12 securities has uncovered deficiencies in due diligence on account opening documentation and acceptance of forged documents making their way into client files. Firms accepting them are either unaware or choose not to look hard enough and consequently, the SFC has responded with a forceful circular that sets out binding expectations for every licensed corporation. The regulator identified a collection of recurring failures as a result of superficial due diligence at onboarding, inadequate handling of client introductions through overseas intermediaries, and a general culture of growth at expense of know-your-client procedures. The SFC is explicit that forged documents create pathways for money laundering and terrorist financing through Hong Kong’s securities infrastructure. The Circular Requirements: LCs must conduct an internal review to identify whether questionable or forged documents were accepted at account opening. The SFC has specified additional requirements for accounts held by Chinese Mainland Investors including: Closure of accounts with forged or questionable documents Closure of zero-balance dormant investment accounts Written investor declarations and a requirement that all settlements and fund movements use only the client’s own named bank accounts with eligible banks. The SFC also reminds investors that submitting false documents to open a brokerage account can constitute a criminal offence under the Hong Kong Crimes Ordinance. SIGNIFICANCE: The circular demands immediate action from firms to designate a senior individual to own the internal review, set a clear completion deadline, and document findings. For mainland investor accounts specifically, the additional measures apply to all new accounts going forward. The SFC has signaled that follow-up inspections and enforcement will follow firms that have self-identified and remediated problems will be far better positioned than those discovered to have done nothing. 8. FTSB and SFC conclude consultations on Virtual asset advisory and management regimes Hong Kong has spent the last three years building a legal framework for digital assets. On the 26 th of May, the Financial Services and the Treasury Bureau (“ FSTB ”) and SFC took the final significant step in that project, publishing consultation conclusions that pave the way for licensing regimes covering virtual asset advisory and management service providers. The framework is deliberately designed to mirror the conventional securities licensing structure: VA advisory services will be regulated in line with Type 4 (advising on securities) and VA asset management will track Type 9 (asset management). The “same activity, same risks, same rules” principle means that firms already operating in asset management or investment advisory should find compliance architecture even if underlying assets are new. The consultation drew 51 responses from a broad range of stakeholders. The FSTB and SFC have confirmed they are targeting the legislative bill itself to introduce into the legislative council before the end of 2026. The full suite of VA service providers, trading platforms, stable coin issuers, managers, advisors, etc. will sit within a regulated ecosystem upon the approval of the framework. SFC CEO Ms Julia LEUNG, described the development as “the final leg of our journey to complete the regulatory framework for digital assets” while Secretary Christopher Hui framed it as part of a broader effort to build a digital asset ecosystem “comparable to conventional finance.” SIGNIFICANCE: Firms currently providing VA advisory or portfolio management services in Hong Kong should start engaging with the SFC on pre-application discussions now to understand fit and scoping before the bill is tabled. For LCs that already hold Type 4 and Type 9, adding the VA versions may be smoother but still requires separate licensing and possible substantive obligations on licensing, conduct, and client asset handling. 9. SFC issues news guidance to help securities issuers prepare for upcoming uncertificated securities market regime Hong Kong’s securities market is on the verge of a structural reform that has been years in the making. Physical share certificates, a relic of the paper-era financial system, are being phased out. The SFC has published a Guidance Note to prepare issuers for the Uncertified Securities Market (“ USM ”) regime, which is scheduled to go live on November 16 th , 2026. Under the implementation of USM, issuers are obliged to maintain an approved securities registrar at all times. Currently, six companies have applied to becoming approved securities registrars. Issuers are also required to complete their amendment exercise by the first anniversary of USM launch by the 16 th of November 2027 or by the date of their first annual general meeting post USM launch. SIGNIFICANCE: Listed issuers should treat the November 16 th launch date deadline as an immediate action item. Issuers are recommended to appoint legal counsel and identify a preferred approved securities registrar from the applicant pool and build the USM amendments into their next AGM agenda. Proactive adoption is critical, delaying until 2027 will result in a missed AGM cycle and potential compliance risk. [End of ComplianceOne Newsletter – May 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

The topics discussed in this monthly newsletter for insurance are as follows: ComplianceOne Insurance Newsletter – August 2026 The topics discussed in this monthly newsletter are as follows: Regulatory Updates IA Clarifies that Mainland Residents’ Obligation to Declare and Pay Tax on Overseas Investment Income Has Always Existed IA’s Observations on Insurance Business Carried On with Premium Financing Facilities IA Requires Authorised Insurers to Adopt an Integrity Management Policy by 1 January 2027 Enforcement News IA and Hong Kong Police Force Conduct Joint Operation and Arrest 15 Persons for Suspected Fraudulent Practices at an FLMI Examination Centre Market News HKSAR Government Re-appoints Mr Clement CHEUNG as Chief Executive Officer of the IA First cohort of GenA.I. Sandbox++ announced, including insurance claims and anti-fraud use cases Regulatory Updates 1. IA Clarifies that Mainland Residents’ Obligation to Declare and Pay Tax on Overseas Investment Income Has Always Existed On 06 Aug 2026, multiple media outlets reported that cities such as Beijing and Hangzhou where individual income tax at 20% has been levied on Hong Kong insurance proceeds, covering insurance policy dividends (保險分紅) and prepaid premium interest (預繳保費利息). However, the taxation is not yet universal, with no unified enforcement standard. Source: Reuters ; South China Morning Post ; HK01 The Insurance Authority (" IA ") responded that the Government and the IA are closely monitoring the latest developments regarding mainland financial product tax arrangements. The