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

The topics discussed in this monthly newsletter for Licensed Corporations are as follows: ComplianceOne Newsletter – December 2025 The topics discussed in this monthly newsletter are as follows: Regulatory Updates FSTB and SFC conclude consultations on virtual asset dealer and custodian regimes Market News A quarter of connecting, innovating and diversifying Hong Kong markets: SFC Report Enforcement News - Intermediary SFC Suspends Loretta LEE Si Kar for Three Months and Two Weeks Over Neglect of Duties in Safeguarding Client Assets at Tung Tai Securities SFC Reprimands and Fines EFG Bank AG $10.85 Million for Regulatory Breaches and Internal Control Failures Enforcement News - LISTCO SFC Convicts and Sentences Former Vice President of Computershare to Imprisonment and Fine for Insider Dealing SFC Obtains Order to Freeze $101 Million Belonging to Suspected Shadow Director in Corporate Misconduct Case Involving Teamway (1239.HK) SFC Secures Conviction and Eight-Month Prison Sentence in False Trading Prosecution Involving China All Access Shares SFC Suspends Dealings in Dashan Education (9986.HK) Shares over Significant Overstatement of Corporate Bank Balances Regulatory Updates 1. FSTB and SFC conclude consultations on virtual asset dealer and custodian regimes The Financial Services and the Treasury Bureau (“ FSTB ”) and the SFC published two consultation conclusions on legislative proposals to regulate virtual asset (VA) dealing and custodian service providers in Hong Kong; and also proceed for further consultation on new regimes to cover VA advisory and management services providers adopting the familiar philosophy of “same business, same risks, same rules” principle, these new regimes are formulated on the model base of similarities with the securities market. For VA dealers , the regime will be aligned closely with that for Type 1 (dealing in securities) regulated activity, some key takeaways from the consultation conclusions are as follows: Scope and Coverage : still adhering to the principle of“same business, same risks, same rules”; Regulatory Requirement : SFC-licensed VATPs are permitted to integrate with intra-group liquidity via a shared order book while still upholding an appropriate balance between investor protection and market development; Transitional Period : no plan for any deeming arrangement to existing VA dealing service providers; Expedited Licensing Process : SFC-licensed VATPs and licensed corporations currently providing VA dealing services will be subject to an expedited approval process; Prohibition : any person is prohibited from actively marketing its VA dealing services, whether in Hong Kong or elsewhere, to the public of Hong Kong, unless that person is licensed by with the SFC; Powers of Regulatory Authorities : the SFC and the HKMA would be provided with the proposed powers. For VA custodians , the new regime will focus on managing risks related to safekeeping private keys of client VAs in Hong Kong, to secure client assets and protect investors. Key takeaways from the consultation conclusions are as follows: Scope and Coverage : target entities safekeeping private keys which represent the core risk area in VA custody; Activities Allowed : safekeeping of VAs and provision of staking services; Financial Resource Requirements: subject to the similar financial requirements as an LC carrying on Type 13 regulated activity of providing depositary services; Transitional Arrangement : no plan for any deeming arrangement to existing VA custodian service providers; Prohibition : any person is prohibited from actively marketing VA custodian services, whether in Hong Kong or elsewhere, to the public of Hong Kong, unless the person is licensed by with the SFC; Powers of the Regulatory Authorities : the SFC and the HKMA would be provided with the proposed powers. SIGNIFICANCE: As Julia Leung, CEO of the SFC, said: “ The significant progress in our VA regulatory framework ensures Hong Kong remains at the global forefront of digital asset market developments by fostering a trusted, competitive and sustainable ecosystem .” Meanwhile, Mr. Christopher Hui, the Secretary for Financial Services and the Treasury, said: “ The proposed licensing regimes strike a prudent balance among fostering market development, managing risks and protecting investors. ” Market News 2. A quarter of connecting, innovating and diversifying Hong Kong markets: SFC Report In the Jul-Sep 2025 Quarterly Report, it showed Hong Kong’s capital markets continued to deepen connectivity with Mainland and overseas markets, while driving advanced financial innovation and diversification. Some key takeaways of the Report on the financial areas are as follows: The SFC signed six MOUs in 2025 (three in the quarter) with overseas