The topics discussed in this monthly newsletter for insurance are as follows: ComplianceOne Newsletter – September 2025 The topics discussed in this monthly newsletter are as follows: REGULATORY UPDATES NASDAQ is pioneering in launching tokenization of stocks SFC consults on extending investor identification regime to exchange-traded derivatives in Hong Kong MARKET NEWS Hong Kong’s securities industry saw continued earnings growth and record transactions in first half of 2025 Only a limited number of licenses will be granted by the HKMA amid 77 applications received for Stablecoin Issuers SFC and Dubai Financial Services Authority bolster ties in supervising cross-border investment management SFC and HKMA unveil roadmap to advance Hong Kong’s vision to be global fixed income and currency hub ENFORCEMENT NEWS SFC Bans Former UBS Advisor Suen Kin-wing for Life Over Money Laundering and Contempt Convictions SFC Bans Former Citigroup Executive Richard Charles Heyes for 5 Years Over Serious Misconducts SFC Reprimands and Fines Instinet Pacific Limited $8 Million for Cross Trade Reporting Failures SFC Upholds Fine on RaffAello Capital for Sponsor Failures in Paprika Listing SFC Reprimands and Fines Roofer Securities $2.1 Million for Client Money Mishandling SFC Secures Disqualification Orders Against Five More Former Directors of Superb Summit Due to misappropriate assets SFC Suspends Former Agg. Asset Management RO Chow Tsz Lam for 12 Months Over Fund Mismanagement SFC Pursues Disqualification Orders Against Former Directors of Century Energy International Holdings Limited Regulatory Updates 1. NASDAQ is pioneering in launching tokenization of stocks In less than two years, the tokenized securities market experienced almost “explosive” growth with on-chain stocks surging from less than 5 million dollars starting from 2024 to 0.42 billion, a more than 80 times increase in two years. The driving wave is originated from the collective entry and accelerated layout of enterprises; both crypto-native companies and traditional financial giants are striving to tap the advantage of being the first-mover in the emerging circuit of tokenized stocks. These moves not only set off a race between crypto and traditional finance, but also a potential “revolution” against the traditional exchange model. Nasdaq, being the world’s second-largest exchange, took the initiative to incorporate tokenized stocks attempting to push itself to be the pioneer in the Wall Street. Some key takeaways we need to know about the moves by NASDAQ: Tokenized stocks are not new stuff, they are new “packaging” for the traditional equity, namely, to connect blockchain’s bookkeeping and settlement capabilities on top of existing financial infrastructure. The appeal of tokenization is that it touched several “core pain points” in the capital market and provide quick solution with: (i) settlement efficiency, (ii) transaction time and accessibility, (iii) programmability of assets. With the completion of the Depository Trust Company (“DTC”) upgrade, and the on-chain settlement function early in Q3 next year, there will already be parallel run of cryptocurrency stocks and traditional stocks this year. SIGNIFICANCE: NASDAQ has officially submitted an application for tokenized Stocks trading with the SEC, a “core attempt” by Wall Street in the digitalization process. The core of this proposal is that tokenized stocks should enjoy exactly the same rights and protections as their underlying securities , transaction matching is still carried out in the existing order book, and DTC is responsible for minting equivalent tokens on the chain. As the CEO of NASDAQ has said, “ Blockchain technology offers unprecedented possibilities for shortening settlement cycles, modernizing proxy voting, and automating corporate actions .” To put in simple words, NASDAQ is not trying to do away with the old order, but rather to upgrade the underlying structure of the market with minimal impact and to ensure that the core principles of investor protection and market transparency remain intact . 2. SFC consults on extending investor identification regime to exchange-traded derivatives in Hong Kong The SFC launched a consultation on 22 September 2025 on the proposed investor identification regime for the exchange-traded derivatives market (“ HKIDR-DM ”) which is expected to further consolidate and reinforce the integrity and sustainable development of Hong Kong’s exchange-traded derivatives markets, while a tentative schedule for implementation is in the first quarter of 2028. The proposed HKIDR-DM was established and based on the successful implementation of the similar regime for the securities markets, i.e. the HKIDR-S (the Hong Kong investor identification regime for securities markets). The scope of the HKIDR-DM comprises of order submissions for futures contracts, options contracts and stock options traded on the trading system of the Hong Kong Futures Exchange Limited (“ HKFE ”). Key takeaways are: the regime will apply to Relevant Regulated Intermediaries (“ RRIs ”), i.e., licensed corporations (“ LCs ”) under the SFC and registered institutions (“ RIs ”) under the HKMA that trade (as principal or agent) futures and options contracts; the requirements under the proposed HKIDR-DM are analogous to those currently set out in the HKIDR-S. RRIs will be required to assign a unique “Broker-to-Client Assigned Number” (“ BCAN ”) to Relevant Clients (it basically refers to the immediate client of a RRI who maintains a trading account with the RRI) placing or intending to place orders in the futures market; RRIs must collect and submit up-to-date client identification data (“ CIDs ”) alongside the BCAN in a file (“ BCAN-CID Mapping File ”) to a central data repository maintained by Hong Kong Exchanges and Clearing Limited (HKEX), the same arrangements as the securities side; SIGNIFICANCE: As Mr. Rico Leung, the SFC’s Executive Director of Supervision of Markets has said, “t o keep up with Hong Kong’s fast-growing derivatives market and align with global best practices, the proposed extension of our investor identification regime represents a major stride in detecting irregularities and protecting investors whilst minimizing operational burden on the industry ”; and he further added that, “ our enhanced cross-market surveillance capabilities will help reinforce market integrity and investors’ confidence – both essential in solidifying Hong Kong’s sustainable development as an international financial center. ” Market News 3. Hong Kong’s securities industry saw continued earnings growth and record transactions in first half of 2025 The latest financial review of the industry issued by the SFC demonstrates a robust growth in the earnings of the securities sector with key promising figures as below: a steady growth momentum with a 14% profit increase to HKD28.9 billion amid record high securities transaction value in the first six months of 2025; a total value of transactions of all securities dealers and securities margin financiers reached a record HKD99.2 trillion in the first half of 2025, a recorded increase of 22% from Q2 of 2024 and 57% (year-over-year); the net profits of all the SEHK participants were up 34% during the previous 6 months to HKD15.6 billion. The main driving forces are attributed to the steady growth of trading commission, reduction in overheads and interest expenses; within the revenue side, the net securities income was up 23% to HKD13.6 billion and income from advising on corporate finance was up 33% to HKD2 billion! One point deserves attention is that the net profits of Category C brokers, which cater for general public and small retail investors, doubled to HKD2.5 billion, implying a holistic recovery of the brokerage business rather than being concentrated on the top category brokers. SIGNIFICANCE: As Dr Eric Yip, the SFC’s Executive Director of Intermediaries, said, “ once again, the solid performance of our licensed corporations showcases the strength and agility of our financial industry in a fast-changing business landscape , underscoring their key role in driving Hong Kong’s continued success as a top international financial centre. ” 4. HKMA to grant limited stablecoin licenses amid 77 stablecoin application Main themes of the press are that: the 77 applicants originated from a range of sectors comprising of banking, technology firms, asset manager, e-commerce platforms, payment companies and Web3 startups; only a limited number of stablecoin licenses will be issued in the initial stage; only applicants meeting strict compliance requirements will be granted approvals. Key takeaways readers should know : the Hong Kong Monetary Authority ("HKMA") would not publish the list of entities showing interests or submitting applications; and reiterated that communications with the applicants did not indicate any hints of regulatory approval; the meetings were only meant to help applicants evaluate the necessity and maturity of their issuance plans before making a formal submission; with the stablecoin licensing regime came into effect on 1 August 2025, it serves as a regulatory reference point to develop the virtual asset framework. As only a limited number of licenses will be granted, some applicants either postpone applications, partner with existing licensees or adopt alternative structures to meet the strict compliance thresholds. These adaptive adjustments amid the screening process help shape the evolving regulatory regime of the nascent stablecoin ecosystem. 5. SFC and Dubai Financial Services Authority bolster ties in supervising cross-border investment management The SFC and the Dubai Financial Services Authority (“ DFSA ”), the independent regulator of the Dubai International Financial Centre (“ DIFC ”), today signed a Memorandum of Understanding (MoU) to deepen cooperation on the regulatory oversight and supervision of collective investment scheme managers in each other’s markets to ensure compliance, governance, and cross-border regulatory alignment. Key takeaways of the MOU: underscoring the significance of cross-border regulatory collaboration and Hong Kong’s growing ties with the Belt and Road jurisdictions; establishing a collaborative framework for consultation, cooperation and the exchange of information in order to enhance the regulators’ supervision and oversight of regulated entities which engage in cross-border investment management or advisory activities; signifying the efforts of joint collaboration of the high-level meetings between the SFC and the DFSA over the years. SIGNIFICANCE: As comments from SFC and DFSA officials, the MOU is a consequence of strengthened SFC-DFSA partnership which underscores the shared commitment to mutual benefits of HK and DIFC as internation financial hubs, and efforts towards regulatory excellence, supervision and cross-border innovation between the two jurisdictions. 6. SFC and HKMA unveil roadmap to advance Hong Kong’s vision to be global fixed income and currency hub The SFC and the HKMA jointly announced Hong Kong’s Roadmap for the Development of Fixed Income and Currency (“ FIC ”) Markets (the “ Roadmap ”) on 25 September 2025 to position the city strategically as a global FIC hub by fostering demand, liquidity and innovation. An overview of the Roadmap is outlined as below with FOUR pillars and TEN initiatives: Reinforcing Foundations Pillar 1: Boosting issuance in primary market Initiative 1: Lead by example through government bond issuance Initiative 2: : Promote Hong Kong’s strengths to issuers and investors in target markets Initiative 3: Expand investor base including family offices, funds and corporate treasury centres Pillar 2: Enhancing liquidity in secondary market Initiative 4: Finalize implementation of over-the-counter FIC derivatives regime Initiative 5: Facilitate development of a repo central counterparty Breaking New Ground Pillar 3: Expand offshore RMB business Initiative 6: Broaden offshore RMB usage Initiative 7: Enhance Connect schemes to increase offshore RMB liquidity and RMB-related product offerings Pillar 4: Next-generation infrastructure Initiative 8: Future-proof FIC financial market infrastructure Initiative 9: Support development of next-generation electronic trading platforms Initiative 10: Facilitate market innovation and implementation of use cases for tokenized FIC products SIGNIFICANCE: The Roadmap will guide the policy making and implementation of the SFC and the HKMA in coming years to support the sustainable and diversified growth of Hong Kong’s capital markets. Comments from key officials highlight the significance of the Roadmap: Dr. Kelvin Wong, Chairman of the SFC: “ The Roadmap is poised to guide our marketevolution that will benefit issuers, investors and intermediaries alike for years to come ”. Mr. Eddie Yue, Chief Executive of the HKMA: “ The Roadmap comprehensively set out our work focuses in the near future . We look forward to implementing the initiatives in collaboration with industry stakeholders. ” Ms. Julia Leung, Chief Executive Officer of the SFC: “ The Roadmap reflects our close collaboration and shared commitment with the HKMA, industry partners and other stakeholders to enhance Hong Kong’ s vital role in bridging Mainland and international capital markets .” Enforcement News 7. SFC Bans Former UBS Advisor Suen Kin-wing for Life Over Money Laundering and Contempt Convictions On 2 September 2025, the SFC has imposed a lifetime ban on Mr. SUEN Kin-wing (“ SUEN ”), a former Associate Director at UBS AG (“ UBS ”), preventing him from re-entering the industry. This action follows SUEN's criminal convictions for money laundering and contempt of court, highlighting serious breaches of trust and regulatory standards. Background of the Case SUEN, who served as a Client Advisor at UBS from January 2014 to June 2018, was responsible for Type 1 and Type 4 regulated activities. The issues stemmed from his dealings with two Mainland Chinese clients who held a joint account at UBS. Facing challenges in transferring RMB funds from Mainland China to Hong Kong, the clients entered into an arrangement with SUEN to facilitate cross-border transfers. Under this setup, the clients deposited over RMB132 million into Mainland bank accounts designated by SUEN between November 2016 and February 2018. SUEN provided what appeared to be legitimate transaction confirmations and bank statements showing the funds had reached the joint account. However, the clients later discovered that a substantial portion of the money was missing. Investigations revealed that over HK$134 million had been diverted into two Hong Kong bank accounts controlled by SUEN. The Court determined these funds were proceeds of crime, as SUEN had defrauded or stolen them from his clients. He used the misappropriated money to fund a luxurious lifestyle, including purchases of high-end vehicles and properties in the UK and Mainland China. Legal Outcomes Charge(s) Remarks Case No. Money Laundering Conviction On June 21, 2024, the Court of First Instance sentenced SUEN to 10 years' imprisonment after he pleaded guilty to two counts of dealing with property known or believed to represent proceeds of an indictable offense. HCCC 77/2021 Contempt of Court In July 2018, the clients secured a worldwide freezing injunction against SUEN to recover the stolen funds, prohibiting him from disposing of assets up to HK$130 million. Despite this, SUEN transferred his interests in several UK properties to a British Virgin Islands (BVI) company he owned, violating the order. On 20 December 2023, he was sentenced to six months' imprisonment for contempt. HCMP 633/2019 SIGNIFICANCE: Given the severity of SUEN's actions, which demonstrated a profound lack of honesty and professionalism, the SFC has deemed him unfit and improper to hold any regulated position in the future. SUEN is currently neither registered with the Hong Kong Monetary Authority (“ HKMA ”) nor licensed by the SFC. This case serves as a stark reminder of the consequences of financial misconduct and the SFC's zero-tolerance policy toward activities that undermine market confidence. Industry professionals are encouraged to review internal controls and compliance measures to prevent similar incidents. 8. SFC Bans Former Citigroup Executive Richard Charles Heyes for 5 Years Over Serious Misconducts In a significant move underscoring the importance of senior management accountability, the SFC has imposed a five-year industry ban on Richard Charles Heyes (“ Heyes ”), a former key figure at Citigroup Global Markets Asia Limited (“ CGMAL ”). Effective from 15 September 2025 to 14 September 2030, the ban prevents Heyes from re-entering the financial industry in any licensed capacity. Heyes, who served as a RO, Manager-In-Charge (“ MIC ”) of Key Business Line, board member, and Head of Pan-Asia Equities at CGMAL, has been held accountable for serious regulatory breaches and internal control lapses at the firm. These issues stem from a decade-long period (i.e. 2008–2018) where CGMAL's Cash Equities business disseminated mislabelled Indications of Interest (“ IOIs ”) and made misrepresentations to institutional clients during facilitation trades. Key Details of the SFC's Findings: The SFC's investigation highlighted Heyes' failure to fulfill his supervisory and managerial duties, which directly contributed to CGMAL's violations. Specifically: 1. Mislabelled IOIs Heyes overlooked practices at the Equities Sales Trading Desk where IOIs were falsely labelled to elicit client inquiries. Despite a 2014 SFC review flagging concerns with CGMAL's IOI processes, Heyes did not implement adequate controls. Additionally, between 2017 and 2018, he received reports of client complaints about IOI accuracy but took no action to investigate or halt the misconduct. 2. Misrepresentations in Facilitation Trades In 2014, Heyes attended an SFC roundtable that SFC emphasized the need for explicit client consent and pre-trade disclosures for facilitation trades. However, he failed to ensure CGMAL had proper guidelines or monitoring in place. Emails forwarded to him revealed traders disguising facilitation trades as agency trades to boost market share, but these went unaddressed. These lapses allowed a culture prioritizing revenue over client interests and ethical standards to persist within CGMAL. The SFC emphasized that Heyes' neglect enabled the firm's internal control failures to continue unchecked for over ten years. Factors Influencing the Sanction In determining the five-year ban, the SFC considered: The severity of Heyes' neglect, which enabled prolonged regulatory breaches. His extensive industry experience, which should have ensured higher standards as an RO, MIC, board member, and senior manager. The need to send a strong deterrent message to the industry. Mitigating factors, including Heyes' cooperation with the SFC, withdrawal of his appeal to the Securities and Futures Appeals Tribunal, and his otherwise clean disciplinary record. This action follows prior SFC sanctions against CGMAL itself for the same underlying issues. For more details of the case, please refer to the Statement of Disciplinary Action . SIGNIFICANCE: Christopher Wilson, SFC's Executive Director of Enforcement, stated: "Senior management of a licensed corporation bears primary responsibility for ensuring the firm’s maintenance of appropriate standards of conduct and adherence to proper procedures. By exerting significant pressure on the trading desks to grow CGMAL’s market share while failing to be vigilant for telltale signs that his subordinates were achieving this by dishonest means, Heyes neglected and failed to properly discharge his managerial responsibility." Wilson added that the SFC will actively use the MIC regime to hold senior executives accountable, aiming to foster cultural and behavioral changes among intermediaries. This case serves as a stark reminder for financial institutions in Hong Kong and beyond: Senior leaders must prioritize robust compliance frameworks, vigilant oversight, and ethical practices. With regulators increasingly focusing on individual accountability, firms should review their internal controls, training programs, and escalation procedures to prevent similar failures. 9. SFC Reprimands and Fines Instinet Pacific Limited $8 Million for Cross Trade Reporting Failures The SFC has issued a reprimand and imposed an $8 million fine on Instinet Pacific Limited (Instinet) for non-compliance with reporting requirements for direct business transactions, commonly known as cross trades, to The Stock Exchange of Hong Kong Limited (“ SEHK ”). Key Details of the Case The SFC's investigation uncovered that from December 2012 to March 2018, Instinet failed to report 8,817 pairs of cross trades totalling approximately $25.9 billion in value between its clients and an affiliated company. This breach violated the Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission. During this period, Instinet lacked any internal policies, procedures, or monitoring mechanisms for reporting cross trades to the SEHK, and it conducted no reviews of its trade reporting processes. Scope of the Breach: The unreported trades spanned over five years and involved significant transaction volumes, highlighting systemic deficiencies in Instinet's compliance framework. Code and Rule Violations: The failures contravened the SFC's Code of Conduct and Rules of the Exchange, which mandates proper cross trades reporting. In deciding the disciplinary sanction, the SFC has taken into account all relevant circumstances, including the duration of Instinet’s failure, the number of unreported cross trades and the sum involved, and Instinet’s initiative to cease the relevant trade flows and cooperation with the SFC in resolving the SFC’s concerns. For more details of the case, please refer to the Statement of Disciplinary Action . SIGNIFICANCE: This enforcement action reinforces the SFC's commitment to upholding market transparency through strict adherence to reporting obligations. Financial institutions must prioritize robust internal controls, regular reviews, and comprehensive policies to monitor trade reporting. Failures in these areas can lead to significant penalties and reputational damage. Firms are encouraged to audit their compliance systems, particularly for cross trades and affiliated transactions, to align with SEHK and SFC standards. 10. SFC Upholds Fine on RaffAello Capital for Sponsor Failures in Paprika Listing In a recent decision, the Securities and Futures Appeals Tribunal (“ SFAT ”) has affirmed the SFC reprimand and $4 million fine against RaffAello Capital Limited (“ RaffAello ”) for shortcomings in its role as sponsor for Paprika Holdings Limited's Paprika listing application. This case underscores the critical importance of rigorous due diligence in Hong Kong's capital markets, highlighting lapses that could undermine investor confidence. Background on the Case RaffAello, a licensed corporate finance advisor, sponsored Paprika's application for listing on the Growth Enterprise Market (“ GEM ”) of the Stock Exchange of Hong Kong Limited ("SEHK"), submitted in June 2017 but withdrawn in April 2018. Paprika, a handbag and accessories retailer, relied heavily on retail sales, accounting for about 90% of its revenue in the two financial years ending March 2017, with over 80% from physical stores. The SFC's investigation revealed that RaffAello failed to conduct reasonable due diligence and lacked professional scepticism when reviewing Paprika's provided information. Key issues centered on suspicious retail transactions and questionable relationships with key business partners. Key Findings Failings in Retail Sales Due Diligence During a sample walkthrough of retail store transactions from 19 February to 13 March 2016, RaffAello uncovered several red flags: Approximately 230 consecutive cash transactions across stores, involving 1,431 handbags, made up 90% of cash sales and 42% of total sales on those dates. Many occurred within 1-10 minutes. Around 240 bulk credit card purchases of 1,860 handbags by individuals, including owners of Paprika's wholesaler and suppliers, accounting for 83% of credit card sales and 45% of total sales. Invoices marked "POS Test" (point-of-sale system testing) were included in sales records. Despite inquiries, RaffAello largely accepted explanations from Paprika and involved parties without deeper scrutiny. The SFC noted overlooked indicators suggesting potential fabrication to inflate sales figures. Inadequate Scrutiny of Key Partners RaffAello also fell short in verifying the independence of Paprika's largest wholesaler, Novi eBusiness Limited (“ Novi ”) (responsible for over 90% of a 96% wholesale revenue surge from 2016 to 2017), and its fifth-largest supplier, API Trading Company Limited (“ API ”) (part of suppliers accounting for 53.4% of 2017 purchase costs). Red flags included: Bovi and API both were former subsidiaries of a company linked to a 15% Paprika shareholder. Acquisitions facilitated by Paprika's founder, Chairman, and CEO, Mr. Samuel Leung ("Leung"). Novi's owner partnered with Mainland Chinese firms tied to Leung's authorized payment recipients. Owners of both entities made repeated bulk purchases from Paprika stores. Additionally, RaffAello did not sufficiently probe API's business substance, especially after discovering it acted as an intermediary for a pre-existing supplier (i.e. Lung Yiu), with supplies jumping from $41,000 in 2016 to $3.18 million in 2017. SIGNIFICANCE: The SFC initially proposed a $13 million fine but reduced it to $4 million due to RaffAello's financial constraints, a decision the SFAT upheld to avoid liquidation and harm to clients. Chaired by Mr. Michael Hartmann, GBS, the Tribunal emphasized sponsors' duties under the Code of Conduct: when red flags arise, additional due diligence is mandatory, including detailed documentation and consultations (e.g., with reporting accountants) rather than assumptions. The Tribunal noted: "If issues of concern are identified, it is not sufficient for the sponsor simply to investigate the matter, make a bald note of that fact... a coherent note should be made of what has been discovered and what has been resolved." Over-reliance on management's representations was deemed unreasonable. Related actions include a two-year industry ban for Mr. Tsang Kwong Fai , RaffAello's responsible officer overseeing the application. This ruling serves as a stark reminder for sponsors to apply professional scepticism and thorough investigations. It reinforces SFC's commitment to maintaining listing integrity, potentially influencing future due diligence practices in Hong Kong's vibrant IPO market. 