IA emphasised that the requirement for Chinese residents to lawfully declare and pay tax on overseas investment income has always existed, and the market should not over-interpret or speculate. The IA further noted that Hong Kong’s insurance market remains mature and attractive to mainland clients, offering currency selection, global asset allocation, life planning and wealth succession services. The next-day (i.e. 07 Aug 2026) official Mainland line is separate: State Taxation Administration of PRC / Xinhua on 7 August 2026 SIGNIFICANCE: The IA and STA clarifications confirm that mainland tax residents’ duty to declare and pay tax on overseas investment income, including returns on Hong Kong policies, is a long-standing rule rather than a new levy aimed at Hong Kong. Enforcement does not yet appear uniform. Brokers in cross-border business should make sure mainland clients are told that filing and payment obligations may arise, and that marketing and oral explanations do not treat Hong Kong proceeds as tax-exempt. Stay close to further STA and local-bureau practice: a move toward consistent collection would change how certain savings and participating features are sold, even if the legal text does not change. 2. IA’s Observations on Insurance Business Carried On with Premium Financing Facilities On 20 August 2026, the IA issued a circular to chief executives of all authorised insurers carrying on long-term insurance business, setting out its observations on policies written with premium financing facilities. The Hong Kong Monetary Authority (“HKMA”) also issued a companion circular the same day to all authorized institutions, including those acting as licensed insurance intermediaries or as premium financing providers. The IA noted a marked rise in premium-financed long-term business in the first half of 2026. The increase was observed across a number of life insurers, and for some insurers premium financing has become the main source of new sales. Period Figure H1 2025 *Premium-financed business about 21% of new business premiums. H1 2026 *Premium-financed business about 36% of new business premiums (+15 percentage points). H2 2026 IA and HKMA schedule a further joint thematic inspection on premium financing. *For some products, PF Policies exceeded 80% of policy count or premiums. What is Premium-Financed Policies: Premium-financed policies (“PF Policies”) are commonly used for wealth management. Customer objectives and lapse behaviour can differ materially from non-PF policies. Because participating policyholders share returns from the same participating fund pool, practices on PF business can also affect the long-term outcomes of non-premium-financed policyholders. Principal risks identified What the IA observed Interest-rate and market sensitivity PF business is sensitive to interest rates and economic volatility. Leverage amplifies these risks for policyholders and insurers, raising lapse risk and putting pressure on liquidity in private credit, private equity and other alternatives. Correlated stress sales A concentrated PF book may trigger correlated asset sales at depressed prices in a stress scenario. Lapse assumption mismatch If a large number of customers surrender when target returns are reached, or when financing facilities mature, actual lapse experience may diverge from product-design assumptions and produce adverse financial effects for the insurer. Competitive leverage The industry has competed through larger premium discounts and higher “Day 1” surrender values, while banks have offered higher loan-to-value ratios. Recent IA reviews found sales materials suggesting a policyholder could achieve leverage of up to nine times by contributing only 10% of the premium. Supervisory expectations What is expected Authorised insurers Comply with the Insurance Ordinance and relevant regulatory requirements when underwriting new policies that use premium financing facilities. Authorised insurers - ORSA Enhance Own Risk and Solvency Assessment (“ORSA”) analysis of PF business, including appropriate lapse and economic stress and scenario testing. Insurers - sales and training Keep materials well balanced. Do not emphasise the leveraging benefit of premium financing. Disclose potential significant losses under adverse scenarios and other key downside risks clearly and prominently. Authorized institutions acting as intermediaries Keep abreast of changes in appointing principals’ materials and ensure the relevant information is properly disclosed and explained to customers. SIGNIFICANCE: Premium financing is no longer a niche wealth-management feature. It now accounts for about 36% of Hong Kong new business premiums. The circular is a clear signal that product design, illustrations, sales scripts, fund management and ORSA should treat PF books as a distinct risk cluster, not as ordinary participating business with a financing overlay. Insurers, banks and intermediaries should review materials, leverage disclosures, persistency assumptions and participating-fund fairness before the H2 2026 joint inspection. 3. IA Requires Authorised Insurers to Adopt an Integrity Management Policy by 1 January 2027 On 31 August 2026, the IA issued a circular to chief executives of all authorised insurers. Each authorised insurer must formulate an Integrity Management Policy, or enhance its existing policy, by 1 January 2027 . The IA’s position is that sound corporate governance and internal controls are essential to the healthy development of the insurance industry. Integrity standards must be clearly communicated and built into the insurer’s control system through: reporting and enforcement of non-compliance; and regular review of the integrity policy and related procedures Essential governance aspects in the sample policy ( Annex ) Pillar Expectation Anti-bribery Prohibit the offer, solicitation or acceptance of advantages. Conflicts of interest Avoid conflicts where possible. Declare and properly manage conflicts that cannot be avoided. Confidentiality Preserve confidential information of the insurer, policyholders and counterparties. Enforcement and reporting Report and enforce non-compliance, including corruption. Provide assistance to regulators and law enforcement agencies. Covered Persons The policy is expected to bind directors, controllers, key persons in control functions, staff and agents. Insurance Broker Companies are not required to adopt their own policy under this circular, but counterparties may still raise anti-bribery, conflicts, confidentiality and reporting standards in agency agreements and due diligence. SIGNIFICANCE: This circular is addressed to authorised insurers only. Licensed insurance agencies and broker companies are not required to adopt their own Integrity Management Policy under this circular. That said, intermediaries should not treat the development as irrelevant. Appointed agents of an insurer fall within that insurer’s policy once it is in force, and insurers may cascade the same integrity standards through agency agreements, codes of conduct, training and monitoring. Brokers dealing with those insurers may also see tighter counterparties’ expectations on anti-bribery, conflicts, confidentiality and reporting. Enforcement News 4. IA and Hong Kong Police Force Conduct Joint Operation and Arrest 15 Persons for Suspected Fraudulent Practices at an FLMI Examination Centre On 27 August 2026, the IA and the Hong Kong Police Force conducted a joint enforcement operation against an examination centre operated by the Greater China Wemedia Association Limited. The centre organised the Fellow, Life Management Institute (“ FLMI ”) examinations awarded by the Life Office Management Association (“ LOMA ”). The IA announced the operation on 28 August 2026. The operation covered searches of nine locations and the arrest of 15 persons, including three current and three former licensed insurance intermediaries. Cheating in Exams Police identified a syndicate of three local companies that marketed “intensive revision classes” and a “guaranteed pass”. Candidates were charged an extra HK$14,000 on top of the official examination fee of about HK$20,000. The alleged method was to: install remote-control software on candidates’ examination computers; arrange syndicate staff as invigilators; and have off-site operators sit the online paper while the candidate remained seated, to create the appearance of a normal sitting. Source: stheadline 29 Aug 2026 Temporary IA Non-Recognition of FLMI Because there were indications that the suspected malpractice had continued for some time, and that LOMA had not exercised effective monitoring, the IA immediately suspended recognition of the FLMI as a qualification meeting the educational requirements for an insurance intermediary licence. The IA will also review in detail all cases in which the qualification was obtained through the examination centre concerned. SIGNIFICANCE: This is the first public use of the 2024 IA and Police joint enforcement MoU and goes directly to fitness and propriety. With immediate effect, FLMI is not recognised as meeting the educational requirements for an insurance intermediary licence. Firms should not treat an FLMI certificate as a valid licensing credential until the IA reinstates recognition. The IA has also said it will review, case by case, qualifications obtained through the affected centre, which may lead to follow-up on existing licences. Identify staff and appointed agents who used FLMI from that centre, keep the records, and be ready for licensing queries. Markets News 5. HKSAR Government Re-appoints Mr Clement CHEUNG as Chief Executive Officer of the IA On 14 August 2026, the HKSAR Government announced the reappointment of Mr Clement CHEUNG Wan-ching (張雲正) as Chief Executive Officer of the IA for a further term of three years, from 15 August 2026 to 14 August 2029. Mr CHEUNG was first appointed as CEO in August 2018. He currently serves as a member of the Executive Committee of the International Association of Insurance Supervisors and as a member of the Asian Forum of Insurance Regulators. Sources: HKSAR Government press release (14 August 2026) IA press release (14 August 2026) SIGNIFICANCE: Continuity of leadership matters for the regulatory calendar, such as RBC refinements, ILS and captives, and the conduct and technology agenda. The more immediate signal is the one CHEUNG gave on reappointment: reduce concentration on mainland-visitor demand and widen the regional client base. 6 . First cohort of GenA.I. Sandbox++ announced, including insurance claims and anti-fraud use cases The HKMA, the Securities and Futures Commission, the IA and the Mandatory Provident Fund Schemes Authority, together with the Hong Kong Cyberport Management Company Limited, announced the first cohort of the Generative Artificial Intelligence Sandbox++ (“GenA.I. Sandbox++”). From nearly 100 proposals, 36 use cases were selected, involving 30 financial institutions and 27 technology partners. Selection turned on innovation, technical complexity and potential value to the industry, together with advice from an academic selection committee. Participants will be onboarded to a designated platform at Cyberport’s Artificial Intelligence Supercomputing Centre. Technical trials start later in 2026. This cohort focuses on agentic A.I. systems that go beyond content generation and can take on greater autonomy. Testing will cover end-to-end processes including customer onboarding, payments, insurance claims and customer interactions. Building on the earlier “A.I. vs. A.I.” theme, the pilots will also examine how one A.I. application can provide dynamic oversight of another. Illustrative themes Theme Example use cases Risk management Real-time A.I. judge for chatbots; multimodal A.I. for compliance review; A.I.-enhanced due diligence; A.I. cybersecurity tools; A.I. compliance and regulatory-oversight assistants. Anti-fraud Fraud simulation and defence reinforcement; multi-agent fraud detection and behavioural risk monitoring; intelligent fraud prevention for digitally altered medical documentation. Customer experience Agentic payments; multi-agent wealth management; A.I. knowledge assistant for medical claims; A.I. engagement platforms for MPF scheme members. Insurance-sector participants in the first cohort include: AXA China Region Insurance Company (Hong Kong) Limited; FWD Life Insurance Company (Bermuda) Limited; HSBC Life (International) Limited; BOC Group Life Assurance Company Limited; and Manulife (International) Limited. For more details, please refer to the Annex(s) Mr Clement CHEUNG, Chief Executive Officer of the IA, said: “ I am very impressed by the quality and diversity of proposals originating from the insurance industry which reflect a commitment to deploy advanced technologies for the betterment of policyholders. The GenA.I. Sandbox++ has inspired new ideas, generated practical insights and deepened cross-sector collaboration. The IA will strive to reinforce the position of Hong Kong as an international innovative and technology centre under the National 15th Five-Year Plan through progressive expansion of the AI Cohort Programme. ” SIGNIFICANCE: The first cohort confirms that agentic A.I. in claims, anti-fraud and customer servicing is moving from concept to supervised testing. Firms that are not in the cohort should still prepare governance, model-risk and conduct frameworks. Sandbox learnings are intended to be shared more widely through the IA’s AI Cohort Programme, and those standards will not stay confined to the 30 participating institutions. [End of ComplianceOne Insurance Newsletter – August 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 3955 0277 www.complianceone.hk