11. SFC Reprimands and Fines Roofer Securities $2.1 Million for Client Money Mishandling The SFC has issued a reprimand and imposed a $2.1 million fine on Roofer Securities Limited ("Roofer") for violations related to the improper handling of client funds. This action highlights the SFC's ongoing commitment to enforcing strict segregation rules to protect investor assets in Hong Kong's financial markets. Case Overview The investigation, initiated following a referral from the Hong Kong Exchanges and Clearing Limited (“ HKEX ”), uncovered 12 incidents between 8 February 2021, and 7 July 2022, where Roofer failed to maintain adequate funds in its segregated client account. In one notable instance, the shortfall reached $15.5 million. These breaches stemmed from several operational lapses: Using client account funds to cover margin calls (actual or anticipated) from HKEX which is not paid in accordance with a written direction or standing authority form the client and/or used to meet the client’s settlement or margin requirement. Failure in client money segregation due to inadequate management of daily online bank transfer limits. Human errors by staff. The SFC determined that these failures violated the Securities and Futures (Client Money) Rules and the Code of Conduct for Persons Licensed by or Registered with the SFC. Mitigating Factors and Sanctions In determining the penalty, the SFC considered various factors, including: No clients suffered financial losses due to the incidents. Roofer promptly rectified the under-segregation in each case and implemented remedial measures, such as strengthening internal controls and processes. The firm's full cooperation with the SFC during the investigation. Roofer's clean prior disciplinary record. For more details of the case, please refer to the Statement of Disciplinary Action . SIGNIFICANCE: This case serves as a reminder to licensed corporations of the critical need for robust internal systems to ensure client money segregation. Failures in this area can erode market trust and expose firms to significant regulatory penalties. The SFC's balanced approach factoring in remediation and cooperation, demonstrates its focus on proportionate enforcement while upholding high standards. 12. SFC Secures Disqualification Orders Against Five More Former Directors of Superb Summit Due to misappropriate assets The SFC has successfully obtained disqualification orders from the Court of First Instance against an additional five former directors of Superb Summit International Group Limited (“ Superb Summit ”), bringing the total number of disqualified directors to 10. This latest action emphasizes the SFC's rigorous enforcement of director duties in cases involving misleading acquisitions and non-existent assets. This follows earlier disqualifications in June 2025 against five other former directors: Mr. Lee Chi Kong (10 years), Mr. Wong Yun Kuen (7 years), and Messrs. Lam Ping Kei, Wong Choi Fung, and Yeung Kwong Lun (5 years each). The SFC's investigations and proceedings against additional former directors and officers of Superb Summit continue. Director(s) involved: Director(s) Disqualifications Mr. Chan Chi Yuen (“ CHAN ”) 4 Years Mr. Law Wai Fai (“ LAW ”); and Mr. Cheng Man (“ CHENG ”) 3.5 Years each Mr. Qiu Jizhi (“ QIU ”) 3 Years Mr. Li Jun (“ LI ”) 2.5 Years Details of the Breaches Superb Summit, listed on the Main Board of The Stock Exchange of Hong Kong Limited from September 2001 until its delisting in June 2020, engaged in two problematic acquisitions: 2007 Acquisition : LAW, LI, QIU, AND CHAN failed to adequately review key documents or critically assess the methodologies and assumptions used by professionals during due diligence on the target company's alleged forestry assets. 2009 Acquisition : LAW, CHENG, AND CHAN neglected to properly verify the ownership of the claimed forestry assets. They also approved a company announcement containing false or misleading information about these non-existent assets. The SFC initiated proceedings under section 214 of the Securities and Futures Ordinance in December 2020. The disqualifications were resolved via the Carecraft procedure, where the court approved orders based on agreed facts and proposed sanctions. Overview of the Disqualifications The affected individuals include three former executive directors, LAW, LI and CHENG and two former independent non-executive directors, QIU and CHAN. The orders, effective immediately, prohibit them from serving as directors or participating in the management of any corporation in Hong Kong or elsewhere for periods ranging from two and a half to four years. Additionally, the former directors have been ordered to cover the SFC's costs in the proceedings. These sanctions follow their admissions of breaching duties and negligence related to Superb Summit's acquisitions in 2007 and 2009, which involved purported forestry assets that proved to be fictitious. **For the detail of judgment and the prior disqualifications, please refer to: - the Judiciary’s website (Case No. HCMP 2305/2020 ); or - the SFC’s press release dated 11 July 2025 ,.** SIGNIFICANCE: These orders reinforce the SFC's stance on accountability for directors, particularly in due diligence and disclosure processes. They highlight the severe consequences of negligence in approving transactions with misleading elements, serving as a cautionary tale for boards in Hong Kong's listed companies to uphold rigorous standards to protect investors and maintain market integrity. 13. SFC Suspends Former Agg. Asset Management RO Chow Tsz Lam for 12 Months Over Fund Mismanagement The SFC has suspended Mr. CHOW Tsz Lam (“ CHOW ”), a former RO and manager-in-charge at the now-dissolved Agg. Asset Management Limited (“ Agg ”), for 12 months effective from 2 September 2025, to 1 September 2026. This disciplinary measure addresses failures in fund management practices that exposed investors to undue risks and conflicts of interest. Investigation Findings The SFC's probe revealed that Agg, acting as investment manager for a Cayman-incorporated fund, allocated up to 100% of the fund's assets into debentures issued by entities controlled by Mr. NG Ka Shun (“ NG ”), Agg's sole shareholder, director, and fellow RO. This approach neglected to mitigate conflicts of interest and adequately manage associated risks (concentration risks and credit risks). Furthermore, Agg directed the fund into two debentures seemingly designed to artificially inflate the fund's net asset value. CHOW, as an RO and senior management member, was found to have fallen short in ensuring Agg operated in the best interests of the fund and its investors, while adhering to regulatory standards. Although primary responsibility lay with NG (who made the investment decisions), CHOW's oversight lapses contributed to these breaches. For more details of the case, please refer to the Statement of Disciplinary Action . SIGNIFICANCE: This case underscores the SFC's emphasis on robust conflict management and risk oversight in asset management, particularly where personal interests intersect with firm operations. It serves as a reminder for ROs and senior executives to prioritize investor protection and regulatory compliance, with self-reporting potentially mitigating penalties. The SFC previously issued a lifetime ban and $1.7 million fine to NG for window-dressing Agg's financial resources and mismanaging two funds (see SFC press release dated 23 December 2024 ). Agg itself faced a restriction notice in April 2020 prohibiting regulated activities, leading to its dissolution in July 2024 and deemed license revocation. 14. SFC Pursues Disqualification Orders Against Former Directors of Century Energy International Holdings Limited The SFC has initiated legal proceedings to seek court orders disqualifying four former directors of Century Energy International Holdings Limited ("CEIHL", formerly known as China Oil Gangran Energy Group Holdings Limited). The action targets individuals accused of misconduct that led to substantial financial losses for CEIHL. Background on CEIHL CEIHL, listed on the Growth Enterprise Market of the SEHK since 18 May 2011, was primarily involved in trading refined oil and methyl tert-butyl ether, as well as manufacturing and selling power and data cords. CEIHL's troubles stem from the loss of control over four major operating subsidiaries in Mainland China, which accounted for over 80% of its total revenue for the year ended 31 March 2018, and more than 40% of its total assets as of that date. These subsidiaries were deconsolidated from CEIHL's accounts effective 1 January 2019, resulting in a staggering loss of $184 million for the fiscal year ended 31 March 2019. Allegations of Misconduct The SFC alleges that these former directors failed to adequately supervise the Mainland subsidiaries and did not act in the best interests of the company. This prolonged lack of oversight contributed to the deconsolidation of the subsidiaries and the ensuing financial losses. Furthermore, Mr. Ho, Ms. Yang, and Mr. Lau are accused of being responsible for the publication of a 2014 circular that contained inaccurate or misleading information about one of the operating subsidiaries. Under section 214 of the SFO , the Court of First Instance may impose disqualification orders preventing individuals from serving as directors or being involved in the management of any corporation for up to 15 years if they are found responsible for conduct involving defalcation, fraud, misfeasance, or other misconduct toward the company or its members. The SFC's proceedings name the following accused directors: Mr. Gregory Ho Chun Kit (“HO”) Former executive director. Mr. Zheng Jian Peng (“ZHENG”) Former executive director, chief financial officer, and company secretary. Ms. Eugenia Yang (“YANG”) Former independent non-executive director. Mr. Vincent Lau Sung Tat (“LAU”) Former independent non-executive director. The SFC alleges that these former directors failed to adequately supervise the Mainland subsidiaries and did not act in the best interests of CEIHL. This prolonged lack of oversight contributed to the deconsolidation of the subsidiaries and the ensuing financial losses. Furthermore, HO, YANG, and LAU are accused of being responsible for the publication of a 2014 circular that contained inaccurate or misleading information about one of the operating subsidiaries. Under section 214 of the SFO , the Court of First Instance may impose disqualification orders preventing individuals from serving as directors or being involved in the management of any corporation for up to 15 years if they are found responsible for conduct involving defalcation, fraud, misfeasance, or other misconduct toward the company or its members. SIGNIFICANCE: This case highlights the SFC's commitment to enforcing corporate governance standards and holding directors accountable for oversight failures in Hong Kong-listed companies. Investors in Hong Kong-listed companies should note the potential risks associated with operations in cross-border subsidiaries and the importance of robust internal controls. 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The topics discussed in this monthly newsletter are as follows: ComplianceOne Newsletter - May 2024 The topics discussed in this monthly newsletter are as follows: 1. Dagong Global Hong Kong Limited succeeded in acquiring the Type 10 license of “Providing Credit Rating Services” 2. SFC announces the end of non-contravention period for virtual asset trading platforms 3. SFC welcomes industry-led public consultation on voluntary code of conduct for ESG ratings and data products providers 4. SFC facilitates broadening of master-feeder ETFs offerings in Hong Kong 5. SFC suspends Wong Ka Ching for four years for his negligence as an RO 6. Market manipulators convicted of false trading activities in landmark High Court jury trial MARKET NEWS 1. Dagong Global Hong Kong Limited succeeded in acquiring the Type 10 license of “Providing Credit Rating Services” ComplianceOne Consulting Limited (“ CO ”) has assisted Dagong Global Hong Kong Limited (" DGHK ", CE Number: BUK036), the wholly-owned Hong Kong subsidiary of Dagong Global Credit Rating Co., Ltd.'s (" Dagong Global "), in successfully applying for Type 10 license of “Providing Credit Rating Services” under the SFC. Dagong Global has become the only licensed corporation (“LC”) approved by the SFC for the Type 10 License in the past four years, and is also the 9th LC accredited with Type 10 license in Hong Kong as well as the 4th credit rating company originated from mainland China. As a compliance consultant, CO has provided DGHK with its professional, comprehensive and bespoken consultancy services, including design of the application, and corresponding internal control process, together with seasoned compliance advisory services in addressing queries from SFC amid the application process. SIGNIFICANCE: This event signifies an emblem of success of CO in proliferating its licensing advisory services to non-traditional licensing regimes. 2. SFC announces the end of non-contravention period for virtual asset trading platforms On 28 May 2024, the SFC kindly reminded the virtual asset trading platforms (VATP) of the end of the non-contravention period on 1 June 2024, after which ALL VATPs operating in HK must either be licensed by the SFC, or “ deemed-to-be-licensed” VATP (“DTBL-VATP”) applicants under the AMLO. To facilitate the transition and avoid ambiguities, there are reminders to both investors and DTBL-VATPs as below: Reminder for investors (1) Investors are urged to trade virtual assets (VAs) ONLY on SFC-licensed VATPs , where reference can be made from “ List of licensed virtual asset trading platforms ” on SFC website. (2) Investors are reminded that DTBL-VATP applicants are NOT formally licensed by the SFC yet; they still have to demonstrate to the SFC of their competence before formal approval be granted. Reminder to DTBL-VATP applicants (3) DTBL-VATP applicants must fully comply with all of the SFC’s regulatory and licensing conditions; and are expected NOT to actively market their services or solicit any new clients prior to demonstrating the actual implementation and effectiveness of their policies, procedures, systems and controls to the satisfaction of the SFC and being formally licensed. (4) The SFC also reminds all VATPs and their ultimate owners, controlling entities of the compliance of all applicable laws and regulations, including but without limitation, preventing Mainland Chinese residents from accessing any of their virtual asset-related services . (5) The deeming arrangement serves to strike a balance between protecting investors and facilitating market development. DTBL-VATP applicants should bear in mind that it is merely a temporary arrangement whereby any non-compliance will result in refusal of the license application by the SFC swiftly. (6) In the coming months, the SFC will conduct on-site inspections to the DTBL-VATP applicants to ascertain they are in compliance with the regulatory requirements, with a particular focus on their measures in safeguarding client assets and KYC process. SIGNIFICANCE: It should be noted with caution by all existing VATPs not yet on the list of “deemed-to-be-licensed” on 1 June 2024 to cease operation in HK, or otherwise it will constitute a breach of the AMLO as a criminal offence. The DTBL-VATP applicants are required to engage a qualified external assessor to conduct an assessment of the full implementation and effectiveness of their policies, procedures, systems and controls as demonstration to safeguard the protection of investors One reminder from the SFC which deserves extra attention is the “prevention of Mainland Chinese residents from accessing any of their virtual asset-related services" to all VATPs. 3. SFC welcomes industry-led public consultation on voluntary code of conduct for ESG ratings and data products providers On 17 May 2024, the SFC welcomed the launch of a public consultation by an industry-led working group on a voluntary code of conduct (VCoC) for environmental, social and governance (ESG) ratings and data products providers providing products and services in Hong Kong. Led by the International Capital Market Association (ICMA), the Hong Kong ESG Ratings and Data Products Providers VCoC Working Group (VCWG) modelled the draft VCoC on international best practices recommended by the International Organization of Securities Commissions (IOSCO). Key elements of the draft VCoC: (i) it is consistent with the expectations introduced in other major jurisdictions in English and Chinese versions; (ii) it includes a self-attestation document to provide information relevant to the code by the providers in a structured format to facilitate the end users, like licensed intermediaries, to compare the conduct of ESG ratings and data products providers during their due diligence and ongoing assessment processes. SIGNIFICANCE: As Ms Julia Leung, the SFC’s Chief Executive Officer, has said, “ The code, together with the self-attestation document, will be vital in fostering greater transparency, quality and reliability of ESG information, as well as comparability of products .” A set of more international-based standards in ESG ratings and data products are essential resources in furnishing common benchmarks for the market participants to adhere to with recognizable quality, reliability of the ESG information. 4. SFC facilitates broadening of master-feeder ETFs offerings in Hong Kong The SFC published a revised circular on 16 May 2024 to allow SFC-authorised feeder ETFs under master-feeder structure to invest in overseas-listed master ETFs , including actively managed ETFs, from different markets under streamlined requirements provided certain conditions are met. The asset under management (AUM) of the global ETF market continued to grow rapidly, reaching USD12.7 trillion at first quarter end of 2024. Product issuers are expressing to the SFC of their keen interest in bringing well-established actively managed ETFs from overseas to Hong Kong, potentially through the route of a master-feeder fund structure. And the SFC considers appropriate to extend the existing streamlined requirements for master ETFs to actively managed ETFs as previous exemptions apply to passively managed master ETFs only. SIGNIFICANCE: A master-feeder fund structure refers to a fund (the feeder fund) that invests 90% or more of its total net asset value in another single fund (the master fund). These funds are permitted under the Code of Unit Trusts and Mutual Funds provided that both the feeder-fund and master-fund are authorized by the SFC (previous requirement). Actually, the SFC has been streamlining the requirements since December 2019 to allow SFC-authorized feed ETF to invest in an eligible overseas-listed master ETF without SFC authorization on a case-by-case basis. As Ms Christina Choi, SFC’s Executive Director of Investment Products, has said, “ Further streamlining the requirements for master-feeder ETFs will bring cost-saving and provide flexibility to ETF issuers, and broaden investment choices for investors, whilst ensuring appropriate level of investor protection remains in place. ” ENFORCEMENT NEWS 5. SFC suspends Wong Ka Ching for four years for his negligence as an RO On 28 May 2024, the SFC has suspended Mr Wong Ka Ching, former responsible officer (RO) of China On Securities Limited (China On), for four years from 28 May 2024 to 27 May 2028. The SFC considered China On’s failures was due to Wong’s consent or connivance, or were attributable to his negligence as an RO and a member of the senior management. The SFC also found that Wong acted in gross negligence or recklessly in handling the share placement and failed to ensure the maintenance of appropriate standards of conduct and adherence to proper procedures by China On. It was also found that Wong: · allowed an individual , a purported consultant of China On, to be heavily involved in the operations of China On without ensuring that he was fit and proper or otherwise qualified to act in such capacity; · disclosed confidential contents of the SFC’s investigation to this individual; and · knowingly provided false or misleading information to the SFC about the same individual. SIGNIFICANCE: As the concluding remark by SFC, it was pointed out that Wong had disclosed confidential contents of the SFC’s investigation to this same individual and acting dishonestly by furnishing false information to SFC, a four-year suspension of license was to deliver a message of deterrent to the industry that disclosure of the details about the SFC’s investigation and negligence of conduct will not be tolerated! 6. Market manipulators convicted of false trading activities in landmark High Court jury trial On 29 May 2024, the Court of First Instance today convicted three individuals, Ms SIT Yi Ki, Ms LAM Wing Ki and Mr TAM Cheuk Hang of conspiracy to carry out false trading in the shares of Ching Lee Holdings Limited (Ching Lee) following an historic 22-day market manipulation trial by jury. This is a highly sophisticated and complex market manipulation case and the criminal prosecution was brought by the Department of Justice following extensive investigations by the SFC. This also marks the first time that an offence under the Securities and Futures Ordinance (SFO) has been tried at the Court of First Instance. The prosecution stemmed from the SFC’s investigations which revealed that, between the seven months from March 2016 to September 2016, SIT, LAM and TAM conspired together with Ho Ming Hin, Simon Suen Man and other unknown persons to carry out a complex scheme of market manipulation. Through conducting manipulative transactions among 156 securities accounts, they created false and misleading appearance of active trading, and it lasted for more than five months with illicit profits of over HKD124 million. SIGNIFICANCE: The SFC’s Executive Director of Enforcement, Mr Christopher Wilson, said: “ We welcome the verdicts by the jury. The outcome of this case sends a strong deterrent message on the legal consequence of undermining the integrity of Hong Kong’s securities markets and the confidence of the investing public.” And Mr Wilson further added that “ the successful prosecution of these manipulators is the latest in the SFC’s all-out efforts to combat market misconduct and other forms of financial crime in Hong Kong. ” 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

Deficiencies and substandard conduct noted in the management of private funds and discretionary accounts Compliance Impact Alert: Deficiencies and substandard conduct noted in the management of private funds and discretionary accounts Nov 2024 Disclaimer: Contents contained in this document including should not be regarded as a substitute legal and / or compliance advice in any circumstances and shall not be reproduced (in whole or in part), distributed or otherwise passed on to any other person without our prior written consent. Language: English version only Executive Summary The recent circular " Circular to licensed corporations engaged in asset management business: Deficiencies and substandard conduct noted in the management of private funds and discretionary accounts " issued by the Securities and Futures Commission (“SFC”), identifies critical deficiencies and misconduct within the asset management sector. The SFC's findings in appendix part reveal a pressing need for asset managers to strengthen their governance frameworks and compliance mechanisms. This summary serves as an important reminder for asset managers to uphold integrity, transparency, and compliance with regulatory standards. Key Regulatory Concerns: Conflicts of Interest Poor management of conflicts of interest, leading to decisions that favor personal or related interests over those of investors. Risk Management Deficiencies Ineffective risk management procedures, exposing investors to significant risks, including concentration and liquidity risks. Insufficient Investor Communication Inadequate information provided to investors regarding fund performance and risks, hindering informed decision-making. Improper Valuation Practices Use of inappropriate valuation methodologies, obscuring true investment losses and compromising transparency. Non-Compliance with Regulatory Requirements Breaches of the SFC’s Code of Conduct, FMCC, and Internal Control Guidelines, indicating systemic issues within asset management practices. Senior Management Accountability Emphasis on the responsibility of senior management to ensure adherence to standards of conduct and effective compliance programs. How We Can Help ComplianceOne possess extensive experience in the asset management industry and are well-equipped to provide valuable guidance to asset managers in several key areas. Our expertise ensures adherence to regulatory standards and enhances overall compliance practices. Continuous Support: Stay ahead of regulatory changes with our continuous monitoring and updates, ensuring that you are always in compliance. Expert Guidance: Benefit from our deep industry expertise and experience, providing you with valuable insights and best practices for managing your assets. Enhanced Governance: Strengthen your governance frameworks with our tailored solutions, enhancing your operational integrity and investor confidence. Proactive Risk Management: Identify and mitigate potential risks before they impact your business with our proactive risk management strategies. Comprehensive Training: Ensure your team is always up-to-date with the latest regulatory requirements and best practices through our ongoing training programs. Peace of Mind: Focus on your core business activities while we take care of your compliance and risk management needs, providing you with peace of mind. By using our ongoing compliance service, asset managers can enhance accountability, ensure compliance with regulatory standards, and protect investors' interests. It is crucial for asset managers to critically evaluate their existing frameworks and make necessary adjustments to align with regulatory expectations. For any inquiries, please refer to our Ongoing Compliance Support Service or feel free to Contact us .

2022年5月26日，政信產業聯盟與中國政信國際開發集團有限公司聯合舉辦的「跨境投融資實務操作系列講座之香港金融牌照優勢解析」在線上成功 聚焦出海之路|「跨境投融資系列講座之香港金融牌照優勢」線上成功舉辦 2022年5月26日，政信產業聯盟與中國政信國際開發集團有限公司聯合舉辦的「跨境投融資實務操作系列講座之香港金融牌照優勢解析」在線上成功舉辦。 本次講座特別邀請天匯合規顧問有限公司合夥人王陶浚先生為大家解析香港金融牌照優勢，帶來更多創富靈感和投資機會。 王陶浚先生畢業於美國堪薩斯大學工商管理與金融學系，曾任職海通國際十餘年，有全方位牌照公司運營管理經驗，並專業為客戶設計策略性規劃、提供量身企業服務方案、申請相關金融牌照服務等，具備專業、豐富的金融實操經驗。 香港作為中資企業出海的橋梁，在公開交易市場完善度、經營環境成熟度以及金融產品豐富度等層面，都處在國際金融市場的優勢地位。隨著中國經濟的快速發展，不少中資企業通過赴港開展金融業務，獲得了參與國際金融活動的機會。而後疫情時代，眾多投資者希望通過香港作為跳板投資海外市場。 王陶浚先生分別從香港金融牌照「申請概況」「申請要求」等環節，介紹了香港主要金融監管機構、金融牌照的基本情況，重點闡述了香港金融牌照的優勢。他表示，香港金融牌照具備成本低、國際背書效果強、可承接承做更多國際業務、背靠全球頂尖的資本市場的優勢。 最後，結合具體案例講解，王陶浚先生進一步講解，如何通過香港的美元債券市場，為各省市的基建項目籌集到低成本的資金；如何通過香港的金融市場，為國內高凈值的客戶進行海外資產配置及家族顧問服務等，通過對案例進行分析拆解，讓與會嘉賓對跨境投融資業務有了更加直觀具體的認識，為企業開展境外發債、拓展跨境融資渠道提供了經驗分享和專業建議。 當下，隨著「走出去」步伐加快，跨境融資是眾多中資企業拓寬融資渠道、降低融資成本、優化境內外兩個市場資源配置的「新藍海」。作為政信投資集團海外業務中心，中國政信國際開發集團有限公司，以香港地區為戰略支點，依托政信面向全球開展國際開發，發揮香港節點作用，促進「外循環」，為內地政信項目構建基金融資平臺，對接海外機構投資者，致力實施集團國際化戰略。 未來，中國政信國際開發集團有限公司也期待與更多合作夥伴積極溝通交流，探索多樣化的活動形式，共同賦能更多中資企業出海。

The topics discussed in this monthly newsletter for insurance are as follows: ComplianceOne Newsletter – October 2025 The topics discussed in this monthly newsletter are as follows: MARKET NEWS SFC Supports Market’s Initiatives on Regulatory Compliance for Digital Asset Funds and Tokenised Funds Navigating Fast-evolving Capital Markets through Balanced Regulation – the Golden Mean SFC and Québec’s AMF Enhance Regulatory Cooperation on Supervision of Cross-border Investment Management Activity Enforcement News - Intermediary SFC Reprimands and Fines UBS AG $8 million for Professional Investor Misclassification SFC Suspends MTF Securities and its Responsible Officer Over Suspicious Transaction Monitoring Failures SFC Prohibits Ex-Employee of BOCOM Over Undisclosed Nominee Account SFC Suspends Ex-employee of Shanxi Securities Over 945 Unauthorized Trade Orders ENFORCEMENT NEWS - LISTCO SFC Seeks Court Order to Freeze Assets up to $394 Million for Investors Compensation in Suspected Manipulation of Grand Talents Shares Court Penalises AMTD Global Markets Limited for Contempt of Court Due to Non-compliance with SFC Notices and Orders it to Produce Records and Pay Fine Court Order Sentenced Wong Ming Chun to 7 Years and 8 Months' Imprisonment for Money Laundering Related to Misappropriation of Listed Company Funds SFC and HKEX Collaborate in Enforcement Action Against Former Directors of Universal Star for Failure to Disclose Material Loans and Conflicts of Interest in Prospectu SFC Obtains Court Order to Freeze up to $82.4 Million of Assets Belonging to Suspected Manipulators of Smartac Shares Market News 1. SFC Supports Market’s Initiatives on Regulatory Compliance for Digital Asset Funds and Tokenised Funds The SFC showed its support to the market’s initiatives in a seminar organized by the Association of Fund Administrators of Hong Kong and the Greater Bay Area (“ AFA ”) in October for raising industry awareness of regulatory compliance standards in the fast-evolving digital asset sector. During the seminar, the AFA discussed various risk management and control measures to support the management of digital asset funds and tokenized funds. It is worth noted in the discussion of the importance for collaborative efforts within the fund industry to strengthen digital asset-related technical and regulatory compliance capabilities while adopting innovative technologies in fund management. SIGNIFICANCE: Participation of the SFC in the seminar showed its commitment to the industry as its initiative under the Pillar Re ( Re lationship) of the “ ASPIRe ” Roadmap. Dr Eric Yip, the SFC’s Executive Director of Intermediaries, said in the seminar that “b y supporting industry participants in their ongoing efforts to uphold regulatory compliance standards in managing digital asset funds and tokenized funds, we (the SFC) aim to cultivate a safe, reliable, sustainable and competitive digital asset fund ecosystem anchored in robust risk management and investor protection measures . ” 2. Navigating Fast-evolving Capital Markets through Balanced Regulation – the Golden Mean Chairman of the SFC, Dr Kelvin WONG, delivered a speech on 21 October 2025 on the perspective of the SFC in maintaining a balanced regulatory approach, cherished with a mission to ensure that the capital market of Hong Kong would “continue to thrive in a well-regulated environment that upholds integrity.” And he also expressly emphasized that the SFC plays dual roles as both a guardian and a facilitator, and put forward with the following three reflections. Some key takeaways are as follows: (1) Evolving challenges to capital markets: regulator’s perspective There are challenges to market integrity and market stability (1.1) Challenges to market integrity though remains as the world’s top three financial center, with its Fintech ranking jumping to global No.1, Hong Kong is still facing challenges stemming from gatekeeping listed issuers’ quality and forms of misconduct; encountered with increasing demand from international investors for accountability, transparency and strong board leadership given Hong Kong as the world’s top IPO listing center; enhancing listing market quality, particularly the standards of corporate governance, is not without challenges; over the years, there were cases of misconduct, false disclosure or accounting fraud that were jeopardizing the interests of the investors, and damaging public trust; besides, evolving financial fraud, scams and deception cases also pose significant risks. (1.2) Challenges to market stability external risk factors threaten to exacerbate market volatility and systemic vulnerabilities, including geo-economic fragmentation and shifts in monetary policies; our market resilience has stood the test of time as an effective shield against unexpected external shocks when global trade tensions intensified, HK was able to withstand the extreme volatility with no system failure in normal operations; digitalisation, algorithmic trading and heightened market connectedness pose profound risks to systemic stability by amplifying vulnerabilities and accelerating the transmission of shocks; monitoring mechanism and resilience framework to mitigate system risks remain as deep concerns. (2) A balanced regulatory approach in fostering sustainable development In meeting the above challenges, Dr WONG shared his view of “ Golden Mean ” to maintain a balance between competing extremes; and to align the dual roles of investor protection and market development. (2.1) Safeguarding investors by upholding high standards of corporate governance, companies can improve their performance with rigorous internal controls and board oversight; the SFC remains steadfast in delivering high-impact enforcement actions that punish wrongdoings, deter criminality, and restore investor confidence; educating and bringing alert to the public against suspected fraud and suspicious trading platforms or products, while dedicating additional resources to anti-scam publicity campaigns. (2.2) Fostering growth opportunities Hong Kong’s evolving listing regimes and enhancement to IPO price discovery, provided fresh momentum for its listing market growth and diversification from traditional sectors; the second notable achievement is our regulatory regime for digital assets as SFC pioneered itself in adopting robust standards while preserving the long-term potential; (3) Proactive stakeholder engagement as key to balanced regulation engagement is essential to attaining that Golden Mean in the regulatory approach; through open dialogues with the financial industry which enables the SFC to ensure its frameworks effectively address market needs; deepened mutual understanding with industry stakeholders through numerous seminars as regular engagement efforts; SIGNIFICANCE: As Dr WONG has said in the speech, “ For the SFC, our mission is to find that Golden Mean where law, integrity, and development co-exist and reinforce each other. We believe this balanced regulatory approach has underpinned public trust in our markets for decades, and will continue to do so in the future. ” 3. SFC and Québec’s AMF Enhance Regulatory Cooperation on Supervision of Cross-border Investment Management Activity The SFC and the Autorité des marchés financiers (“ AMF ”), the financial regulator of Québec, Canada, have concluded a Memorandum of Understanding (“ MoU ”) to enhance cooperation on the supervision of investment managers of collective investment schemes operating in either market; and the two parties signed the MoU in Madrid, Spain on 27 October 2025. What the MoU has achieved? it provides for a regulatory framework for consultation, cooperation and exchange of information for regulated entities engaging in cross-border investment management services with respect to supervision and oversight; it marks a new chapter in regulatory collaboration between the SFC and the AMF in the realm of asset management; it included Québec of Canada on its list of Acceptable Inspection Regimes which facilitates the AMF-licensed managers in providing investment management services in respect of SFC-authorized funds. SIGNIFICANCE: As Mr. Yves Ouellet, the AMF’s President and Chief Executive Officer has said, “ this MoU reflects our shared commitment to fostering robust, transparent regulatory standards. By strengthening cooperation between Québec and Hong Kong, we are enabling asset managers to access new opportunities, better serve investors, and support innovation, integrity, and resilience in our capital markets . ” Enforcement News - Intermediary 4. SFC Reprimands and Fines UBS AG $8 million for Professional Investor Misclassification On 20 October 2025, the SFC publicly reprimanded and fined UBS AG (“ UBS ”) HK$8 million under section 196 of the SFO for systemic deficiencies in its internal controls, leading to the misclassification of clients as Professional Investors (“ PIs ”) over a 12-year period from 2009 to July 2022. Case Details The breaches stemmed from UBS's automated verification process, which misinterpreted the minimum portfolio requirements under the Securities and Futures (Professional Investor) Rules (“ PI Rules ”) for joint accounts, resulting in non-professional investor (“ Non-PI ”) clients being incorrectly treated as PIs. A UBS look-back review for July 2018 to July 2022 identified 560 misclassified joint accounts (including 135 non-associate and 425 parent-child accounts), with 23 accounts involved in 9,190 securities pooled lending (“SPL”) transactions and 94 accounts in 500 PI-restricted product transactions. This misclassification enabled UBS to provide securities pooled lending services without valid standing authorities or required disclosures, and to sell PI-restricted products (such as Chapter 37 bonds, accumulators, decumulators, and loss-absorption products) to ineligible clients, violating: Securities and Futures (Client Securities) Rules ; Securities and Futures (Contract Notes, Statements of Account and Receipts) Rules ; and Code of Conduct for Persons Licensed by or Registered with the SFC . Remediate Result The SFC noted aggravating factors, including the prolonged duration and a prior 2021 fine of HK$9.8 million for similar issues, but considered UBS's self-reporting (prompted by internal review and HKMA referral), cooperation, remedial enhancements to controls, and implementation of Enhanced Complaint Handling Procedures for affected clients. In result, the SFC issues public reprimand and HK$8 million fine against UBS. For more details of the case, please refer to STATEMENT OF DISCIPLINARY ACTION SIGNIFICANCE: This disciplinary action underscores the SFC's emphasis on robust internal controls for accurate client classification to protect non-professional investors from unsuitable products and services. It highlights recurring compliance risks in automated systems for global firms like UBS, serving as a reminder for licensed entities to regularly review interpretations of regulatory requirements, especially post-amendments, to avoid prolonged breaches and escalating penalties. The case also demonstrates the value of self-reporting and remediation in mitigating sanctions, while reinforcing inter-regulator cooperation in upholding market integrity in Hong Kong's financial sector. 