The topics discussed in this monthly newsletter for insurance are as follows: ComplianceOne Insurance Newsletter – February 2026 The topics discussed in this monthly newsletter are as follows: Regulatory Updates Anti-Money Laundering and Sanctions Updates Market News Hong Kong’s Single-Family Offices total surpasses 3,380, Contributing Approximately $12.6 Billion Annually to Hong Kong’s Economy IA Launches Public Consultation on Enhancements to the Risk-based Capital Regime Enforcement News IA Reprimands and Fines Three Licensed Broker Companies HK$429,000 Total for Failures in AML/CFT Requirements Regulatory Updates 1. Anti-Money Laundering and Sanctions Updates In early March 2026, the Insurance Authority (“ IA ”) issued several key circulars and updates on anti-money laundering (“ AML ”) and counter-financing of terrorism (“ CFT ”) matters, accessible via the dedicated IA page for 2026 AML circulars. These updates primarily relate to international sanctions regimes, United Nations measures, and Financial Action Task Force (“ FATF ”) guidance, requiring prompt attention from authorized insurers and licensed insurance intermediaries (especially those handling long-term business). Circulars / Sanction List Updates Contents 3 March 2026 Circular on United Nations (Anti-Terrorism Measures) Ordinance [G.N. (E.) 11 of 2026] Significant Updates: The updated Schedule specifies the following individuals (no entities or groups are added in this update): QDi.001: Mohammed Salahaldin Abd El Halim Zidane , who’s Responsible for security of Usama bin Laden. QDi.002: Amin Muhammad Ul Haq Saam Khan , who’s Security coordinator for Usama bin Laden. QDi.003: Salim Ahmad Salim Hamdan , who’s supporting acts or activities of Al-Qaida and Usama bin Laden. These designations trigger asset freezing, prohibitions on making funds or financial services available, and other restrictions under the Ordinance. 3 March 2026 Circular on Statements issued by the Financial Action Task Force (" FATF ") Informs insurance institutions (“ IIs ”) of the FATF Plenary outcomes (11–13 February 2026), including: High-Risk Jurisdictions subject to a Call for Action : DPRK (Democratic People's Republic of Korea) and Iran remain listed due to ongoing strategic deficiencies and proliferation/terrorism financing risks; countermeasures and enhanced vigilance required. Myanmar continues under enhanced due diligence with potential future countermeasures if no progress by June 2026. Jurisdictions under Increased Monitoring : IIs must factor these into risk assessments and monitor the FATF website for changes. Where the Virgin Islands (UK) (BVI) still remain in the list. Emerging focus areas: Cyber-enabled fraud, virtual assets, offshore VASPs, stablecoins, and unhosted wallets (with related FATF reports expected in March 2026). 2 March 2026 United Nations Sanctions (Sudan) Regulation 2013 [G.N. (E.) 10 of 2026] Significant Updates: United Nations Sanctions (Sudan) Regulation 2013 (Cap. 537 sub. leg. BF), notice updates the list of relevant persons specified under section 31 of the Regulation. It reflects amendments or additions to designations related to Sudan sanctions (imposed by UN Security Council resolutions concerning the situation in Sudan, including arms embargoes, asset freezes, and travel bans on certain individuals or entities linked to conflict or violations). 2 March 2026 Updated list of relevant persons and entities under the United Nations Sanctions (ISIL and Al-Qaida) Regulation Features the latest consolidated list (as at 27 February 2026) of designated individuals and entities linked to ISIL (Da'esh) and Al-Qaida; Insurers and intermediaries must screen clients and transactions against this list to avoid sanctions violations. SIGNIFICANCE: These updates reinforce Hong Kong's alignment with global standards set by the FATF and UN, helping to safeguard the insurance sector against money laundering, terrorism financing, and proliferation risks. Insurance companies, agents, and brokers need to be aware of immediately updating their name screening databases to include the latest UN Security Council Consolidated List, FATF High-Risk Jurisdictions subject to a Call for Action, and FATF Jurisdictions under Increased Monitoring, while conducting enhanced due diligence on high-risk elements, incorporating emerging risks into assessments, and ensuring staff training for ongoing compliance. Timely compliance is essential to avoid regulatory breaches, reputational damage, or enforcement actions by the IA. With increasing scrutiny on virtual assets and cyber fraud, these notices underscore the need for robust screening, risk assessment, and staff training to maintain policyholder protection and industry integrity in an evolving threat landscape. Markets News 2. Hong Kong’s Single-Family Offices total surpasses 3,380, Contributing Approximately $12.6 Billion Annually to Hong Kong’s Economy On 10 February 2026, the Financial Services and the Treasury Bureau (“ FSTB ”) and Invest Hong Kong (“ InvestHK ”) jointly released findings from the Market Study on the Family Office Landscape in Hong Kong , commissioned by InvestHK and conducted by Deloitte. The study estimates that 3,384 single-family offices were operating in Hong Kong as of the end of 2025, marking an increase of 681 offices (over 25%) since the end of 2023. Two major affects to the Hong Kong Market: Economic Impact: Single-family offices contribute approximately HK$12.6 billion annually to the local economy through operating expenditures alone and directly employ over 10,000 full-time professionals. When including multifamily offices and supporting service providers, the overall economic benefits are expected to be substantially greater. Hong Kong’s Wealth Management Position: As of end-2024, assets under management in Hong Kong reached approximately HK$35 trillion (about US$4.5 trillion). The city ranked second globally in the number of ultra-high-net-worth individuals as of June 2025, reinforcing its status as a leading destination for family offices. Key highlights from the announcement and study: Upcoming measures in 2026 Upcoming measures include legislative proposals in the first half of 2026 to expand preferential tax regimes for funds and single-family offices to cover additional asset classes such as precious metals, loans, private credit investments, and digital assets. Achieving the new target set out in the Chief Executive's 2025 Policy Address The Government aims to assist more than 220 family offices to establish or expand in Hong Kong from 2026 to 2028. *The target was set out in the Chief Executive's 2025 Policy . Comments from Representatives of FSTB and InvestHK Mr Christopher HUI, Secretary for Financial Services and the Treasury, attributed the sustained growth to Hong Kong’s advantages under the “one country, two systems” framework, including its role as a leading global asset and wealth management