5. SFC Suspends MTF Securities and its Responsible Officer Over Suspicious Transaction Monitoring Failures The SFC has imposed a four-month suspension on Mr. Joey Lo Wai Hon (羅偉漢) (“ Mr. LO ”), effective from 30 September 2025 to 29 January 2026. MR. LO, a former responsible officer (“ RO ”) and manager-in-charge at MTF Securities Limited (泰富證券有限公司) (“ MTF ”) (formerly Magusta Securities Limited), was found to have failed in overseeing credit risk management and suspicious transaction monitoring. Failures in Credit Risk Management MTF granted substantial trading limits to three new clients (Client A, B, and C) shortly after they opened cash trading accounts in January 2021. Each client deposited only HK$10,000, yet MTF approved limits of HK$4 million for Clients A and C, and HK$5 million for Client B—without client applications or adequate due diligence. Notable Red Flags included: Trading limit exceeded client’s declared annual income No records of income proof, bank statements, trading history, or personal reputation checks. Client A ✓ Client B ✓ ✓ Client C ✓ ✓ Mr. LO, as an RO and Credit Committee member, was responsible for assessing creditworthiness and setting limits. However, he approved these at the request of MTF's substantial shareholder without independent scrutiny, potentially risking a liquid capital deficit if the clients defaulted. Suspicious Trading Patterns and Reporting Delays These three clients used nearly all their limits to trade shares of a Hong Kong-listed company (“ Company X ”) between 22 and 27 January 2021, generating profits from HK$3.8 million to HK$5.3 million. The trades exhibited suspicious features indicative of potential market misconduct and money laundering: Clients bought shares at low prices just before a surge, without any apparent positive news. Clients sold at high prices in the first minute of the afternoon session before a 68% price collapse, followed by further declines. The trades accounted for 46%, 52%, and 30% of Company X's daily turnover during the period. Post-trade, clients withdrew nearly all proceeds and conducted no further activity, inconsistent with their financial profiles. The above patterns aligned with AML Guideline indicators (e.g. unusual transaction sizes, rapid withdrawals etc.) Mr. LO did not investigate or report promptly. MTF only filed a suspicious transaction report (“ STR ”) to the Joint Financial Intelligence Unit (“ JFIU ”) in late July 2021, after SFC intervention. For the full details, refer to the SFC's press release dated 2 October 2025 , and Statement of Disciplinary Action . SIGNIFICANCE: The SFC deemed Lo guilty of misconduct, questioning his fitness and properness. Regarding to such matter, Licensed Corporation (“ LC ”) should reference the below table for ensuring its compliance: Due Diligence LC must rigorously assess client financials before granting credit, avoiding undue influence from shareholders. Monitoring Systems Implement effective, ongoing transaction reviews to detect anomalies like unusual price movements or disproportionate trades. Timely Reporting Suspicious activities must be documented, investigated, and reported without delay to authorities like the JFIU and SFC. In June 2025, the SFC also prohibited Ms. WONG Lai Suen, another former MTF RO and executive director, from re-entering the industry for six months. ( See Enforcement News – WONG Lai Suen ) This enforcement action reinforces the SFC's commitment to upholding market standards amid evolving risks. Firms should review their policies against the Code of Conduct, Internal Control Guidelines, and AML Guideline to mitigate similar exposures. 6. SFC Prohibits Ex-Employee of BOCOM Over Undisclosed Nominee Account On 27 October 2025, the SFC prohibited Mr. CHENG Lai Ho (鄭禮豪) (“ CHENG ”), a former licensed representative accredited to: Bank of Communications Co., Ltd. (交通銀行股份有限公司); and Bank of Communications (Hong Kong) Limited (交通銀行（香港）有限公司) (collectively, “ BOCOM ”); from re-entering the securities industry for seven months, from 27 October 2025 to 26 May 2026, pursuant to section 196 of the SFO. Case Details The sanction arises from CHENG's repeated violations of BOCOM's Staff Dealing Policy and Employee Code between April 2017 and April 2022, which aligned with regulatory requirements under paragraph 12.2 of the Code of Conduct for Persons Licensed by or Registered with the SFC. Key breaches included failing to disclose two pre-existing personal securities accounts at other institutions, opening and controlling an undisclosed nominee securities margin account in his mother's name (where he conducted over 260 unreported trades), and violating the minimum 13-trading-day holding period on at least 12 occasions after 15 July 2020. Reasons for the Disciplinary Action The SFC found CHENG's actions wilful and dishonest, as he deliberately used the nominee account to evade BOCOM's monitoring and internal controls, despite attending compliance trainings and signing false declarations. In determining the penalty, the SFC considered the five-year duration of the misconduct, the need for deterrence, CHENG's cooperation, and his clean prior record, noting no harm to clients or the market. For more details, please refer to STATEMENT OF DISCIPLINARY ACTION . SIGNIFICANCE: This disciplinary action underscores the SFC's stringent enforcement of internal compliance policies to mitigate conflicts of interest and maintain the integrity of licensed representatives, serving as a strong deterrent against deliberate evasion of employer monitoring and regulatory standards in Hong Kong's securities sector. It highlights the importance of honest disclosures and adherence to fitness and propriety requirements, potentially influencing firms to strengthen oversight of employee trading activities. 7. SFC Suspends Ex-employee of Shanxi Securities Over 945 Unauthorized Trade Orders On 28 October 2025, the SFC suspended Mr. TANG Wai Choi (鄧偉財) (“ TANG ”), a former licensed representative of Shanxi Securities International Limited (山證國際證券有限公司) (“ SSIL ”), for seven months from 28 October 2025 to 27 May 2026, pursuant to section 194 of the SFO. Case Details The disciplinary action stems from TANG's misconduct between 10 July 2019 and 10 December 2019 (Relevant Period): During which he logged into a client's securities account using the client's password and placed 945 orders via the internet without valid written authorization from the client or SSIL's knowledge, thereby circumventing internal controls and creating a false appearance that the trades were placed directly by the client. Additionally, TANG failed to maintain proper records of the client's order instructions, breaching paragraph 3.9 of the Code of Conduct for Persons Licensed by or Registered with the SFC ( Code of Conduct ), which requires time-stamped records and telephone recordings for agency orders. This exposed the client to risks of unauthorized trading, deprived SSIL of audit trails, and violated General Principle 2 (Diligence) of the Code of Conduct. The SFC deemed TANG guilty of misconduct and not fit and proper to remain licensed, considering the duration and frequency of the breaches, the need for deterrence, and his otherwise clean record. The investigation originated from a probe into a suspected ramp-and-dump scheme involving securities transactions handled by TANG at SSIL. For more details, please refer to STATEMENT OF DISCIPLINARY ACTION . SIGNIFICANCE: This enforcement action highlights the SFC's commitment to upholding professional standards among licensed representatives by addressing breaches that undermine client protections and internal controls, serving as a deterrent against unauthorized account access and inadequate record-keeping that could facilitate market misconduct in Hong Kong's securities industry. It reinforces the importance of compliance with the Code of Conduct to maintain market integrity and prevent risks such as trade disputes or unauthorized activities. Enforcement News - LISTCO 8.SFC Seeks Court Order to Freeze Assets up to $394 Million for Investors Compensation in Suspected Manipulation of Grand Talents Shares On 30 September 2025, the SFC filed an application with the Court of First Instance for an interim order to freeze assets up to $394,067,589. This amount represents the estimated losses suffered by investors affected by an alleged sophisticated ramp-and-dump scheme involving the shares of Grand Talents Group Holdings Limited (廣駿集團控股有限公司) ( 08516.HK ) (“ Grand Talents ”), which was listed on the GEM board of the Stock Exchange of Hong Kong Limited in October 2018. The application is part of broader legal proceedings under section 213 of the Securities and Futures Ordinance (“ SFO ”) against 16 defendants, including suspected masterminds, accused of manipulating Grand Talents shares between June 2021 and June 2022. The SFC aims to prevent the defendants from disposing of their assets in Hong Kong to secure funds for potential compensation to victims. The following table provides a chronological summary of key events in the Grand Talents case (for reference only): Date Remarks Source 25 Apr 2023 The SFC issued a notice under Sections 204 and 205 of the SFO imposing restrictions on four client accounts at Silverbricks Securities Company Limited, totaling HK$94,610,762.71, due to suspected manipulative trading in Grand Talents shares from 24 November 2021 to 14 June 2022, leading to a 93% share price plunge on 15 June 2022. The notice aims to prevent asset dissipation amid investigations into possible false trading, price rigging, and stock market manipulation. G.N. 2821 5 Aug 2025 The SFC issued a notice under Sections 204 and 205 of the SFO prohibiting Tiger Brokers (HK) Global Limited from dealing with assets in a specified account (no. 63820919) linked to suspected manipulative trading in Grand Talents shares from 24 November 2021 to 14 June 2022, which culminated in a 93% share price drop on 15 June 2022. The restrictions are to preserve assets during ongoing investigations into potential violations including false trading and stock market manipulation. G.N. 4982 29 Sep 2025 The SFC applied for an interim court order to freeze assets up to HK$394,067,589 from 16 defendants, including suspected masterminds, in an alleged social media ramp-and-dump scheme manipulating Grand Talents shares from June 2021 to June 2022. The court granted an interim injunction against four defendants, with the matter adjourned for the remaining 12. This action aims to secure funds for investor compensation estimated at the frozen amount. SFC - Press Release Court Orders to the 16 defendants To date, the Court has granted an interim injunction against 4 of the defendants, restraining them from dealing with assets up to $394 million, which remains in force until further order. For the remaining 12 defendants, the Court has issued directions and adjourned the matter to a future date. The SFC has indicated it will refrain from further comments as proceedings are ongoing. SIGNIFICANCE: This enforcement action by the SFC underscores its commitment to combating market manipulation and protecting investors in Hong Kong's financial markets. By seeking asset freezes, the regulator aims to preserve resources for restitution, deterring similar schemes that erode market integrity and investor confidence. It highlights the SFC's proactive use of legal tools to address complex frauds, such as social media-driven ramp-and-dump operations, and reinforces the importance of transparency and accountability in securities trading, potentially setting precedents for future cases involving cross-border or digital manipulation tactics. 9. Court Penalises AMTD Global Markets Limited for Contempt of Court Due to Non-compliance with SFC Notices and Orders it to Produce Records and Pay Fine On 13 October 2025, the Court of First Instance ordered AMTD Global Markets Limited (現稱:奧翱驁集團（香港）證券有限公司, 前稱: 尚乘環球市場有限公司) (“ AMTD ”, formerly known as orientiert XYZ Securities Limited and currently known as oOo Securities (HK) Group Limited) to produce records and pay a fine for contempt of court, following proceedings initiated by the SFC under section 185 of the SFO. The Court ordered AMTD to comply with the outstanding requests by 19 January 2026 and imposed a fine for past non-compliance, with the amount to be determined later. It rejected AMTD's excuses, including changes in ownership, management, and loss of records, deeming them unreasonable. Case Overview: Period/Date Remarks Prior to 2023 SFC issues notices under sections 181, 182, and 183 of the SFO to AMTD, requiring records, documents, and answers related to IPO investigations involving suspected fraud and misleading information. 30 Jan 2023 SFC issues a notice under section 183 of the SFO; Court later finds AMTD not liable for non-compliance with this specific notice. 23 Nov 2023 SFC commences legal proceedings under section 185 of the SFO against AMTD and its former executives (including Lo Chi Hang, Philip Yau Wai Man, and See Hiu Lun) for non-compliance with notices in IPO-related investigations. 13 Oct 2025 Court of First Instance rules AMTD in contempt, orders compliance by 19 January 2026, and imposes a fine (amount to be determined later); rejects AMTD's excuses for non-compliance. Case Number: HCMP 2027/2023 19 Jan 2026 Deadline for AMTD to comply with outstanding SFC notice requests. To be determined Court to decide the amount of the fine imposed on AMTD for contempt. Current Status of the Case The Court ordered AMTD to comply with the outstanding requests by 19 January 2026 and imposed a fine for past non-compliance, with the amount to be determined later. It rejected AMTD's excuses, including changes in ownership, management, and loss of records, deeming them unreasonable. SIGNIFICANCE: The SFC's Executive Director of Enforcement, Mr. Christopher Wilson, stated: “The SFC does not tolerate non-compliance with the SFO. Non-compliance undermines the SFC’s ability to discharge its regulatory functions and erodes the integrity of Hong Kong’s capital markets. The SFC will take robust enforcement action against non-compliance.” This ruling emphasizes the SFC's zero-tolerance approach to non-compliance with investigative notices, highlighting the importance of licensed entities maintaining proper records and cooperating fully to uphold market integrity. It serves as a precedent for robust enforcement against excuses like corporate changes, potentially deterring similar failures in IPO-related probes and reinforcing regulatory oversight in Hong Kong's capital markets, with cross-border cooperation exemplified by the UK FCA's involvement. 