hub with predictable environment, connectivity to the mainland and the world, and supportive policies. Ms Alpha LAU, Director-General of Investment Promotion at InvestHK, highlighted strong overseas interest (particularly from Europe and Southeast Asia) in Hong Kong’s flexible investment environment, no geographical restrictions on investments under the preferential tax regime, high privacy (no general licensing requirement for single-family offices), and tax incentives. SIGNIFICANCE: The surge in single-family offices underscores Hong Kong’s strengthened position as Asia’s premier wealth and asset management hub, attracting diverse global capital through targeted policy enhancements, tax competitiveness, privacy protections, and strategic connectivity. The substantial annual economic injection of HK$12.6 billion (via operating expenditures) and direct employment of over 10,000 professionals highlight the sector’s growing role in driving local financial services growth, job creation, and broader ecosystem development. With forthcoming tax expansions (including digital assets) and ambitious growth targets, these developments reinforce Hong Kong’s appeal to ultra-high-net-worth families amid global shifts toward sustainable wealth management and intergenerational planning, further solidifying its status as a trusted international financial centre. 3. IA Launches Public Consultation on Enhancements to the Risk-based Capital Regime On 11 February 2026, the IA launched a public consultation on proposed amendments to the Insurance (Valuation and Capital) Rules (Cap. 41R) , applied for authorized insurers only (excluding licensed insurance agencies and licensed insurance broker companies). This follows a comprehensive review of the Risk-based Capital (“ RBC ”) Regime, which commenced on 1 July 2024. The proposed changes seek to refine the framework while preserving strong prudential safeguards for policyholders. Key areas include: Preferential capital treatment for eligible infrastructure investments, to encourage financing that supports local economic development. Revisions to the required capital amounts for general business lines. Technical adjustments for indexed universal life (“ IUL ”) business. Specific treatments for crypto assets (with a proposed 100% risk charge in related discussions) and specified stablecoins, reflecting evolving exposures to digital assets. These refinements aim to enhance Hong Kong’s position as a competitive global risk management hub, attract more international activity, and align capital requirements with market innovations and emerging asset classes. The consultation paper is available on the IA website. Interested parties, including insurers, intermediaries, industry associations, and the public, are invited to submit comments by 10 March 2026 via: email to rbc@ia.org.hk ; or by post to the IA office at 19/F, 41 Heung Yip Road, Wong Chuk Hang, Hong Kong. SIGNIFICANCE: This consultation represents a forward-looking adjustment to the RBC Regime, balancing innovation with stability. By incentivizing infrastructure investments and clarifying treatment of modern assets like crypto and stablecoins, the proposals support Hong Kong’s strategic goals in sustainable development and digital finance. They also reinforce the city’s attractiveness to multinational insurers and investors, while ensuring continued robust protection for policyholders amid global regulatory evolution. Industry participants are encouraged to engage actively to shape these important enhancements. Enforcement News 4. IA Reprimands and Fines Three Licensed Broker Companies HK$429,000 Total for Failures in AML/CFT Requirements On 4 March 2026, the IA announced disciplinary action against three licensed insurance broker companies for breaches of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance ( Cap. 615 ). The affected companies are: Insurance Broker Companies’ Name License Number ASI-Union Global Assets Management Ltd. FB1534 Macroscopica International Wealth Management Ltd. FB1557 Bay Union Insurance Brokers Limited (formerly known as Huize Hong Kong Insurance Broker Limited) FB1661 The contraventions include: Failure to establish and maintain effective internal procedures for conducting customer due diligence (“ CDD ”). Failure to determine whether customers were politically exposed persons (“ PEPs ”) or whether a person was purporting to act on behalf of the customer. Failure to keep relevant records as required. In addition to the companies, three related individuals were reprimanded for their involvement in these compliance failures. The total pecuniary fine imposed across the three broker companies amounts to HK$429,000. The IA noted that the companies have since implemented effective remedial actions to address the identified deficiencies. SIGNIFICANCE: No evidence of actual money laundering or terrorist financing was reported in connection with these cases, but the breaches highlight gaps in frontline controls that could expose the insurance sector to misuse. Broker companies play a critical role as the primary point of contact with policyholders and are essential in preventing the insurance industry from being exploited for financial crime, thereby protecting Hong Kong's reputation as an international financial centre. This enforcement action reinforces the IA's ongoing priority on robust AML/CTF compliance among insurance intermediaries, particularly broker companies. As intermediaries interact directly with clients, effective CDD, PEP screening, and record-keeping are foundational to preventing financial crime and maintaining trust in Hong Kong's insurance market. The penalties serve as a reminder that even post-remediation cooperation does not eliminate accountability for systemic control weaknesses. With increasing regulatory scrutiny on financial crime risks, licensed entities are urged to review and strengthen their AML/CTF frameworks to avoid similar outcomes, including potential reputational damage, higher supervisory intensity, or escalated sanctions in future cases. [End of ComplianceOne Insurance Newsletter – February 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