10. Court Order Sentenced Wong Ming Chun to 7 Years and 8 Months' Imprisonment for Money Laundering Related to Misappropriation of Listed Company Funds On 22 October 2025, the SFC welcomed the High Court's conviction and sentencing of Mr. WONG Ming Chun (王名俊) (“ WONG ”), the former financial controller and company secretary of Hua Han Health Industry Holdings Limited (華瀚健康產業控股有限公司) ( 00587.HK ) (“ Hua Han ”), for two counts of money laundering. Case Details The case originated from the SFC's investigation into suspected false or misleading disclosures in Hua Han's financial statements from 2013 to 2015, which uncovered the misappropriation of fundraising proceeds. These findings were referred to the Police for further action. Hua Han, listed on the Main Board of The Stock Exchange of Hong Kong Limited since 2002 and delisted in 2020 , was involved in health industry operations, highlighting vulnerabilities in financial controls within sectors that may intersect with insurance and investment products. Enforcement Act and Court Order WONG pleaded guilty to the charges under section 25(1) of the Organized and Serious Crimes Ordinance ( Cap. 455 ), stemming from the misappropriation of funds raised by Hua Han in 2015. He was sentenced to seven years and eight months' imprisonment and disqualified from serving as a director of any Hong Kong company for 12 years without court leave, pursuant to section 168E of the Companies (Winding Up and Miscellaneous Provisions) Ordinance ( Cap. 32 ). [Court Case: HCCC 402/24] SIGNIFICANCE: This conviction emphasizes the critical role of financial gatekeepers, such as controllers and secretaries, in upholding corporate integrity and investor trust. As noted by SFC's Executive Director of Enforcement, Mr. Christopher Wilson, failures in these positions not only breach fiduciary duties but also threaten market stability. For the insurance sector, it serves as a reminder of the need for robust internal controls to prevent similar abuses, particularly in entities handling policyholder funds or linked investments, reinforcing collaborative enforcement efforts between regulators to maintain transparency and deter financial misconduct. 11. SFC and HKEX Collaborate in Enforcement Action Against Former Directors of Universal Star for Failure to Disclose Material Loans and Conflicts of Interest in Prospectus On 23 October 2025, the SFC and the Stock Exchange of Hong Kong Limited (“ HKEX ”) announced a collaborative enforcement outcome resulting in disciplinary action against: Mr. LU Qingxing (呂慶星) (“ LU ”), former non-executive director; and LU’s son, Mr. LYU Zhufeng (呂竹風) (“ LYU ”), former executive director; of Universal Star (Holdings) Limited (星宇（控股）有限公司) ( 02346.HK ) (“ Universal Star ”). Case Details The action stems from: SFC's investigation into the directors' failure to disclose 13 outstanding loans totaling approximately RMB49 million where a Universal Star subsidiary served as co-borrower or guarantor, in the company's May 2019 IPO prospectus. These loans, taken out by LU between April 2017 and April 2019, primarily benefited him personally (with at least RMB44 million paid directly to him and RMB2 million to LYU, who transferred it to the subsidiary). The undisclosed loans represented material financial liabilities, breaching disclosure obligations to the sponsor and other directors. Additionally, post-IPO, the pair caused the subsidiary to pledge its property as security for the loans without the knowledge or approval of other directors, independent shareholders, or the compliance adviser—violating Listing Rules on major and connected transactions. This conduct also involved unmanaged conflicts of interest, as LU personally profited, constituting a breach of fiduciary duties that prejudiced investors. The SFC shared its investigation findings, including loan and pledge evidence, with HKEX, leading to the disciplinary sanctions. Regarding the STATEMENT OF DISCIPLINARY ACTION : HKEX issued a "Prejudice to Investors’ Interests Statement" (PII Statement), indicating that the directors' continued board tenure would have harmed investors, along with a public censure. Both individuals, who resigned in 2021 and 2023 respectively, agreed to settle without contesting the breaches. SIGNIFICANCE: This collaborative enforcement action between SFC and HKEX underscores the regulators' commitment to accountability in corporate governance, particularly for directors of listed entities, to safeguard investor interests and market transparency. The case reinforces the value of inter-regulator cooperation in detecting and addressing misconduct that could erode trust in Hong Kong's capital markets. 12. SFC Obtains Court Order to Freeze up to $82.4 Million of Assets Belonging to Suspected Manipulators of Smartac Shares On 27 October 2025, the Court of First Instance granted an interim injunction order sought by the SFC under section 213 of the SFO against 12 individuals suspected of manipulating shares of Smartac International Holdings Limited (環球智能控股有限公司) ( 00395.HK ) (“ Smartac ”, formerly Smartac Group China Holdings Limited, delisted from the HKEX Main Board on 20 February 2023). Case Details The proceedings form part of broader SFC legal actions against the former chairman and non-executive director of Ding Yi Feng Holdings Group International Limited (renamed Carmen Century Investment Limited on 3 July 2025), along with 28 other suspects and one corporate entity, for their roles in the alleged manipulation. Separately, in September 2025, the SFC obtained a consent order to freeze assets of one additional suspect, while an application for another remains pending. The interim injunction remains in effect until the next court hearing on 27 March 2026. Court Order The Court of First Instance prohibits the suspects from removing, disposing of, dealing with, or diminishing the value of their assets in Hong Kong up to $82.4 million, ensuring sufficient assets are available for potential restoration orders if contraventions of the SFO are proven. This action relates to alleged market manipulation of Smartac shares between 31 October 2018 and 11 March 2019. Enforcement News Consolidate Table: Remarks Source/Linkage SFC issues restriction notices to 14 brokers to freeze client accounts linked to suspected Smartac manipulation. 25 Jun 2019 SFC commences MMT proceedings against Sui Guangyi, two entities, and 28 suspects for alleged Smartac manipulation. 12 Nov 2024 SFC applies for asset freeze up to $82.4m against 14 suspects; obtains consent order for one suspect; hearing adjourned to 24 October 2025. 12 Sep 2025 Scheduled next hearing for the interim injunction order. 27 Oct 2025 SIGNIFICANCE: This court order highlights the SFC's proactive enforcement strategy to preserve assets in market manipulation cases, protecting investor interests and ensuring potential remedies for affected parties. By targeting a group allegedly involved in coordinated misconduct over an extended period, it underscores the regulator's commitment to combating sophisticated financial crimes that undermine market integrity, while the ongoing proceedings may set precedents for handling multi-party manipulations in Hong Kong's capital markets. [End of ComplianceOne Newsletter – October 2025] 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

證監會對期貨經紀行的新風險管理指引即將於2024年2月25日起生效，我們準備了以下快速指南以方便期貨經紀行能快速理解是次指引的重點及待辦事項。 適用於從事期貨合約交易持牌人的風險管理指引 (快速指南) [Feb 2024] A. 引言 1. 證券及期貨事務監察委員會（證監會）根據《證券及期貨條例》第 399 條於2023年8月25日發表了《適用於從事期貨合約交易的持牌人的風險管理指引》（下文簡稱“ 指引 ”）的諮詢總結，其旨在對適用於從事期貨合約交易的持牌人的現行監控規定作出補充。 2. 指引應與適用於期貨經紀行 [ 第 2 類受規管活動（期貨合約交易）持牌人] 的所有相關法律、法例、守則、規例或其他指引一併閱讀，並在不損害該等法律、法例、守則、規例或其他指引的原則下應用。 3. 指引於 2024年2月25日起生效 ，而 其後起計 12 個月的期間內為 過渡期的安排 。 過渡期的安排主是要給予期貨經紀行額外時間去完成相關系統的開發，例如： (a) 將客戶風險限額納入其風險管理系統、交易指示管理系統或交易平台之內，以識別或防止任何風險限額被突破；及 (b) 採用的假設的壓力情境應包括該行或其客戶交易的期貨合約出現極端但可能發生的價格變動或波幅變化的情境等。 如期貨經紀行未能於 2024年2月25日前 完成相關系統的開發便應採取其他臨時補償措施 (可參考以下列表的“參考 / 補償措施”一欄），這些措施可包括以人手方式監察風險限額的遵守情況，及使用審慎的簡化壓力情境來進行壓力測試以符合以上(a)或(b)所述的規定的風險管理目的等等。 我們準備了以下清單列表以方便期貨經紀行能快速理解是次指引的重點及待辦事項，建議期貨經紀行可根據以下清單去檢查是否已完成證監會最新的風險管理指引要求。我們以 藍色及底線標示的為是次證監會新指引中的重要項目及重點 ，需要特別關注。若期貨經紀尚未完成相關的待辦事項，便應從速處理並落實執行。 另外，由於指引較為繁複，且某些詞匯的定義亦必須參考回指引，我們亦建議客戶細閱指引原稿以作更深入的了解。 4. 我們準備了以下清單列表以方便期貨經紀行能快速理解是次指引的重點及待辦事項，建議期貨經紀行可根據以下清單去檢查是否已完成證監會最新的風險管理指引要求。我們以 藍色及底線標示的為是次證監會新指引中的重要項目及重點 ，需要特別關注。若期貨經紀尚未完成相關的待辦事項，便應從速處理並落實執行。 另外，由於指引較為繁複，且某些詞匯的定義亦必須參考回指引，我們亦建議客戶細閱指引原稿以作更深入的了解。 B. 定義 “指引” 指證監會於2023年8月發出的 《適用於從事期貨合約交易的持牌人的風險管理指引》。 “關連客戶組別” 根據 指引 中第20段註釋1的(a)至(f)的定義。 “聯屬客戶” 指與該期貨經紀行屬同一公司集團之內的任何公司。 “優惠保證金待遇” 指期貨經紀行與客戶之間就期貨合約作出的一種安排， 如客戶符合執行或結算有關期貨合約的交易所或結算所的規則所訂明的資格準則，則客戶無須遵守該等規則所訂明的預繳抵押品規定。 “資金流動性風險” 指期貨經紀行在某期貨合約到期時未能履行其在該合約下的財務責任的風險。 “保證金短欠＂ 指當客戶帳戶的權益淨額結餘低於期貨經紀行就有關帳戶內的未平倉持倉而設定的保證金規定時，便產生“保證金短欠＂。 “權益淨額結餘” 指在該帳戶內持有的抵押品、在該帳戶內的未平倉持倉的浮動利潤及記入該帳戶內的收入的總和，減去在該帳戶內的未平倉持倉的浮動虧損及從該帳戶扣除的費用、佣金、徵費及其他收費。 “貫徹符合保證金規定” 指有關客戶在下列期間: (a) （如有關帳戶開立達一年或以上）最近至少一年的期間內; 或 (b) （如有關帳戶開立少於一年）自帳戶開立日期起計，並至少三個月的期間內; 並無不符合保證金規定、被強制平倉或遭退回支票的紀錄。 “客戶保證金短欠數額” 指客戶分類帳內該帳戶的期貨合約買賣所須的保證金金額中，超出該帳戶內權益淨額結餘的數額。 “速動資金盈餘” 指根據《財政資源規則》，其速動資金減去規定速動資金後的數額。 “客戶分類帳” 指就“期交所交易”及“非期交所交易＂設有獨立分類帳的規定 “可用資金” 指由該行實益擁有的沒有產權負擔現金與其分配作期貨合約交易用途的未提取銀行信貸額的總和。 “ 量化基準 ” 設定為該行的速動資金盈餘與可用資金中較高者的 50% “超蝕款項” 指一個客戶帳戶的交易虧損超逾該帳戶的權益淨額結餘的任何金額。 “預計超蝕款項” 就某客戶帳戶而言，指任何預計虧損超逾該帳戶的權益淨額結餘的金額。 C. 清單列表 類別 指引下期貨經紀行應具備的政策/ 待辦事項清單 Checkbox 備註 參考 / 補償措施 1. 自營買賣及客戶買賣期貨合約所產生的風險管理 (1) 應建立有效的風險管治框架，以管理其本身及其客戶所承擔的風險，應將風險管理責任授予具備經驗及專業知識且擁有足夠權限以 實施政策及程序 的高級管理層。 ☐ 應確保其風險胃納及風險限額與其策略目標相符並與其財政及管理能力相稱。 (2) 就(1)的政策及程序實施持續風險監察、監控和匯報。 ☐ 須要制定風險限額及偏離 (deviation policy)的政策和匯報程序。 (3) 就(1)的政策及程序進行壓力測試及實施應變計劃。 ☐ 須要考慮如何建立/設計切實並可行的壓力測試場境及相關條件。 2. 市場價格水平或波幅出現不利變動而招致損失的風險（ 只適用於有參與自營買賣的期貨經紀行 ） (1) 確保期貨合約的自營買賣持倉均應以實時方式按市值計算。 ☐ 自營買賣持倉的日終重新估值應以獨立於前線部門的來源取得或經獨立核實的資料來源。 (2) 應定期將估計的自營買賣持倉的 實際及假設回報進行比較 。 ☐ 當發現估值誤差時須要進行調查及檢討 。 (3) 釐定與其財政及管理能力相稱且審慎的市場風險限額。 ☐ 採用的市場風險限額必須獲得其高級管理層及董事會妥為批准，出現違反限額的情況時應予及時上報。 3. 商品期貨買賣風險 (1) 備存獲得其高級管理層批准的一份＂ 其可 交易的商品期貨清單 ＂。 ☐ 當交易的商品期貨須要以實物交收時，須先制定／計劃清楚所附帶的運送，存倉及交付安排。 4. 客戶信貸風險 (1) 以單一客戶而言 ，為每名客戶制定審慎的交易限額及持倉限額； (2) 以每個關連客戶組別而言 ，從整體角度顧及該組別內所有客戶而設的合計基準風險限額，期貨經紀行可參考指引中第21段(c)的風險項目。 ☐ 言 ，為每名客戶制定審慎的交易限額及持交易限額及持 ☐ 設定(1)、(2)條件的目的在於防止任何違反適用的法定或監管持倉限額（如結算代理人或交易所的持倉限額）。 (3) 需設有識別關連客戶組別的措施，及評估相關組別的財務及信貸資料， 特別是如何識別相關帳戶的實益擁有人。 ☐ 為確定兩名或以上屬自然人（配偶除外）的客戶是否屬某個關連客戶組別， 期貨經紀行無須主動查核該等客戶的帳戶的實益擁有人 ，但當有跡象顯示某客戶並非為其本身行事時，便應作出適當查詢。 (1) 以聯屬客戶而言 ，須要考慮的風險項目與(1)、(2)類別大致相同，詳情可參考指引中的第22段(c) 。 ☐ 定期檢視該聯屬客戶及時向該期貨經紀行履行交收責任的能力，包括其交易模式，風險胃納給管理政策，財務狀況及分配作期貨合約交易用途的資金資源等。 5. 收取客戶基本保證金 (1) 除非客戶已提供充足的抵押品以符合其保證金規定，否則不應為該客戶買賣期貨合約。 (2) 對客戶施加保證金規定（可能包括開倉保證金規定及維持保證金規定） 不得低於其對手方所設定的金額 ， 不應向任何客戶授出任何信貸融通 或貸款或作出任何其他安排，以便任何客戶得以符合保證金規定。(例如，期貨經紀行不應向其聯繫公司提供財政支持，以便後者向該行的客戶授出信貸融通的安排。) ☐ 已提供充足的抵押品以符合其保證金規定，否則不應為該客戶買賣期則不應為該客 ☐ 施加保證金規定（可能包括開倉保證金規定及維持保證金規定） 不得低於其對手方所設定的金額 ， 不應向任何客戶授出任何信貸融通 或貸款或作出任何其他安排，以便任何客戶得以符合保證金規定。(例如，期貨經紀行不應向其聯繫公司提供財政支持，以便後者向該行的客戶授出信貸融通的安排。) i. 享有優惠保證金的客戶除外； ii. 期貨經紀行經考慮客戶及其自身的情況後，可向客戶施加較其對手方 (或交易所) 所設定的金額為高的保證金規定。 (3) 制定特殊保證金安排 ，以紓減因市場波動及公眾假期情況而可能引致的客戶信貸及資金流動性風險。 ☐ 可不時按市場情況暫時調高保證金規定或在公眾假期前席收取額外保證金。 6. 客戶出現保證金短欠 (1) 就以香港為基地的客戶而言，在發出追繳保證金通知起計 一個營業日內 向客戶收取任何到期應付的保證金數額； (2) 向每名客戶發出的追繳保證金通知備存詳細的紀錄，當中包括每項追繳保證金通知涉及的金額及發出的時間； (3) 嚴格執行其保證金和強制平倉的政策及程序。 ☐ 客戶而言，在發出追繳保證金通知起計 一個營業日內 向客戶收取任何到期應付的保到期應付的保到期應付的 ☐ 追繳保證金通知備存詳細的紀錄，當中包括每項追繳保證金通知涉及的金額及發出的金額及發出的金額及發 ☐ i. 須保存記錄關於客戶的回應和清繳詳情，以及就未清繳追繳保證金所採取的任何跟進行動。 ii. 評估在上一次向其客戶發出追繳保證金通知和下一次發出追繳保證金通知 之間的期間內的風險承擔 。 根據證監會諮詢總結第13段， 期貨經紀行要求在授出寬免方面享有較大的靈活性，證監會已修改了《指引》， 將焦點集中於所授出的寬免是否適當之上。 (4) 高級管理層須具有適當的充分理由，包括批准人 合理地信納有關偏離或寬免不會影響期貨經紀行的財務穩健性( 例如，在《財政資源規則》下的速動資金規定)，否則不應授予批准。 ☐ 當出現以下情況須取得高級管理層的批核 -偏離該政策的情況； -對追繳保證金或強制平倉的寬免。 具體而言，對於偏離或寬免期貨經紀行的保證金及強制平倉政策的情況，除非高級管理層具有適當的充分理由， 否則不應授予批准。 7. 給予優惠保證金待遇予客戶 (1) 如符合下列要求，期貨經紀行可就某客戶在期貨市場進行的買賣給予優惠保證金待遇 ： i. 該客戶有 貫徹符合保證金規定的紀錄 ，並維持著穩健的財務狀況，以及符合相關交易所或結算所的規則下就優惠保證金待遇所訂明的資格準則； ii. 期貨經紀行嚴格遵守該交易所或結算所規則中的所有要求； iii. 期貨經紀行具備充足的流動資金及財政能力， 以符合其對手方就所有獲得優惠保證金待遇的客戶的期貨合約買賣所施加的保證金規定。 備註: “ 貫徹符合保證金規定 ”指有關客戶在最近至少一年的期間內；或自帳戶開立日期起計， 並至少三個月的期間內，並無不符合保證金規定、被強制平倉或遭退回支票的紀錄。 (1) 如符合下列要求，期貨經紀行可就某客戶在期貨市場進行的買賣給予優惠保證金待遇惠保證金 ☐ 如符合下列要求，期貨經紀行可就某客戶在期貨市場進行的買賣給予優惠保證金待遇惠保證金 如符合 下列要求，期貨經紀行可就貨經紀行可紀行可就貨經紀 ☐ 當市況出現大波動， 享有優惠保證金優惠的 優惠的客戶出 ☐ 當市況出現大波動， 享有優惠保證金優惠的客戶出現追加保證金時的處理方案。 (2) 以個別客戶而言， 為每名獲得優惠保證金待遇的客戶訂立一個審慎的交易限額 。期貨經紀行應充分考慮其財政能力及該客戶的具體情況， 並避免訂立過高的交易限額 。 ☐ 定期檢視獲得優惠保證金待遇的客戶的財務狀況、清繳紀錄、投資目標、風險胃納和交易模式或策略; 以釐定相稱的交易限額。 (3) 當 客戶分類帳 內出現“客戶保證金短欠數額”須要計算時， 可參照以下其中一項： i. 存放於其對手方的保證金總額；或 ii. 客戶須存放於該經紀行的保證金總額。 ☐ 如期貨市場的某個交易時段的 交易時間跨越該交易日的午夜 ，期貨經紀行便無須將在該交易時段內的期貨合約買賣計算在內。 (4) 期貨經紀行應計算截至每個交易日結束時所有獲得優惠保證金待遇的客戶的分類帳內的客戶保證金短欠數額的總額，及將該總額與量化基準 （ 設定為該行的速動資金盈餘與可用資金中較高者的50%）進行比較。當發現超出量化基準時， 應確保不會出現過度風險承擔及採取及時及適當的行動，並在下一個交易日及時向證監會作出匯報。 ☐ 期貨經紀行應具備充足的速動資金盈餘與可用資金，並衡量其可承受的風險，及其對財政能力的影響。可使用 i. 其最近期的速動資金盈餘或可用資金的金額；或 ii. 其在向證監會提交的最近期的財務申報表中所匯報的速動資金盈餘或可用資金的金額，以進行(4)的比較。 跟據證監會諮詢總結第15段， 證監會不會強制規定超逾該限額的期貨經紀行須在下一個交易日糾正有關情況，但它們仍須及時向證監會作出匯報。 8. 資金流動性風險 (1) 應實施相應措施審慎管理現金流，及確保其持有的客戶款項或抵押品具備充足的流動性，以代表客戶為期貨合約買賣符合其對手方的保證金規定。 ☐ 具備可行的壓力測試環境； 在某些情況下，期貨經紀行或許未能在限期前履行其對手方就有關期貨合約發出的追繳保證金通知，原因可能是相關客戶沒有及時履行該行的追繳保證金通知 (例如本地農歷新年假期間)，以及該行並無充足資金代該客戶清繳該追繳保證金。 (2) 應定期評估其在承受影響全個市場的壓力或影響特殊情況的壓力時的流動資金需要，及 制定適當的緊急融資方案 。 ☐ (3) 在緊急情況下如何可獲取足夠的新資金，應 避免依賴單一資金來源 。 ☐ 9. 委聘執行或結算代理人為客戶執行或結算期貨合約 (1) 制定書面政策及程序，以確保該行及其客戶對該代理人的風險承擔獲得妥善管理； ☐ 有關建議沒有規定期貨經紀行必須與後備代理人訂立正式協議或開立帳戶， 與該候選代理人就後備安排確立和維持相互諒解便已足夠。 就客戶保證金溢差(client margin excess)的建議限額及分隔規定(segragation requirements)所識別出的實際問題 (2) 在該代理人並非持牌法團、註冊機構、認可交易所的交易所參與者或認可結算所的結算所參與者的情況下，須定期對該代理人進行盡職審查覆核並評估該代理人的能力； ☐ 期貨經紀行可以設下一個特定時段（例如一個月以25個交易天為樣本），估算主要活躍客戶在這個時段內的平均交易量和平均持倉量的保證金要求，並以此作為參考標記。 (3) 實施適當的安排和後備措施，物色至少一名後備執行或結算代理人的候選人 ，並盡可能就後備安排與該候選人確立和維持相互諒解或正式協議。 ☐ 並根據此參考標記的成交量和持倉量的波動情況，設定上下120%-80%的緩衝區。 當存放於結算代理人的客戶保證金超出參考標記的120%時，期貨經紀行向結算代理人執行提取超額的保證金。如果保證金低於 80%時，則可向結算代理人存入額外保證金以維持至 100% 的平均水平（參考標記），以方便客戶隨時建立任何新倉的保證金要求。 10. 因委聘執行或結算代理人而產生保障客戶資產風險 (1) 應確保在其於對手方開立的帳戶內，客戶的期貨合約持倉及該等持倉的相關保證金是與期貨經紀行自營買賣持倉及該等持倉的相關 保證金分開記帳的; ☐ 自營資金與客戶資金必須完全分隔。 (2) 不應使用屬於某客戶的資產為另一客戶的交易提供保證或進行交收; ☐ 某客戶帳戶的資產 不能被用於抵銷 或清繳另一客戶帳戶的“超蝕款”。 (3) 當期貨經紀行在於某對手方（代理人）開立的綜合帳戶內持有客戶持倉及資產，便應採取合理步驟， 防止屬於某客戶帳戶的資產被用於抵銷或清繳另一客戶帳戶的“超蝕款項” 。 ☐ (4) 若出現以上(3)的情況，應盡快將其收到用來清繳出現超蝕款項的客戶帳戶的追繳保證金的任何資產， 以及一筆數額相等於上述追繳保證金尚未獲清繳的金額的自身現金 ，存入該綜合帳戶或指定的信託銀行帳戶或獨立帳戶內， 以彌補因該抵銷而令其他客戶帳戶的資產出現的短欠。 ☐ 使用自身資金時， 須要計算速動資金盈餘或可用資金的金額。 11. 進行壓力測試環境下所產生的潛在虧損風險 (1) 制定妥善的壓力測試政策及程序，清楚地列明壓力測試的方法和頻密程度，以及檢討和匯報機制。這些政策及程序應獲高級管理層批准。 (2) 自行進行壓力測試應至少每周及在市況波動時進行壓力測試 。 特別安排： (3) 若客戶屬i. 持牌法團，ii. 註冊機構；或iii. 在香港以外地方的期貨交易商，其帳戶內的持倉是由該金融機構代其客戶持有的， 可將該帳戶內的任何持倉排除在根據本“指引”進行的壓力測試的範圍之外。 ☐ 的壓力測試政策及程序，清楚地列明壓力測試的方法和頻密程度，以及檢討和匯報機制。這些政策及程序應獲高級管理層批 准。 獲高級管理層批 ☐ 行壓力測試應至少每周及在市況波動時進行壓力測試 。 波動時進行壓力動時進行壓力 ☐ i. 應採用與其自營或其客戶買賣的產品的風險特性相稱的適當壓力測試方法。 ii. 預計 每個客戶帳戶 在 該壓力測試假設的壓力情境（假設的壓力情境）下可能產生的虧損金額（預計虧損）， 並估計 客戶帳戶的大額 預計超蝕款項 對期貨經紀行的速動資金盈餘及可用資金造成的影響。 iii. 預計期貨經紀行的 自營買賣持倉 在該假設的壓力情境下可能引致的交易虧損及追繳保證金金額， 並估計該等預計交易虧損及追繳保證金的總額 對其速動資金盈餘及可用資金造成的影響。 當擬備本“指引”時， 壓力測試中採用的假設的壓力情境在期交所買賣的指數期權的相關價格變動 被假設為±20%。 (4) 在其 壓力測試中採用的假設的壓力情境 應包括該行或其客戶交易的期貨合約 出現極端但可能發生的價格變動或波幅變化(期權合約的持倉)的情境， 並應參考或基於下列因素來釐定有關情境： i. 過去的期貨市場受壓事件；及 ii. 其對潛在且令期貨合約的價格或波幅產生重大影響的風險所作出的評估。 (4) 在其 壓力測試中採用的假設的壓力情境 應包括該行或其客戶交易的期貨合約 出現極端但可能發生的價格變動或波幅變化(期權合約的持倉)的情境， 並應參考或基於下列因素來釐定下列因素來 ☐ 去的期貨市場受貨市壓事件；及 ☐ 若期貨經紀行為某交易所或結算所的會員或參與者 ， 便應確保為在該交易所或結算所買賣或結算的期貨合約持倉進行的壓力測試所採用的 假設的壓力情境， 至少與該交易所或結算所為其會員或參與者指明或建議的假設的壓力情境同等嚴謹。 期貨經紀行在預計虧損應出現極端但可能發生的價格變動或波幅變化的假設來進行估算，或以 “替代方案”假設為相等於期貨經紀行的對手方所設定的保證金規定的 200%。 (5) 在 集團層面集中進行的壓力測試 : i. 已考慮到該期貨經紀行的風險承擔及財務狀況，並適當地預計壓力情境對該行的速動資金盈餘及可用資金造成的影響； ii. 採用的方式與自行進行壓力測試所載列的規定大致上一致或在嚴謹程度上高於該等規定； iii. 在證監會提出要求時，向該會提交有關其集團層面壓力測試的報告。 (5) 在 集團層面集中 (5) 在 ☐ 考慮到該期貨經紀行的風險承擔及財務狀況，並適當地預計壓力情境對該行的速動資金盈餘及可用資金 ☐ 用的方式與自行進行壓力測試所載列的規定大致上一致或在嚴謹程度上高一致或在嚴謹程 ☐ (6) 及時和勤勉盡責地評估壓力測試結果，以識別任何對其財政穩健性構成的潛在威脅 ，以及採取及時的跟進行動。進行評估的最低要求： a. 將客戶帳戶的預計虧損總額及自營帳戶的預計交易虧損總額 與過往的壓力測試結果進行比較 ， 並識別： i. 預計超蝕款項超逾該行的速動資金盈餘或可用資金的30% 的任何客戶或關連客戶組別； ii. 該行認為 使其承擔過高風險 的任何其他客戶或關連客戶組別； b. 評估該行的速動資金盈餘或可用資金是否足以承受帳戶內有著最大金額的預計超蝕款項的兩個客戶或關連客戶組別的預計超蝕款項造成的綜合影響。 特別安排： 根據以上(6)的條件， 具有貫徹符合保證金規定的紀錄或維持著相對其投資組合及交易規模而言屬穩健的財務狀況的客戶或關連客戶組別 可被排除在外。 (6) 及時和勤勉盡責地評估壓力測試結果，以識別任何對其財政穩健性構成的潛在威脅 ，以及採取及 以及採取及 及 以及採取及 及 以及採 ☐ 戶帳戶的預計虧損總額及自營帳戶的預計交易虧損總額 與過往的壓力測試結果進行比較 ， 並識結果進行比 ☐ 計超蝕款項超逾該行的速動資金盈餘或可用資金的30% 的任何客戶或關任何客戶或關 ☐ 行認為使其承擔過高風險的任何其他客戶或關其他客戶或關 ☐ (7) 當在壓力測試下可能出現威脅時的應變措施: i. 採取及時和有效的跟進行動，例如調整其風險管理措施； ii. 擬備詳細的應變計劃，以免在市場受壓的情況下出現交收失敗、無力償債；或 iii. 避免違反《財政資源規則》下的最低速動資金規定的情況 。 (7) 當在壓力測試下可能出現威脅時的出現威脅時的 ☐ 取及時和有效的跟進行動，例如調整其風險管理措 ☐ 備詳細的應變計劃，以免在市場受壓的情況下出現交收壓的情況下出現交收 ☐ 免違反《財政資源規則》下的最低速動資金規定的情況 。 應確保應變計劃採用的假設能切合付諸實行。 (8) 壓力測試的文檔記錄包括： i. 所進行的每個壓力測試的詳情，包括該壓力測試所採用的方法、數據來源、數據紀錄、假設和假設的壓力情境； ii. 每個壓力測試的結果，包括但不限於每個客戶帳戶的預計虧損金額及預計超蝕款項，及其每個自營帳戶的預計交易虧損； iii. 就壓力測試結果進行的評估的結果；及 iv. 就評估結果採取的任何跟進行動。 (8) 壓力測試的文 (8) 壓力測試的文 ☐ 進行的每個壓力測試的詳情，包括該壓力測試所採用的方法、數據來源、數據紀錄、假設和假據紀錄、假設和假 ☐ 個壓力測試的結果，包括但不限於每個客戶帳戶的預計虧損金額及預計超蝕款項，及其每個自營帳戶的計交易易 ☐ 壓力測試結果壓力測試結果壓力測 ☐ 評估結果採取的任何跟進行動。 12. 風險披露及聲明 期貨經紀行應在客戶協議內披露以下重要事項： (1) 期貨經紀行 就其代理人之綜合帳戶內持有的客戶資產 而向有關客戶負上法律責任的範圍，及客戶在綜合帳戶內的資產的權利； (2) 客戶享有其對持有在期貨經紀行於 某結算所開立的綜合帳戶 內的資產的權利； (3) 為客戶提供在香港以外地方的期貨市場買賣或結算服務時， 其海外對手方及該期貨市場不受證監會所規管及可能受到有別於《證券及期貨條例》及據此訂立的規則和規例的法律及規例所規管，而因此 客戶在海外進行交易所存放款項可能無法享有在香港期貨市場進行交易所獲賦予的相同保障。 期貨經紀行應在客戶協議內披露以下重要披露以下重要 ☐ 貨經紀行 就其代理人之綜合帳戶內持有的客戶資產 而向有關客戶負上法律責任的範圍，及客戶在戶負上法律責任的範圍 ☐ 戶享有其對持有在期貨經紀行於 某結算所開立的綜合帳戶 內的資產的權 ☐ 客戶提供在香港以外地方的期貨市場買賣或結算服務時， 其海外對手方及該期貨市場不受證監會所規管及可能受到有別於《證券及期貨條例》及據此訂立的規則和規例的法律及規例所規管，而因此 客戶在海外進行交易所存放款項可能無法享有在香港期貨市場進行交易所獲賦予的相同保障。 13. 通知規定 (1) 當察覺到任何以下事宜起的 一個營業日內給予證監會書面通知 ： i. 每個交易日結束時所有獲得 優惠保證金待遇 的客戶的分類帳內的 客戶保證金短欠 數額的總額， 超逾量化基準 （設定為該行的速動資金盈餘與可用資金中較高者的50%）; ii. 在期貨經紀行及時和勤勉盡責地評估壓力測試結果時，所識別“超逾該行的速動資金盈餘或可用資金的30%”的任何客戶或關連客戶組別可能無法清繳其預計超蝕款項； iii. 該行的速動資金盈餘或可用資金將不足以承受最大金額的預計超蝕款項的兩個客戶或關連客戶組別的預計超蝕款項，及該行自營帳戶的預計交易虧損； iv. 該行無法或將無法履行任何對手方發出的任何追繳保證金通知。 (1) 當察覺到任何以下事宜起的 一個營業日內給予證監會書日內給予證監 ☐ 個交易日結束時所有獲得 優惠保證金待遇 的客戶的分類帳內的 客戶保證金短欠 數額的總額， 超逾量化基準 （設定為該行的速動資金盈餘與可用資金中較高可用資金中較高 ☐ 期貨經紀行及時和勤勉盡責地評估壓力測試結果時，所識別“超逾該行的速動資金盈餘或可用資金的30%”的任何客戶或關連客戶組別可可用資金中較高可用資金中較高 ☐ 行的速動資金盈餘或可用資金將不足以承受最大金額的預計超蝕款項的兩個客戶或關連客戶組別的預計超蝕款項，及該行自營帳戶的預計可用資金中較高 ☐ 行無法或將無法履行任何對手方發出的任何追繳保證金通知。 (2) 當出現以上(1)的情況向證監會提交通知時， 須要列明有關事宜的全部詳情， 包括: i. 超逾基準的原因及就享有優惠保證金待遇的客戶持倉而承擔的風險； ii. 根據以上(1)情況的相關壓力測試結果，及該等客戶或關連客戶組別在出現該等預計超蝕款項時是否有能力清繳該等虧損進行的相關評估結果；及 iii. 已採取、正採取或將採取的任何風險紓減措施，以減低就享有優惠保證金待遇的客戶持倉而承擔的任何過高風險； iv. 已採取、正採取或將採取的任何跟進行動，以防止出現交收失敗或違反《財政資源規則》下最低速動資金規定的情況； v. 無法或將無法履行任何對手方發出的任何追繳保證金通知的理由， 以及其為糾正或防止有關無法履行有關追繳保證金通知的情況而已採取、正採取或將採取的任何措施。 (2) 當出現以上(1)的情況向證監會提交通知時， 須要列明有關事宜的全部詳 可用資金中較高 ☐ 逾基準的原因及就享有優惠保證金可用資金中較高可用資金中較高 ☐ 據以上(1)情況的相關壓力測試結果，及該等客戶或關連客戶組別在出現該等預計超蝕款項時是否有能力清繳該等虧損進行的相關評估結損進行的相關 ☐ 採取、正採取或將採取的任何風險紓減措施，以減低就享有優惠保證金待遇的客戶持倉而承擔的可用資金中較高 ☐ 中較高可用資金中較高可用資金中較高可用資金中較高可用資金中較高可用資金中較高可用資金中較高用資金中較 ☐ 法或將無法履行任何對手方發出的任何追繳保證金通知的理由， 以及其為糾正或防止有關無法履行有關追繳保證金通知的情況而已採取、正採取或將採取的任何措施。

Review of Custody of Virtual Assets Compliance Impact Alert: Custody of Virtual Assets Aug 2025 Disclaimer: Contents contained in this document including should not be regarded as a substitute legal and / or compliance advice in any circumstances and shall not be reproduced (in whole or in part), distributed or otherwise passed on to any other person without our prior written consent. Language: English version only I. INTRODUCTION Overview The Securities and Futures Commission (“ SFC ”) has issued a guidance on expected standards for the safe keeping of client’s virtual assets held by SFC-licensed virtual asset trading platform (“ VATP ”) operators and their associated entities (collectively, “ VA Operators ”). Compliance with the guidance will address potential vulnerabilities exposure and provides good market practices to VA Operators. General We do not accept or assume responsibility for the ongoing update of the contents of this Compliance Impact Alert document in accordance with the applicable regulatory requirements nor to any person reliance upon the contents of this document. For the avoidance of doubt, the information contained in this document is for reference only and should not be considered as a complete set of regulatory requirements. In case there is any conflict regarding contents or understanding between this document and the Full Circular, the Full Circular shall prevail. For all purposes, the English version of this document shall be original. In the event of any subsequent translation into any other language, this English language version shall prevail. Construction Unless the context otherwise requires, all terms used in this document shall bear the same meaning as in the Guidelines for Virtual Asset Trading Platform Operators (“ VATP Operator Guideline ”), Management, Supervision and Internal Control Guidelines for Persons Licensed by or Registered with the Securities and Futures Commission (“ Internal Control Guidelines ”).All singular terms and expressions shall have the same meanings in plural forms, and vice versa. A reference to any gender also denotes to other genders. II. OVERSEAS INCIDENTS ON VA PLATFORMS Below highlights the reported cybersecurity incidents affecting overseas virtual asset platforms which resulted in substantial financial losses. 1. Compromised third-party wallet solutions – attackers injected malicious code which altered platform user interface. 2. Inadequate access control – allowed unauthorized access to approval devices. 3. Insufficient systematic and independent verification of transactions – failed to prevent fraudulent activities. 4. Blind approval of transactions - signers approved forged transactions without verifying the details of the content. These incidents highlight critical vulnerabilities in virtual asset custody and offer actionable lessons for institutions, exchanges, and individual users. The SFC conducted a targeted review of VA Operators’ custody control measures to assess their resilience against similar vulnerabilities. Based on its findings, the SFC determined that key control measures implemented by VA Operators were insufficient. To address these gaps, the SFC established minimum requirements as a guide aiming to foster a standardized framework and promoting best practices in virtual asset custody. III. SFC EXPECTED STANDARDS The following standards elaborate on the SFC’s guidance in its VATP Operator Guideline and related FAQs and thematic guidance. Scope Expected Standards 1. Senior Management Responsibilities Ensure effective policies, procedures and internal control are in place. Suitable, qualified and experienced individuals are appointed to oversee the daily operation of the business. At least, one Responsible Officer or Manager-in-Charge to oversee the daily operation related to VA custody. 2. Client Cold Wallet Infrastructure Establish and implement strong internal controls and governance procedures for private key management to ensure all cryptographic seed and private keys are securely generated, stored and backed up. Perform appropriate due diligence on Hardware Security Modules (“ HSM ”) provider before engagement and an ongoing basis. Conduct proper due diligence to ensure that HSM vendor is capable of continuous and committed in maintaining HSM security. 3. Client Cold Wallet Operation Using air-gapped devices for seed and private key generation and safeguarding. Conduct a regular review on any material changes or modifications to processes, systems or authorized personnel before implementation. Implement a robust systematic control to prevent unauthorized transactions from the cold wallet. Using a dedicated device with restricted functionality and limited connectivity for transaction approval, with integrity checks and physical access restrictions. Displaying transaction details in a clear, human-readable format allowing signers to review the information before proceeding. 4. Use of Third-party Providers Maintain continuous oversight, evaluating security controls, incident reporting, and disaster recovery capabilities. Strict segregation of duties and oversight mechanisms for wallet system code management. Establish emergency procedures and conduct regular Business Continuity Plan (“ BCP ”) drills. 5. Ongoing Real-time Threat Monitoring Real-time reconciliation of on-chain client assets with the ledger balance. Ensure alert thresholds are effectively calibrated for timely detection of potential issues. Robust mechanisms to detect unauthorized intrusions to critical wallet infrastructure. Monitoring processes should cover both custody system and its dependencies. Security Operations Centre (“ SOC ”) or equivalent function should ensure 24/7 monitoring on its security processes. Develop a structured framework for handling security alerts and managing incidents according to severity and risk levels. 6. Training and Awareness Transaction signers must undergo comprehensive training to fully understand verification requirements and appropriate handling procedures. Effective manual transaction review or approval to prevent blind signing. These expected standards apply to VA Operators only. However, VA custody expectations tend to be replicated across regulated sectors in Hong Kong. Therefore, it is recommended that anyone providing custody services or custody technology solutions consider these requirements and expected standards to mitigate associated risks. IV. KEY ACTIONS AND RECOMMENDATIONS VA Operators must continuously update their systems and process. Below are the key actions recommended in custody of client’s virtual assets. 1. Evaluate custody framework: Strengthen custody controls aligning with the SFC’s guidance for VA Operators. 2. Conduct regular compliance reviews: Integrate expected standards into periodic evaluations. 3. Monitor developments: Stay updated on evolving best practices and regulatory changes, especially as new threats and vulnerabilities surface. 4. Engage with regulators: Consult the SFC when considering adjustments to existing approaches. The ongoing consultation on virtual asset custodian services presents a timely opportunity for such engagement. V. How We Can Help Our team comprises experienced professionals with deep expertise in compliance, risk management, and policy review and development in identifying gaps between the regulatory expectations in the circular and your current policies and procedures. We understand the complexities of regulatory requirements and provide tailored solutions to meet your specific needs and close any material gaps. Our expertise ensures adherence to regulatory standards and enhances overall compliance practices. If you have any questions, please feel free to reach out to your manager-in-charge or our Compliance Support, or Contact Us .