The reform introduces new and expanded SFC regulated activities for Hong Kong OTC derivatives, expected to take effect in H2 2027. ComplianceOne's Impact Analysis : Commencement of OTC Derivatives Licensing Regime (August 2026) Disclaimer: The content and recommendations contained in this document are solely our internal opinions and guidelines, for internal reference and evaluation purposes only. This document does not constitute professional or formal legal advice. The information contained herein is subject to further amendments or updates by the Securities and Futures Commission or other relevant regulatory authorities. Our company assumes no legal responsibility for the content of this document. Licensed corporations should make independent judgments based on their own circumstances and the latest regulatory requirements when referring to or using this document, and are advised to seek independent legal advice from qualified lawyers or professional advisors if necessary. Our company reserves the right to modify or update this document at any time without prior notice. Table of Contents 1.......... Background 2.......... Scope and Licensing Implications 3.......... Proposed RA11 OTCD Dealer Licence Application Requirements 4.......... Transitional Arrangements 5.......... Key Takeaways and Next Steps for Industry 6.......... How we can help 1. Background The Securities and Futures Commission (“ SFC ”) is implementing the major component of OTC (“ Over-the-Counter ”) derivatives (“ OTCD ”) reforms by introducing: Two new regulated activities – Type 11 (dealing in or advising on OTC derivative products) and Type 12 (providing client clearing services for OTC derivative transactions); and Two expanded regulated activities – Type 7 (automated trading services) and Type 9 (asset management) extended to cover OTC derivative products. The SFC estimates the new regime will become effective in the second half of 2027 . Licensed corporations (“ LCs ”) is highly encouraged to assess whether their existing or planned activities fall within the scope of these new or expanded regulated activities and take preparatory action well in advance of the commencement date. 2. Scope and Licensing Implications LCs should carefully consider whether their proposed / existing business activities trigger licensing requirements: Activity Licensed Required? Type of License Required Dealing in OTC equity derivatives on agency basis ( Note 1 ) × RA1 Dealing in OTC futures derivatives on agency basis × RA2 Dealing in OTC equity derivatives on principal basis √ RA11 Dealing in interest rate derivatives, credit derivatives, commodity derivatives, etc. √ RA11 Advising on OTCD products √ RA11 Proprietary clearing of OTCD positions × RA12 license not required Providing clearing services to third-party clients through a CCP √ RA12 Operating an electronic trading platform for OTCD products √ RA7 (Extended) Providing execution-only ATS for OTCD products √ RA7 (Extended) Managing portfolios containing OTCD products for external clients √ RA9 (Extended) Managing OTCD portfolios for wholly-owned group companies × RA9 Note 1 Licensing Implications Under the new OTC derivatives licensing regime, the SFC draws a clear line between acting as agent and acting as principal when dealing in OTC equity derivatives. Agency basis executes transactions on behalf of its clients , does not become a counterparty to the trade, and does not assume principal market or credit risk . In this capacity, the activity falls outside the scope of the new Type 11 regulated activity and remains subject to the existing Type 1 (dealing in securities) and Type 2 (dealing in futures contracts) licences Principal basis the firm enters into OTC equity derivative transactions as a direct counterparty to its clients, taking on proprietary risk and effectively “dealing” in those products on its own account. This constitutes a dealing activity that squarely triggers the new Type 11 licensing requirement. For non‑equity OTC derivatives (e.g. interest rate, credit, commodity derivatives), however, the agency / principal distinction is generally not the determining factor – any dealing or advising in such products will typically require a Type 11 licence, regardless of whether the firm acts as agent or principal , unless a specific exemption applies. Firms should therefore carefully assess their business models and booking arrangements to determine whether they are acting as agent or principal, particularly for OTC equity derivative transactions, as this distinction directly affects their licensing obligations under the new regime. 3. Proposed RA11 Licence Application Requirement Activity Licensed Required? Activity Licensed Required? Capital Requirement Paid-Up Share Capital: HK$30 million Required Liquid Capital: HK$15 million Paid-Up Share Capital: HK$60 million Required Liquid Capital: HK$30 million Below specified thresholds [1] Tangible Capital: HK$500 million Required Liquid Capital: HK$78 million In any other case Tangible Capital: HK$1 billion Required Liquid Capital: HK$150 million FRR Computation Approach Basic approaches (BMRA / BOCCRA) Standardized approaches (SMRA / SOCCRA) Risk Management Resources Low risk profile without taking principal position Less complex risk data aggregation and calculation Require use of complex calculations and more advanced risk data Need to maintain sophisticated risk management systems RO Competence At least 3 years of relevant industry experience within the past 6 years Familiar with the risk management and capital standards for the OTCD regime [1] HK$600 million of aggregate gross notional amount of OTCD transactions in 12 months 4. Transitional Arrangements To avoid market disruption, the SFC has designed a 6-month transitional arrangement commencing in Jul 2027 (estimated) to enable existing qualified market participants to continue their activities before obtaining the full licence under the new regime. Note 2 Applicable for LC, RO and LR with no licence for the new (Type 11 and 12) or expanded RA (Type 7 and 9) Note 3 Applicable for LC, RO and LR with existing license for RA9 which managing portfolios containing OTCD products for external clients Note 4 LC will be deemed as Qualified if: Has been carrying on the activity for at least 2 years immediately before the commencement date Has at least 2 eligible ROs RO will be deemed as eligible RO if: Has been carrying on the activity for at least 2 years immediately before the commencement date 5. Key Takeaways and Next Steps for Industry Senior management should ensure the following five readiness steps are completed before H2 2027: Complete a thorough review of whether current activities fall within Type 11, 12, or expanded Types 7 and 9. Determine whether the firm qualifies for the deeming mechanism. Review legal entity and booking arrangements and assess where risks are booked and managed. Evaluate how the broader regulatory framework applies to the business. Ensure governance, risk management, and internal controls are appropriate for a regulated environment. 6. How we can help Our team consists of experienced professionals with deep expertise in compliance, risk management, and policy review and development. We can accurately identify gaps between the regulatory expectations outlined in the relevant circulars and your company’s existing policies and procedures. With a thorough understanding of the complexities of regulatory requirements, we provide tailored solutions and analyses to meet your specific needs and address any material deficiencies. Our expertise ensures that your company maintains full compliance with regulatory standards while comprehensively elevating your compliance practices to a higher level. If you have any questions, please feel free to contact our compliance support team at any time. [End of ComplianceOne's Impact Analysis: Commencement of OTC Derivatives Licensing Regime – Augest 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