The topics discussed in this monthly newsletter for insurance are as follows: ComplianceOne Insurance Newsletter – November 2025 The topics discussed in this monthly newsletter are as follows: REGULATORY UPDATES IA Issues Circular on Reference Checking Schemes for Licensed Insurance Intermediaries ENFORCEMENT NEWS IA Imposes Restrictive License Conditions on Mighty Divine Insurance Brokers Limited Associated with Prince Group (太子集團) ICAC Secures Jail Sentences for Last Batch of Defendants in $52 Million Dummy Agents Commissions Fraud ICAC Issues Arrest Warrants for Two Individuals Implicated in $3 Million Insurance Commissions Fraud Regulatory News 1. IA Issues Circular on Reference Checking Schemes for Licensed Insurance Intermediaries On 20 November 2025, IA Issues further Circular on the Reference Checking Scheme (the “ Scheme ”) for Licensed Insurance Intermediaries. Addressing the “rolling bad apples” phenomenon “One bad apple spoils the whole barrel” so the old adage goes. In the context of the Scheme, the phenomenon of “rolling bad apples” refer to licensed individuals attempt to evade the consequences of past misconduct by moving principals without proper disclosure. To address the issue of “rolling bad apples”, the Scheme was launched by the Hong Kong Federation of Insurers (“ HKFI ”) by its circular dated 5 July 2025 to be used by its members which are authorized insurers carrying on long-term business from 1 September 2024 onwards. The IA then issued the Circular on 5 July 2024 to endorse and support the Scheme. The Scheme then expanded in Phase 2, jointly launched by the HKFI, the Hong Kong Confederation of Insurance Brokers (“ CIB ”) and Professional Insurance Brokers Association (“ PIBA ”), covers all licensed long-term individual intermediaries to protect policyholders, maintain market confidence, and prevent misconduct from spreading. Effective Date With effect from 1 January 2026 , the Scheme will be expanded to cover all appointment of all individuals licensed intermediaries carrying on long term insurance business. Non-compliance may lead to supervisory scrutiny or disciplinary action by the IA. Scope and Application Applies to appointments of prospective intermediaries (the “ Candidates ”), including: licensed individual insurance agents; technical representatives (agent); or technical representatives (broker) (collective as “ TRs ”); for regulated activities in long-term business . As a Recruiting Principal, conduct reference checks on candidates with past 7 years of relevant experience. Check only the THREE most recent appointments if multiple. Excludes agencies that are authorized institutions under Banking Ordinance (potential integration with banking scheme ongoing). Summary of the Scheme Making a Reference Checking Request (as Recruiting Principal) Before appointing for long term activities, conduct reference checks on THREE most recent appointments within Past 7 years. · Use Annex 1A template to request info from responding principals. · Obtain written consent from candidates via Annex 2A form , authorizing checks, disclosure, and exempting contractual limits. If candidates refuse to provide consent or withdrawn the provided consent, should NOT appoint. For group companies, one entity can conduct checks for reliance, but each remains accountable with access to results. Responding to a Reference Checking Request (as Responding Principal) Upon received the Reference Checking Request from Recruiting Principal: · Complete and return info within 15 days; · If delayed, send interim reply with reason and expected final (max 2 months , exceptional only, approved by * KPIM/RO or delegate). *KPIM - key person in control function for intermediary management; RO - Responsible Officer. After submitting the first round of reference checking requests, respond to any further clarification requests within 15 days, if applicable. Recruiting Principal may assume that no further clarification to be provided by Responding Principal. Assessment by the Recruiting Principal (as Recruiting Principal) Discretion in Decisions : Recruiting principal has full discretion to appoint based on all info, including references. Evaluate adverse info considering nature, timing, explanations, and recurrence risk. Responding principals may voluntarily add material facts. Opportunity to Be Heard : For fairness, provide candidates chance for representations if adverse info may block appointment; share reference copy. No need to reopen investigations or seek more from responders. Proceeding with Adverse Records : Document assessment and justification for appointing despite issues; endorsed by KPIM/RO. Ongoing Assessment : If Responding Principal declare further information to provide, the reference process may consider complete once the Recruiting Principal assesses available information and decides on appointment ( must document the justification with KPIM/RO endorsement ). Pre-Appointment & Post-Appointment (as Recruiting Principal) Pre-Appointment If the Recruiting Principal decides to appoint despite adverse records from reference checks, they must document the assessment and justification, which requires endorsement by KPIM/RO. Post-Appointment If additional information arrives after appointment, the Recruiting Principal has full discretion to use it for ongoing evaluation, including potential actions like terminate the appointed candidate. Records and Communications (All Principals engaging Long-term business) Record Keeping For Insurance Broker Company engaging Long-Term Business: · Maintain records of resigned TRs for at least 7 years (or per internal policy, not longer than necessary under PDPO). · For unsuccessful application, retain max 2 years unless reason or consent. IIC Centralized Contact Database IA will maintain centralized contact database contain all participating principals via IA’s e-portal - Insurance Intermediaries Connect (“ IIC ”). As a safeguard, responding principals are not required to reply to reference check requests unless sent from the valid designated email address recorded in the contact database. Reference Checking Schemes Materials The Circular attached with relevant materials including: I. Main Paper – Details of the Schemes and Procedures II. Annex 1A – Template III. Annex 2A – Consent Form IV. FAQ for Licensed Entities V. FAQ for Licensed Individuals Attachment: Reference Checking Schemes Materials 附件: 保險中介人背景查核計劃資料 SIGNIFICANCE: This Scheme reinforces the IA's commitment to maintaining high standards of conduct and integrity in Hong Kong's insurance sector by preventing the recirculation of unfit intermediaries. By mandating structured reference checks, it enhances policyholder protection, reduces risks of misconduct, and promotes a more transparent and accountable industry. Insurers and intermediaries should review their hiring processes promptly to ensure compliance, as this could mitigate potential regulatory risks and foster greater trust in the market. Enforcement News 2. IA Imposes Restrictive License Conditions on Mighty Divine Insurance Brokers Limited Associated with Prince Group (太子集團) The Prince Group (太子集團) founded by Chen Zhi (陳志), has been implicated in operating telecom fraud parks in Cambodia, with Chen Zhi facing US prosecution and sanctions, including the freezing of approximately HK$120 billion in Bitcoin assets. On 28 October 2025, IA Imposes Restrictive License Conditions on Mighty Divine Insurance Brokers Limited (“ Mighty Divine ”) - Associate Company with Prince Group. The conditions prohibit the company from conducting, or representing itself as conducting, any regulated activities as defined under the Insurance Ordinance (Cap. 41) . Details of the Licensed Corporate: Name (EN) Mighty Divine Insurance Brokers Limited Name (CN) 美迪保險經紀有限公司 Licence No. FB1329 License Type Insurance Broker Company Line(s) of Business General & Long Term Business (excluding Linked Long Term Business) Business Address FLAT/RM 803, 8/F, 68 KIMBERLEY ROAD, TSIM SHA TSUI, KL Responsible Officer(s) Nill (as of 28 Oct 2025) For more details, please refer to Register of Licensed Insurance Intermediaries Conditions of the License 1) The licensee is restricted from carrying on, or holding out to carry on, any regulated activities under the Insurance Ordinance (Cap. 41) (“IO”); 2) Without prejudice to the generality of condition (1) above, and subject to condition (3) below, the licensee shall not receive, hold, or deal with any monies as specified in section 71(2) of the IO (i.e. (a) monies received by the company from or on behalf of a policy holder or potential policy holder for or on account of an insurer in connection with a contract of insurance; and (b) monies received by the company from or on behalf of an insurer for or on account of a policy holder or potential policy holder.) (“Client Monies”); and 3) The licensee may be involved in arranging the transfer, remittance or payment of, or otherwise deal with, Client Monies in accordance with the requirements under the IO and the Insurance (Financial and Other Requirements for Licensed Insurance Broker Companies) Rules (Cap. 41L), provided that (i) it acts in compliance with all applicable laws and regulatory requirements; and (ii) it has obtained the prior written consent of the Insurance Authority. 3. ICAC Secures Jail Sentences for Last Batch of Defendants in $52 Million Dummy Agents Commissions Fraud On 21 November 2025, the Hong Kong District Court sentenced the final six defendants in a major corruption case investigated by the Independent Commission Against Corruption (“ ICAC ”), involving a $52 million fraud scheme (the ” Scheme ”) orchestrated through dummy insurance agents at: FWD Life Insurance Company (Bermuda) Limited (富衛人壽保險(百慕達)有限公司) (“ FWD ”); and Sun Life Hong Kong Limited (香港永明金融有限公司) (“ Sun Life ”). Case Summary The scheme, masterminded by LO Yin-wa (“ LO ”), a former FWD branch manager who was earlier sentenced to 46 months' imprisonment, involved recruiting dummy agents who falsely represented themselves as handlers of 478 high-commission insurance policies between February 2016 and November 2020. This deception led to the release of over $52 million in commissions, incentives, bonuses, and allowances, most of which were funneled back to LO through laundered bank accounts. The majority of the policies lapsed due to non-payment of subsequent premiums. FWD and Sun Life provided full cooperation during the ICAC investigation, which stemmed from a corruption complaint. Enforcement Act and Court Order The last six defendants, aged 25 to 39 and acting as purported insurance agents were convicted or pleaded guilty to charges of conspiracy to defraud and conspiracy to deal with property known or believed to represent proceeds of an indictable offense, with sentences ranged from 12 to 21 months' imprisonment. i. LEUNG Tsz-wing (梁紫穎) ii. MO Wing-han (毛詠嫻) iii. WOO Kin-leung (胡健良) Entered Guilty Pleas iv. LO Nga-wing (羅雅穎) v. NGAN Tsz-ting (顏梓定) vi. KONG Tsz-ying (江梓瑩) Convicted After Trial A total of 17 defendants faced 20 charges in the case, with 10 other dummy agents previously sentenced to terms ranging from 11 to 22 months. SIGNIFICANCE: The ICAC continues to prioritize integrity in the insurance sector, offering training and resources like the Corruption Prevention Guide for Insurance Companies to mitigate such risks. The judge also reprimanded the defendants for breaching professional conduct standards, noting they were lured into the offenses by the main culprit. This case highlights the severe consequences of integrity breaches in the insurance industry, emphasizing the need for robust internal controls, agent verification processes, and anti-fraud measures to prevent dummy agent schemes that erode public trust and cause financial harm. 4. ICAC Issues Arrest Warrants for Two Individuals Implicated in $3 Million Insurance Commissions Fraud The ICAC has issued arrest warrants for NG Ho-lun (吳浩麟) (“ NG ”) and Kuzca CHIK Sin-deon, formerly known as Pan CHIK Ka-tung (戚善惇, 前稱戚加彤) (“ CHIK ”), two key figures in an alleged insurance fraud scheme that defrauded: Sun Life Hong Kong Limited (香港永明金融有限公司) (“ Sun Life ”); and China Taiping Life Insurance (Hong Kong) Company Limited (中國太平人壽保險(香港)有限公司) (“ Taiping Life ”); of approximately $3 million in commissions, bonuses, and allowances through bogus policies and false representations. Case Summary The case, which involves recruiting family members, friends, and police officers as dummy agents and policyholders, stems from corruption allegations and has led to charges against eight individuals total, with six already charged and appearing in court. On 6 November 2025, the case against the six charged defendants were transferred from the Eastern Magistrates’ Courts to the District Court for plea on 27 November 2025. The defendants face 21 charges. See below table for the Six Charged Defendants Details: Role/Relationship Name Police Sergeant LAM Hin-ho (林顯豪) LAM Hin-ho’s brother LAM Chun-pong (林振邦) LAM Hin-ho’s sister-in-law YU Xiaodan (余曉丹) LAM Hin-ho’s friend LAU Chun-yee, formerly known as LAU Man-yee (劉臻頤, 前稱劉敏儀) Solicitor Osbert HUI Yee (許懿) Police Constable SZE Hong-chak (施匡澤) For more details of the case, please refer to Topic 4 of ComplianceOne Insurance Newsletter – October 2025 Details of Two Wanted Individuals Name Former Positions Role in Fraud Fraud Conducted NG Ho-lun Regional Director of Sun Life; Senior Branch Manager of Taiping Life Central role in orchestrating the fraud Recruited individuals (including LAM Hin-ho’s family, friends, and police colleagues) as dummy downline agents and policyholders; Took out 20 insurance policies, paying premiums while falsely claiming they were settled by genuine policyholders; Ensured false claims of agent interviews; Conspired with LAM Hin-ho and LAU Chun-yee to create false academic qualifications for LAU's recruitment. Kuzca CHIK Sin-deon (formerly Pan CHIK Ka-tung) Insurance Agent of Sun Life Participated in recruitment and posed as a dummy agent Contributed to false representations to insurers; Deceived insurers into believing applications were legitimate and interviews occurred, leading to fraudulent commissions. SIGNIFICANCE: This case underscores the vulnerabilities in the insurance sector to internal fraud schemes involving unlicensed or dummy intermediaries, particularly when intertwined with public servants like police officers, potentially eroding public trust in both law enforcement and financial institutions. The ICAC's proactive investigation and pursuit of fugitives highlight the importance of robust verification processes for policy applications, agent qualifications, and commission payouts to prevent such exploitation. Insurers are urged to enhance anti-fraud measures, including cross-verification of applicant interviews and premium sources, while collaborating with regulators to maintain industry integrity and protect policyholders from systemic risks. [End of ComplianceOne Insurance Newsletter – November2025] 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

Considering the amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Chapter 615), a new registration regime for Dealers in Precious Metals and Stones (“DPMS”) on 1 April 2023. Online Training Program for - Dealers in Precious Metals and Stones (DPMS) 貴金屬及寶石交易商 (DPMS) - 線上持續培訓課程 Considering the amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Chapter 615), a new registration regime for Dealers in Precious Metals and Stones (“DPMS”) on 1 April 2023. The Hong Kong Customs and Excise Department (the “Customs”) is responsible for implementing this system and supervising the compliance of registered dealers with anti-money laundering and counter-terrorist financing (“AML-CFT”) regulations. To help regulated cooperate (including DPMS) stay updated on the latest regulatory requirements, we have launched a series of online courses. These courses are designed to ensure that dealers can grasp and adhere to the latest compliance standards, with content that is continuously updated and revised. Click Thinkific platform link - About the Precious Metals and Stones Dealers Training 根據《打擊洗錢及恐怖分子資金籌集條例》（第615章）的修訂，香港於2023年4月1日引入了貴金屬及寶石交易商（DPMS）的註冊制度。香港海關負責該制度的執行，並監管註冊交易商在打擊洗錢及恐怖分子資金籌集方面的合規性。 為了幫助貴金屬及寶石交易商持續了解最新的法規要求，我們特別開設了一系列在線課程。這些課程旨在確保交易商能夠掌握並遵守最新的合規標準，並會持續更新及修訂内容。 點擊Thinkific平台連結 - 關於貴金屬及寶石交易商培訓課程 Training Program Each session lasts 1 hour and is conducted through the Thinkific platform. After completing the training and passing a short quiz, participants will receive a certificate of participation. You can also log in to Thinkific at any time to review your training records. Intended Audience: Dealers in precious metals and stones Management personnel Compliance officers Money laundering reporting officers Frontline staff Back-office staff New employees Training Topics Include: Registration Guide for DPMS Overview of the registration background for DPMS Obligations and responsibilities AML-CFT requirement Duties for senior management Joint Financial Intelligence Unit - Reporting Suspicious Transactions How to identify suspicious transactions Reporting process and requirements Protective measures and legal responsibilities Case studies and practical applications Conduct and Ethical Definition and importance of business ethics Conduct and integrity Compliance and ethical decision-making Case discussions and industry best practices 關於培訓課程 每節課程為1小時，透過Thinkific平台參與課堂。培訓結束後，只要通過簡短的測驗，即可獲發參與證書。你亦可隨時登錄Thinkific檢閱培訓記錄。 適用人士 : 貴金屬及寶石交易商 管理人員 合規主任 洗錢報告主任 前線職員 後勤職員 新入職人員 課程的題材範圍包括: 貴金屬及寶石交易商註冊指引 金屬及寶石註冊制度的背景簡介 註冊人的責任 相關法例和法定責任 反洗錢系統/制度/核心要求 各職位的責任 聯合財富情報組 - 舉報可疑交易 如何識別可疑交易 舉報流程及要求 保護措施及法律責任 案例分析與實務操作 商業行為和道德標準 商業道德的定義與重要性 職業操守與誠信 法規遵循與道德決策 實例討論與行業最佳實踐 Why ComplianceOne? Professional : Our courses are specifically designed for DPMS to ensure your acknowledgement of the latest compliance knowledge and skills. Flexible: You can log in to Thinkific platform to start or review your training records, anytime, anywhere. Easy access: The Platform supports multiple devices, no installation needed, all you need is a browser. Certification : After finished the training, certificate will be provided for enhancing your professional credentials and credibility. Payment Method: Convenient payment methods by using Visa credit card or PayPal. Courses are valid for 365 days after purchase. During this period, you can log in to Thinkific platform to take course or print certificates at any time. 為什麼選擇天匯合規的網上持續培訓平台？ 專業培訓 ：我們的課程專為貴金屬及寶石交易商設計，確保您獲得最新的合規知識和技能。 靈活學習 ：您可以根據自己的時間安排進行學習，並隨時登入平台檢閱培訓記錄。 簡單易用 ：網上持續培訓平台支援多種裝置，無需安裝，操作簡單。 獲得認證 ：通過簡短測驗後即可獲得參與證書，提升您的專業認證和可信度。 支付方式 ：接受 Visa信用卡或PayPal方式支付，方便快捷。 課程在購買後365天內有效。在此期間，您可以隨時登入Thinkific平台參加課程或列印證書。

The topics discussed in this monthly newsletter for insurance 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 insurance are as follows: ComplianceOne Newsletter – July 2025 The topics discussed in this monthly newsletter are as follows: REGULATORY UPDATES Implementation of regulatory regime for stablecoin issuers Itinerant Professional are allowed to stay longer each calendar year SFC will amend the FRR to foster market developments for OTC derivatives and other products Anti-Scam Consumer Protection Charter 3.0 MARKET NEWS Latest SFC Report shows growing AUM and net fund inflow to Hong Kong SFC hosts meeting to promote industry collaboration in Hong Kong’s digital asset sector HKEX launched Order Routing Service on its Integrated Fund Platform ENFORCEMENT NEWS SFC and ICAC Launch Joint Operation "Leverage" Against Suspected Market Manipulation Syndicate The court-appointed administrator distributed $19 million in assets to clients of Hong Kong Wan Kiu Investment MMT Rules Former Dan Form Company Secretary and Associate Guilty of Insider Dealing Regulatory Updates 1. Implementation of regulatory regime for stablecoin issuers The Hong Kong Monetary Authority (“ HKMA ”) announced the implementation of the regulatory regime for stablecoin issuers which has come into effect on 1 August 2025 (the commencement date). A bundle of documentations has been published as below: Consultation conclusions on the Guideline on Supervision of Licensed Stablecoin Issuers and the finalized Guideline on Supervision of Licensed Stablecoin Issuers ; Consultation conclusions on the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Stablecoin Issuers) and the finalized Guideline on AML & CFT (For Licensed Stablecoin Issuers) ; Explanatory Note on Licensing of Stablecoin Issuers on various aspects of the licensing regime and application process; Explanatory Note on Transitional Provisions for Pre-existing Stablecoin Issuers As we are just on the inception stage of the stablecoin licensing regime, and no license has been granted yet, we will focus more on the initial transitional period where interested parties : are encouraged to contact the HKMA before 31 August 2025 , showing their intention to apply for a license; and the HKMA will communicate with the applicants, conveying to them the regulatory expectations and provide feedbacks as appropriate; which consider themselves sufficiently ready and wish to be considered early should submit an application to HKMA by 30 September 2025 . Key takeaways of the “ Explanatory Note on transitional provisions for pre-existing Stablecoin Issuers ” (“Note”): The Stablecoin Ordinance (SO) effective 1 August 2025 defines Regulated Stablecoin Activities (RSA), including issuing specified stablecoins in Hong Kong or those pegged to the Hong Kong Dollar from outside. Transitional provisions under Schedule 7 of the SO, detailed in this Explanatory Note, apply specifically to Pre-existing Issuers (PEIs). PEIs are entities that substantively carried on RSA in Hong Kong before 1 August 2025; mere "shell" operations do not qualify. These provisions give PEIs time to either apply for a license or wind down their operations. PEIs wishing to continue must submit a formal license application, a written declaration of prior RSA activity, and a written undertaking to comply with regulations to the HKMA by 31 October 2025. Meeting this deadline grants "Application Submitted and Acknowledged" (APSA) status, allowing continued RSA operation until 31 January 2026. During this period, the HKMA assesses APSA entities and may grant a Provisional License, a Full License, issue a Rejection Notice, or refuse the application. PEIs that miss the 31 October deadline, or whose application is rejected, refused, or withdrawn, must enter a closing down period. These entities have one month from the trigger event (e.g., rejection date or 1 November 2025 for non-applicants) to cease RSA activities, operating only to effect an orderly shutdown. SIGNIFICANCE: The RSA licensing process of the HKMA looks alike to that of the VA licensing regime adopted by the SFC, starting with transitional period, provisional license, mutual and interactive communication with the applicants by the regulatory body, with assessment and final determination of license approval. It demonstrates the effectiveness of such pragmatic approach with interactive adjustment through bilateral communication and feedback, and the applicants are given the entire roadmap whether to go or to quit! 2. Itinerant Professional are allowed to stay longer each calendar year The SFC is joining regulators across the globe to curb activities of unlawful financial influencers (“ finfluencers ”) who are putting millions of social media users at risk by touting financial products or services illegally. To achieve this aim, the SFC and the other members of the International Organization of Securities Commissions (“ IOSCO ”) are participating in the “Global Week of Action Against Unlawful Finfluencers” during the week of 2 June 20The SFC post a circular in July 2025 which enhanced measure to facilitate visiting professionals to conduct regulated activities or provide virtual asset service (VA service) in Hong Kong. Current arrangement visiting professionals from an overseas group company of a licensed corporation or licensed provider can choose to apply for a representative licence to be an itinerant professional (“ ITP ”) for providing services in Hong Kong for a short period of time each year to (a) conduct regulated activities on behalf of the licensed corporation; or (b) provide VA service on behalf of a licensed provider, under company of a licensed person at all times; the ITPs are only allowed to stay not more than 30 days each calendar year, and the license is imposed with a condition to this effect ( existing ITP condition ). Revised measure to facilitate and provide more flexibility to visiting professionals to conduct these activities in Hong Kong, the SFC is now extending the period to 45 days each calendar year; it should be noted that the application process, and any exemptions for ITPs remain unchanged; the new condition of extended period is applicable to all existing licensed ITPs, and the SFC will replace their existing ITP condition with a 45-day period accordingly. 3. SFC will amend the FRR to foster market developments for OTC derivatives and other products The SFC launched a public consultation on draft amendments to the Securities and Futures (Financial Resources) Rules (FRR) and related guidelines for implementing a set of internationally comparable capital requirements for licensed corporations (LCs) engaging in over-the-counter derivative activities (“ OTCD capital requirements ”) Under the current proposal, and after a couple of consultations papers & conclusions in 2015 and 2017 respectively before, the OTCD capital requirements previously proposed have been fine-tuned with reference to recent changes to Hong Kong’s Banking (Capital) Rules and the Basel Framework. Some key takeaways from the public consultation (please refer to original for details) the capital requirements for inter-dealer brokers will also be significantly lowered, and the introduction of OTCD in various licenses as below with substantial reduction in capital requirements (reference to APPENDIX 2 regarding details of the proposed minimum capital requirements): (i) LCs conducting OTCD dealing under Type 1, 2, 3 or 11 regulated activity; (ii) LCs conducting OTCD clearing under Type 12 regulated activity; (iii) LCs operating OTCD platform under Type 7 regulated activity; (iv) LCs conducting OTCD advising under Type 4, 5 or 11 regulated activity; (v) LCs conducting OTCD asset management under Type 9 regulated activity Some major incidental and technical changes with respect to: (i) minimum capital requirements (ii) market risk (iii) counterparty credit risk (iv) sundry requirements some substantial amendments to the Securities and Futures (Financial Resources) Rules as compared with the previous 2017 version proposed exemption of capital requirements for centrally-cleared repurchase transactions (repos) to promote central clearing in Hong Kong and the development of the city’s inter-dealer repo market SIGNIFICANCE: As Dr. Eric Yip, the SFC’s Executive Director of Intermediaries, has said, “ To reinforce Hong Kong’s status as an international financial centre, it is crucial to align our OTCD capital requirements with global standard .” Licensed corporations which are keen to engage in OTCD business are strongly advised to take a look and assess if they can fulfil the capital and regulatory requirements with the facilitations proposed. 4. Anti-Scam Consumer Protection Charter 3.0 The Hong Kong Monetary Authority (“HKMA”), the Securities and Futures Commission (“SFC”), the Insurance Authority (“IA”) and the Mandatory Provident Fund Schemes Authority (“MPFA”) together announced the launch of the Anti-Scam Consumer Protection Charter 3.0 (the Charter 3.0) which is fully supported by the Consumer Council, the Hong Kong Association of Banks, the Hong Kong Police Force, and the Office of the Communications Authority. Leveraged with success of previous versions, the Charter 3.0 is enhanced in anti-scam actions by collaboration with the financial regulators, technology firms and telecommunications firms in combatting financial scams. Six principles focused of the Anti-Scam Consumer Protection Charter 3.0 are: (1) Reporting Functions for Users. (2) Reporting Channels for Financial Regulators. (3) Checking of Advertisers. (4) Internal Monitoring Processes. (5) Enforcement of Terms of Service, (6) Collaboration on Public Awareness. During the launch event, executives from various sectors engaged in productive discussion on the latest trends of financial frauds/scams and their collaborative efforts for the common purpose of combatting such frauds and scams. SIGNIFICANCE: Mr Eddie Yue, Chief Executive of the HKMA, said, “ The fight against financial frauds and scams and to protect the public requires a united front, …. The Charter 3.0 represents a significant milestone in this endeavour, harnessing the collective strength of the financial, technology, and telecommunications industries to better safeguard the public .” Ms Julia Leung, Chief Executive Officer of the SFC, added, “ This initiative not only echoes global governments and regulators’ call to action but also positions Hong Kong as a leader in safeguarding the financial world’s digital future. Together, we are building a safer, more responsible online landscape that prioritises vigilance, collaboration, and public trust .” And Mr Clement Cheung, Chief Executive Officer of the IA, said, “ The IA will leverage on this platform to strengthen public education and empower policy holders so that they can safeguard effectively against the increasingly sophisticated plots concocted by swindlers. ” Finally, Mr Cheng Yan-chee, Managing Director of the MPFA, said, “ We urge the working population to stay vigilant and join hands with us by proactively reporting suspected scams to safeguard their MPF interests. ” Though the executives represent interests in their own fields, the Charter 3.0 really achieves concerted efforts by spearheading towards a common goal of combating frauds and scams. Market News 5. Latest SFC Report shows growing AUM and net fund inflow to Hong Kong A growth in Hong Kong's asset and wealth management sector, as revealed in the SFC 2024 Asset and Wealth Management Activities Survey . Released on 16 July 2025, the report underscores Hong Kong's rising prominence on the global stage amid evolving market dynamics. Hong Kong continues to solidify its position as a leading international asset and wealth management center, with assets under management (“ AUM ”) climbing 13% year-on-year to HK$35.1 trillion (US$4.53 trillion) by the end of 2024. This surge was fuelled by net fund inflows of HK$705 billion (US$91 billion), marking an 81% increase from the previous year. Noteworthy Developments Private Banking and Wealth Management Growth The AUM in this segment rose 15% to HK$10.4 trillion (US$1.3 trillion), highlighting strong investor confidence. SFC-Authorized Funds Shine Hong Kong-domiciled funds saw their net asset value (“ NAV ”) jump 22% to HK$1.64 trillion (US$211 billion) by year-end 2024, with further growth of 21% to HK$1.99 trillion (US$256 billion) by May 2025. Net inflows reached HK$163 billion (US$20.9 billion) in 2024, followed by an impressive HK$237 billion (US$30.5 billion) in the first five months of 2025. The number of such funds also expanded to 954 in 2024 and 987 by May 2025. Fund Inflows Surge The asset management and fund advisory business recorded a staggering 571% increase in net inflows to HK$321 billion (US$41.3 billion). Open-Ended Fund Companies (OFCs) Registrations soared 93% in 2024, as managers leveraged Hong Kong's corporate fund structures and government grants. Mainland-Related Firms Thrive Their AUM grew 15% to HK$3.1 trillion (US$397 billion), with net inflows up 68%, marking five consecutive years of outperformance. Licensed Firms Expansion The number of firms licensed for asset management (Type 9 regulated activity) increased 4% to 2,212. Asset managers in Hong Kong are increasingly diversifying their portfolios, allocating 59% of assets outside Mainland China and Hong Kong. Non-equity investments have grown by 13 percentage points over the past five years, now comprising 59% of holdings, as firms adapt to global shifts. These findings align with the Boston Consulting Group's (BCG) Global Wealth Report 2025 , which ranks Hong Kong alongside Switzerland as one of the world's top two cross-border wealth centers. In 2024, Hong Kong achieved the highest absolute growth in cross-border wealth at US$231 billion, with a 9.6% year-on-year increase outpacing the global average. It is on track to surpass Switzerland as the leading global hub for offshore asset management by 2028. SIGNIFICANCE: Ms. Christina Choi, SFC's Executive Director of Investment Products, commented: " Hong Kong is gaining more clout than ever as a leading international hub for asset and wealth management, propelled by strong fund inflows, financial innovation, and a growing talent pool. The SFC is committed to supporting Hong Kong’s continued advancement as a full-service international financial centre and a leading offshore renminbi hub through fixed income and currency market developments. " The survey, which included 1,237 participating firms, covers asset management, fund advisory, private banking, private wealth management, SFC-authorized real estate investment trusts, and assets under trusts. Note that it excludes entities like single family offices, sovereign wealth funds, and government direct investments. 6. SFC hosts meeting to promote industry collaboration in Hong Kong’s digital asset sector On 7 July 2025, the SFC held the second meeting of the Digital Asset Consultative Panel (“ DACP ”), highlighting progress in regulatory innovation and industry collaboration. The SFC convened the meeting with licensed virtual asset trading platforms (“ VATPs ”), fostering dialogue on key market and regulatory advancements in Hong Kong's digital asset sector. Discussions centered on initiatives under Pillars A (Access) and P (Products) of the SFC’s ASPIRe roadmap , including proposals for new regulatory frameworks for virtual asset dealing and custodian providers, as well as enhancements in market accessibility and product offerings. This engagement underscores the SFC's commitment to building a sustainable, competitive digital asset environment while prioritizing investor protection. “A-S-P-I-Re” Roadmap: Pillar A (Access) Streamline market entry through regulatory clarity Pillar S (Safeguards) Optimising compliance burdens without compromising security Pillar P (Products) Expand product offerings and services based on investor categorisation Pillar I (Infrastructure) Modernise reporting, surveillance and cross-agency collaboration Pillar Re (Relationships) Empower investors and industry through education, engagement and transparency SIGNIFICANCE: Dr Eric Yip, the SFC’s Executive Director of Intermediaries and chair of the DACP, stated: “ Today’s DACP meeting is constructive and insightful, underscoring the importance of engagement with licensed VATPs in nurturing a sustainable and competitive digital asset ecosystem. The SFC remains committed to maintaining global competitiveness while ensuring robust investor protection and local safeguards within the digital asset sector .” 7. HKEX launched Order Routing Service on its Integrated Fund Platform On 3 July 2025, the SFC welcomed the rollout of HKEX's Order Routing Service on the Integrated Fund Platform (“ IFP ”) , marking a pivotal step in enhancing Hong Kong's retail funds ecosystem. This service streamlines communication among market participants, fostering greater collaboration within the fund distribution network. What is the Integrated Fund Platform (IFP)? IFP is a business-to-business fund services platform developed with the support of the Hong Kong Special Administrative Region (HKSAR) Government and the SFC. Key features and services include: Fund Repository : An online database featuring all SFC-authorized fund products, providing transparency and helping investors make informed decisions. Launched in 13 December 2024 . Order Routing Service : Connects distributors, fund houses, and transfer agents to facilitate subscriptions and redemptions, improving operational efficiency. Upcoming Services : Platform and Nominee Services are expected to be rolled out subject to regulatory approvals. SIGNIFICANCE: Ms Christina Choi, the SFC’s Executive Director of Investment Products, remarked: “ By enhancing the connectivity between various market participants, the Order Routing Service can help significantly improve the efficiencies of the fund distribution ecosystem. This is expected to contribute to cost optimisation in the fund sales chain, which will also strengthen the overall competitiveness of the Hong Kong retail funds marke t.” The SFC expressed gratitude for industry support and pledged ongoing collaboration with HKEX and stakeholders to ensure the IFP's full implementation. Enforcement News 8. SFC and ICAC Launch Joint Operation "Leverage" Against Suspected Market Manipulation Syndicate On 25 July 2025, the SFC and Independent Commission Against Corruption (“ ICAC ”) announced the results of a joint operation conducted on July 23, codenamed " Leverage " targeting a sophisticated syndicate accused of manipulating shares of a listed company and engaging in corrupt practices. The operation involved searches at 14 locations, including the listed company's offices and SFC-licensed brokers. Key details from the investigation include: Arrests : The ICAC arrested a former chairman and a former executive director of the listed company under the Prevention of Bribery Ordinance. Alleged Scheme : The syndicate is suspected of using false documents, such as internal records and public announcements, to fabricate a share subscription agreement and joint venture with a Mainland company worth over HK$20 million. They allegedly created a false market appearance through nominee accounts. Additional Misconduct : The former executive director, who was also a responsible officer and director of a broker, is accused of accepting advantages from the former chairman and misappropriating client shares valued at approximately HK$9 million. Detection and Collaboration : The SFC initially identified suspicious trading, referring corruption aspects to the ICAC while handling market misconduct under the Securities and Futures Ordinance (“ SFO ”). The operation follows the Memorandum of Understanding between the SFC and ICAC. SIGNIFICANCE: The listed company's shares have been suspended since March 2025 due to a court-ordered liquidation. Suspected offenses include bribery, using false documents, handling proceeds of crime under the Organized and Serious Crimes Ordinance, and market manipulation under the SFO. 9. The court-appointed administrator distributed $19 million in assets to clients of Hong Kong Wan Kiu Investment On 23 July 2025, the SFC reported that court-appointed administrators have distributed around $19 million worth of assets as compensation to impacted clients of Hong Kong Wan Kiu Investment Company Limited (“ HKWK ”), a corporation licensed by the SFC for Type 1 regulated activity. This distribution, completed this month, follows the Court of First Instance's approval in January 2025 and stems from final court orders granted in November 2022 under section 213 of the Securities and Futures Ordinance (SFO). HKWK investigation Case Recap The SFC's actions originated from an investigation uncovering financial irregularities at HKWK. Findings revealed that HKWK and its sole director and shareholder, Connie Sham Khi Rose, had unauthorizedly sold client securities, misappropriated proceeds totalling about $58 million between 2011 and 2019, and falsified statements to hide the activities. The case was referred to the Police, leading to criminal prosecution by the Department of Justice. In the High Court, Sham, aged 88, pleaded guilty and was sentenced on 3 July 2025, to 160 hours of community service, considering her remorse and personal compensation efforts via family and friends. The court orders included a restoration directive for clients and the appointment of administrators—Mr Fok Hei Yu and Mr Chow Wai Shing Daniel of FTI Consulting (Hong Kong) Limited—to recover and manage HKWK's assets. HKWK's license for Type 1 regulated activity (dealing in securities) was revoked in March 2024. SIGNIFICANCE: Prior steps included a restriction notice in November 2019 prohibiting HKWK's operations and asset dealings, followed by an interim injunction in February 2020 to freeze assets. Mr Christopher Wilson, SFC’s Executive Director of Enforcement, stated: “ The SFC is firmly committed to safeguarding market integrity and protecting investors. The actions taken by the SFC in this case highlights the SFC’s strong stance against dishonest practices by intermediaries and its dedication to maintaining public trust in the financial markets .” 10. MMT Rules Former Dan Form Company Secretary and Associate Guilty of Insider Dealing On 17 July 2025, the Market Misconduct Tribunal (“ MMT ”) determined that Ms Cynthia Chen Si Ying, ex-company secretary of Dan Form (now Asiasec Properties Limited) (HKEX: 00271), and her Mainland associate, Mr Wen Lide, engaged in insider dealing related to the company's shares. The tribunal ordered them to disgorge over $1 million in illicit profits and imposed additional sanctions. Case Recap: The case revolves around inside information about the sale of Dan Form's controlling stake. On 22 September 2016, Dan Form, Tian An China Investments Company Limited, and its subsidiary Autobest Holdings Limited announced a conditional agreement for Autobest to acquire 36.45% of Dan Form’s shares from then-chairman Mr Dai Xiaoming at $2.75 per share. Key findings: Chen possessed the inside information by 2 September 2016, and disclosed it to Wen, knowing he might use it for trading. Wen, aware of the information, purchased 1,250,000 Dan Form shares between September 5 and 19, 2016, via his Shenwan Hongyuan Securities account, plus 250,000 shares on September 6 and 50,000 on September 12 through his and his wife's accounts at Grand Investment (Securities) Limited. Chen had an interest in Wen’s dealings through the Shenwan Hongyuan account. The MMT deemed Chen’s actions particularly grave due to her role as company secretary, her managerial responsibilities entrusted by Dai, her encouragement of Wen’s trades, and efforts to obscure profits via layered accounts. Sanctions imposed: Chen and Wen to jointly disgorge $794,347; Wen to disgorge an additional $206,067, plus compound interest from October 26, 2016. Four-year disqualification for Chen from managing Asiasec or any listed Hong Kong corporation without court approval; recommendation for disciplinary action by the Hong Kong Chartered Governance Institute. Four-year cold shoulder orders banning both from dealing in Hong Kong securities, futures, leveraged forex, or collective schemes. Cease and desist orders against future market misconduct. Payment of government and SFC costs. For prior context, see SFC press releases from 23 April 2024 , and 21 January 2025 . [End of ComplianceOne Newsletter – July 2025] 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

香港海關根據《打擊洗錢及恐怖分子資金籌集條例》(第615章)，對四間持牌金錢服務經營者違規行為進行了紀律處分。其中三間經營者受到公開譴責，顯示違規行為的嚴重性。 海關對四間找換店違反反洗錢條例進行紀律處分 香港海關根據《打擊洗錢及恐怖分子資金籌集條例》(第615章)，對四間持牌金錢服務經營者違規行為進行了紀律處分。其中三間經營者受到公開譴責，顯示違規行為的嚴重性。 案例一 決定日期: 2024年8月12日; 紀律處分: 公開譴責及糾正行動。 違規事項: 未就匯款交易備存相關文件記錄（包括內地銀行帳戶匯款明細）。 未設立程序以識別客戶或實益擁有人是否為政治人物。 未在指定時間內向海關報告銀行帳戶變更詳情。 案例二 決定日期: 2024年8月12日; 紀律處分: 公開譴責及糾正行動。 違規事項: 未備存六宗匯款交易的文件記錄（包括客戶盡職審查篩查文件）。 進行匯款交易前，未識別及核實匯款人及實益擁有人身份。 進行匯款交易前，未識別代表客戶行事的人的身份及授權。 案例三 決定日期: 2024年8月12日; 紀律處分: 公開譴責及糾正行動。 違規事項: 未在與客戶建立業務關係前執行客戶盡職審查措施。 進行匯款交易前，未記錄收款人地址及指示時間。 未在指定時間內向海關報告營業處所的停業日期。 案例四 決定日期: 2024年8月12日; 紀律處分: 糾正行動。 違規事項: 未在指定時間內向海關報告提供金錢服務的銀行帳戶變更詳情。 海關執法行動焦點 這四間店鋪中，有三間的違規行為與 客戶盡職審查 和 文件備存 有關。這些行動強調了客戶盡職審查和文件備存在反洗錢合規中的重要性。 根據香港海關執行反洗錢和打擊恐怖融資的紀錄，從2014年到2024年，大部分的執法行動涉及 客戶盡職審查 和 文件備存 的規定。這些規定包括： 第5條: 就客戶作盡職審查及備存紀錄： 這是指金錢服務經營者在與客戶建立業務關係前，必須進行客戶盡職審查，並保存所有與交易有關的文件記錄。 附表2: 就客戶作盡職審查及備存紀錄： 這是對上述規定的具體應用，強調在進行交易前，必須確保客戶的身份和交易活動的合法性。 總計 2024年 2023年 2022年 2021年 2014-2020年 第5條: 就客戶作盡職審查及備存紀錄 23 0 2 1 6 14 第29條: 經營金錢服務的限制 21 0 0 0 2 19 第35條: 擬任持牌人董事需獲關長批准 1 0 1 0 0 0 第37條: 擬成為持牌人合夥人的人需獲關長批准 2 0 2 0 0 0 第38條: 加入新的營業處所 2 0 0 2 0 0 第40條: 持牌人有責任向關長具報詳情改變 19 3 7 8 0 1 第41條: 持牌人有責任向關長具報停業 3 0 1 2 0 0 附表2: 就客戶作盡職審查及備存紀錄 10 0 2 2 2 4 資訊來源 ComplianceOne - 香港海關對金錢服務經營者的執法和刑事調查案件資訊： https://eservices.customs.gov.hk/MSOS/common/enforcenew 客戶盡職審查 指在與客戶建立業務關係前，金錢服務經營者需要採取措施來識別和核實客戶及其實益擁有人的身份，並確保他們不涉及任何非法活動。這包括檢查客戶的身份證明文件、收集相關信息，並在必要時進一步核實。 文件備存 則要求金錢服務經營者保存所有與交易有關的文件記錄至少五年，以確保在監管機構要求時可以提供完整的交易記錄。這不僅有助於防止洗錢活動，還能提高業務透明度，保護金錢服務經營者免受潛在的法律風險。 這些行動展示了海關對維護金融系統完整性及嚴格執行反洗錢法規的承諾。公開譴責提醒所有金錢服務經營者，遵守反洗錢要求的重要性。金錢服務經營者應審查其反洗錢政策及程序，以確保符合要求，避免面臨類似處分。 立即試用「東查查反洗錢/ 客戶管理系統」