2026年7月24日，財政部、國家稅務總局聯合發布《關於離岸信託個人所得稅有關事項的公告》（財政部稅務總局公告2026年第21號，簡稱“21號文” ） ... 國稅局據報加強培訓，離岸信託徵稅新規進入實操階段 2026年7月24日，財政部、國家稅務總局聯合發布《 關於離岸信託個人所得稅有關事項的公告 》（財政部稅務總局公告2026年第21號，簡稱“21號文” ） ，同日國家稅務總局發布信託公告（國家稅務總局公告2026年第15號），第一個國家稅務總局的個人徵管公告（國家稅務總局公告2026年第15號），首次全所得稅系統徵管。 新規明確：居民個人將財產裝入離岸信託，以財產裝入時的市場價值扣除財產原值和合理費用後的餘額為應納稅所得額，按照「財產轉讓所得」申報繳納個人所得稅， 適用20%稅率 。離岸信託存續期間產生的收益，無論是否實際分配，均以該居民個人為納稅人，按年申報繳納個人所得稅。 根據 CN B C 報道，多位境內外稅務律師透露， 國家稅務總局正在對地方稅務官員進行大規模培訓，以統一對離岸信託徵稅的解釋 。訓練涵蓋範圍相當廣闊，涉及省級、市級以至村鎮級別的政府員工。同時，稅務總局已向境內律師事務所和會計師事務所發送指導意見草案，計劃未來幾週舉行諮詢會議。 然而，新規在實操層面仍有許多 待解問題 ： 2023年之前設立的離岸信託，持有人需要追溯申報多少年的信託資產，目前尚不清楚； 是否適用3至5年的標準時效，未有定論； 申報需要提供多詳盡的文件才會被接受或拒絕，尚無統一標準； 10月份的截止日期究竟是申報截止日期還是全額繳稅截止日期，有待釐清。 稅務顧問估計，未來幾週地方當局對這些細節的解讀，將與國家稅務總局的解讀基本一致。 此外，稅務顧問也警告，許多信託資產可能違反7月發布的外國投資申報規則，可能引發外匯管理部門審查，以了解資金最初是如何流出中國的。 小結 ：離岸信託稅新規已正式落地，國稅局正全力推動統一執行口徑。但對於已設立多年信託的持有人而言， 追溯期限、文件要求、截止日期等關鍵細節仍有待進一步明確 。建議相關人士密切注意未來數週稅務總局發布的配套指引及地方稅務機關的具體執行解讀，及時評估自身合規狀況。 關於離岸信託稅務新規的更多細節與實操影響，我們在先前的文章中已作初步梳理，點擊回顧👉 《 離岸信託「免稅時代」 結束？新規明確20%個稅，哪些人要關注？ 》 建議結合本文一併閱讀，更全面掌握新規要點及對高淨值客戶的潛在影響。後續如有進一步解讀或實操指引，我們也將第一時間更新，歡迎持續關注「天匯合規顧問」。 參考資料：中華人民共和國財政部、 CNBC等 [完結 - 國稅局據報加強培訓，離岸信託徵稅新規進入實操階段 ] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The article is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 39550277 www.complianceone.hk

The topics discussed in this monthly newsletter for insurance are as follows: ComplianceOne Insurance Newsletter – Jun 2026 The topics discussed in this monthly newsletter are as follows: Market News IA Warns that Any Attempt to Circumvent Remuneration Rules Via Cross-Border Structures Will Result in Its Timely Intervention IA Hosts AI Cohort Symposium and Welcomes Three New Core Participants Regulatory Updates IA Draws Attention to HKMA Circular on Remuneration Structures for Banks IA Shares Key Observations and Best Practices from Recent Onsite Conduct Inspections Markets News 1. IA Warns that Any Attempt to Circumvent Remuneration Rules Via Cross-Border Structures Will Result in Its Timely Intervention On 16 June 2026, Chief Executive of Insurance Authority (“IA”) - Mr Clement CHEUNG (張雲正) publicly warned that the IA has observed indications of market participants attempting to circumvent the new remuneration measures through indirect methods. The IA has been closely monitoring the market and will intervene at the appropriate time, with public announcements to follow. Source: Bloomberg – Hong Kong Insurance Regulator Vows Crackdown on Rule-Breakers (15 June 2026) ; HKEJ – “保監揭行業規避新例 適時介入” (16 June 2026) To address excessive front-loading of commissions and misaligned intermediary incentives in the participating policy market, the IA has implemented the following measures in quick succession: Announce Date Effective Date Measure Reference 30 Jul 2025 01 Jan 2026 Caps introduced on demonstration interest rates for participating policies, effective on 01 Jan 2026. Commissions payable to intermediaries for participating policies capped at 70% of total commissions, with at least 30% required to be spread evenly over a minimum of five subsequent years Circular 30 Jul 2025 ; Practice Note 01 Sep 2025 01 Oct 2025 Referral fees paid by licensed broker companies to referrers capped at 50% of total commissions Circular 01 Sep 2025 ; Mr Cheung stated that while the IA has not specified the exact evasion methods observed, it will take timely follow-up action where necessary. Maintaining Compliant Cross-Border Insurance Business Mr Cheung also addressed market concerns arising from recent China Securities Regulatory Commission (“CSRC”) actions against illegal cross-border securities activities and the potential impact on Hong Kong insurance business involving Mainland visitors. He reaffirmed that the IA will continue to focus on ensuring insurance funds enter Hong Kong through legal and compliant channels, while proactively applying forward-looking monitoring to reduce market disruption risks. The IA has consistently prioritised cross-border insurance compliance over the years: Year Cross-Border Actions Source (for reference only) 2005 Coordinated with Mainland regulators on “underground policies” and took disciplinary action against insurers and intermediaries suspected of improper sales. Finance Sina (10 Mar 2005) 2016 Following concerns over large premium payments via UnionPay cards under the capital account, coordinated with Mainland authorities and introduced the Important Facts Statement to verify that all policies are signed within Hong Kong, requiring insurers to obtain and retain supporting documentation. INS/TEC/6/64 ; IFS-MP 2024 Jointly with the Independent Commission Against Corruption (“ICAC”), cracked down on insurance broker companies suspected of cross-border unlicensed and illegal policy sales. IA-Press Release (11 Apr 2024) SIGNIFICANCE: The IA’s warning signals that it is actively scrutinising how the new remuneration requirements are being applied in practice and is ready to act where it identifies attempts to bypass them. Insurers and intermediaries should promptly review their commission payment structures, including any overrides, bonuses, and referral arrangements, to ensure they remain aligned with the IA’s expectations under the current framework. For firms with significant cross-border client activity, the IA’s emphasis on forward-looking monitoring highlights the need for heightened vigilance. Companies are advised to strengthen internal controls, documentation standards, and ongoing monitoring of sales processes involving non-Hong Kong clients. Maintaining clear records and robust oversight in these areas will help demonstrate compliance as the IA continues to focus on this segment of the market. 2. IA Hosts AI Cohort Symposium and Welcomes Three New Core Participants On the 15 of June 2026, the IA hosted the AI Cohort Symposium and welcomed three new core participants to the programme. This brings the total number of core participants to 10 since the initiative was launched in August 2025. The full list of core participants now comprises: AIA Group FWD Group AXA Hong Kong and Macau HSBC Life (International) Limited * BOC Group Life Assurance Company Limited * Manulife (International) Limited * China Life Insurance (Overseas) Company Limited Prudential Hong Kong Limited China Taiping Insurance (HK) Company Limited YF Life Insurance International Limited *Newly Join from June 2026 Core participant status carries defined obligations as set out in the IA’s AI Cohort Annex . Each firm commits to: Establishing a Centre of Excellence for AI adoption and innovation in Hong Kong; Developing internal AI talent pipelines; Contributing to positioning Hong Kong as a regional AI hub; Forging a vibrant AI ecosystem; Nurturing talents through capability building; and Sharing knowledge and experience with brokers and smaller participants. At the symposium, representatives from core participating insurers shared their achievements and strategic plans in these areas. Chairman of IA - Mr Stephen YIU highlighted two themes he is monitoring closely: Sector(s) Mr Stephen YIU speech AI governance Insurers are showing stronger ownership and governance, with greater discipline in choosing use cases that support business value and customer outcomes Ecosystem dimension At the same time, Hong Kong’s AI and Insurtech ecosystem has continued to strengthen, with more solution providers bringing capabilities relevant to core insurance functions. This matters because AI adoption does not happen in isolation. It depends on insurers, technology companies and the broader ecosystem progressing together. Representatives from Cyberport and the Hong Kong-Shenzhen Innovation and Technology Park highlighted opportunities for cross-sector collaboration. Technology companies also set up booths to introduce their proprietary AI offerings relevant to insurance functions. **Source: IA Press Releases 15 June 2026 SIGNIFICANCE: The AI Cohort reaching 10 core participants, including major players demonstrates that responsible AI adoption is rapidly becoming a strategic priority and industry benchmark for leading insurers in Hong Kong. Insurers not yet participating should assess whether their AI governance frameworks, talent development plans and use case selection processes would meet the standards expected of core participants. Regulatory Updates 3. IA Draws Attention to HKMA Circular on Remuneration Structures for Banks On 5 June 2026, the IA issued a circular to draw the industry’s attention to the parallel circular issued by the Hong Kong Monetary Authority (“HKMA”) on the same date, titled “Remuneration Structures of Licensed Insurance Intermediaries which are Authorized Institutions for Participating Policies with Regular Payment Terms”. The HKMA Circular sets out regulatory expectations on commission spreading requirements applicable to authorized institutions (“banks”) acting as licensed insurance intermediaries when selling participating policies with regular payment terms. These expectations are consistent with the fundamental principle that properly prorated remuneration structures help align the interests of intermediaries with those of policyholders and support the delivery of both pre-contract and ongoing services. The IA circular reminds authorized insurers that they are expected to take into account the requirements in the HKMA Circular when designing remuneration structures for their appointed licensed insurance intermediaries that are authorized institutions. It further states that the IA’s Practice Note on Remuneration Structures of Authorized Insurers for Licensed Insurance Intermediaries for Participating Policies (issued 30 July 2025) and the HKMA Circular together form a comprehensive regulatory framework that should be interpreted and applied holistically. SIGNIFICANCE: Authorised insurers should reassess existing remuneration arrangements for bancassurance channels to ensure they are consistent with the IA and HKMA requirements. Firms should also review governance processes, monitoring mechanisms and contractual arrangements with banking partners to demonstrate that remuneration practices support fair customer outcomes and encourage ongoing servicing throughout the duration of participating policies. 4 . IA Shares Key Observations and Best Practices from Recent Onsite Conduct Inspections On 29 May 2026, the Insurance Authority issued a circular to share key observations from its recent onsite conduct inspections of authorized insurers. The circular, addressed to Chief Executives and Key Persons in the Intermediary Management Control Function, aims to highlight positive practices, identify common areas requiring improvement, and recommend measures to strengthen compliance and operational resilience. The detailed findings are set out in the accompanying Annex , which covers a wide range of areas including corporate governance and culture, recruitment and onboarding of agents and broker companies, training, remuneration structures, financial needs analysis, premium collection, cooling-off and policy delivery, claims handling, gift offerings, orphan policy management, and policy replacement. The IA emphasises that onsite inspections serve both as a backward-looking verification of compliance and a forward-looking assessment of controls. It encourages insurers to treat the findings constructively, noting that “prevention is always better than cure”. Summary of the Annex Content: Area Common Issues Identified Recommended Focus Areas Corporate Governance & Culture Siloed mindset, weak tone from the top, reactive oversight Strengthen shared accountability and culture metrics Remuneration Structures Misaligned incentives, inadequate monitoring of commission ratios Align structures with fair customer treatment principles Financial Needs Analysis Benefit illustrations generated before FNA, undocumented deviations Enforce system controls and proper documentation Claims Handling Communication gaps with policyholders, delays in disputed claims Set clear timelines and improve claimant updates Orphan Policies & Replacements Delayed assignments, weak monitoring thresholds Implement proactive assignment and aggregated review processes SIGNIFICANCE: This circular provides insurers with a valuable consolidated view of the IA’s current supervisory focus following onsite inspections. Firms should treat the Annex as a practical self-assessment tool and review their policies, procedures, and controls against the common findings and recommended best practices outlined. Particular attention should be given to areas with direct impact on customer outcomes, such as remuneration alignment, financial needs analysis quality, and claims handling efficiency. Insurers that proactively address the gaps highlighted in the report will be better positioned to strengthen their compliance framework and demonstrate a robust culture of fair treatment to the regulator. [End of ComplianceOne Insurance Newsletter – Jun 2026] For more details, please click on the title of the topic above. ================================= ~ Make It Right Today, Better Tomorrow ~ ================================= The Newsletter is for general information purpose only and is not intended to constitute legal or other professional advice. For enquiries, please email to support@complianceone.hk or WhatsApp us at (852) 95164607 . Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong Tel: (852) 3955 0277 www.complianceone.hk