and Mainland markets to strengthen global asset management ties and reinforce Hong Kong’s super‑connector role. Swap Connect, with its product expansion, recorded a 56% year-on-year (“ YoY ”) increase in trading volume as of November 2025, with aggregate transactions exceeding RMB9.3 trillion since its 2023 launch. The SFC collaborating with the HKSAR Government to finalize two new virtual asset (“ VA ”) regulatory regimes, namely , in dealing and custodian areas. VA spot ETFs authorized by the SFC reached $5.47 billion in market cap (+33% YoY) increasing to 11 ETFs as of end‑November; tokenized retail money market fund hit $5.48 billion AUM (+557% since the first launch this year) with eight funds in total. To support Hong Kong as an offshore renminbi and fixed‑income hub, the SFC and HKMA issued a RMB fixed income and currency roadmap in September and are preparing a detailed workplan for implementing the roadmap initiatives. The 24 IPOs in the quarter raised over $70 billion, more than 70% higher YoY, keeping Hong Kong among global leaders by IPO funds raised. Hong Kong‑domiciled funds recorded net inflows of $46.9 billion; their AUM grew 35.9% YoY to $2.27 trillion as of September, while SFC‑authorized ETFs’ market capitalization rose 31.8% YoY to $653.5 billion, accounting for 13% of daily turnover. 2,799 new SFO license applications were filed in the period (+12% YoY); SFC‑licensed corporations and individuals increased to 3,379 and 46,457 respectively (+2.7% and +3.6% YoY). The SFC and HKMA issued a joint statement highlighting the development of the stablecoin regime. On the regulatory landscape, we can take a look at the table below relating breaches noted during the SFC on-site inspections. Quarter ended 30.9.2025 Six months ended 30.9.2025 Six months ended 30.9.2024 YoY change (%) Breach of the Code 72 180 193 -6.7 Breach of FMCC 40 99 56 +76.8 Non-compliance with AML guidelines 55 113 142 -20.4 Internal control weakness 176 341 472 -27.8 It is obvious that there was an increasing trend in deficiencies found in asset management regulatory regime in 2025 as contrast to the other categories where the figures were decreasing. SIGNIFICANCE: As Julia Leung, CEO of the SFC, said: “ Our capital markets delivered another quarter of steady and diversified growth despite global headwinds and volatility. ” On the regulatory side, the acute increase in breaches of FMCC signalled the need to have more comprehensive guidelines and implementable measures to safeguard compliance from market participants. Enforcement News - Intermediary 3. SFC Suspends Loretta LEE Si Kar for Three Months and Two Weeks Over Neglect of Duties in Safeguarding Client Assets at Tung Tai Securities On 3 December 2025, the SFC announced the suspension of Ms Loretta LEE Si Kar (“ LEE ”), a responsible officer (“ RO ”), manager-in-charge (“ MIC ”), and director of Tung Tai Securities Company Limited (“ Tung Tai ”), for three months and two weeks, effective from 1 December 2025 to 14 March 2026 (see Statement of Disciplinary Action ) Case Details This action stems from LEE's neglect of her supervisory duties, which contributed to Tung Tai's failures in handling unauthorized instructions from a bogus email, leading to the sale of client securities and improper transfers totaling US$3,301,740 to undesignated overseas accounts. Despite red flags such as rejected telegraphic transfers (“ TTs ”) and inconsistent beneficiary details, Tung Tai processed the transactions without client verification, breaching requirements to safeguard assets and maintain effective internal controls against theft or fraud. Enforcement Act Following the incident, Tung Tai compensated the affected client, implemented remedial measures, and engaged independent reviewers to strengthen procedures. The SFC factored in LEE's cooperation, clean record, and the seriousness of the lapses when determining the sanction, after previously reprimanding and fining Tung Tai HK$900,000 for related violations (see the SFC’s press release dated 13 November 2025 ). For more details of the background, please refer to ComplianceOne Newsletter (Nov) - Topic 6 SIGNIFICANCE: This disciplinary measure reinforces the SFC's emphasis on senior management's responsibility to uphold robust internal controls and vigilance against fraud in securities firms. It serves as a reminder for financial intermediaries, including those in related sectors, to prioritize client asset protection through proactive verification and risk management, as lapses can result in significant financial losses, regulatory penalties, and reputational harm. The case may prompt firms to review email authentication protocols and TT processes to mitigate similar cyber-enabled threats. 4. SFC Reprimands and Fines EFG Bank AG $10.85 Million for Regulatory Breaches and Internal Control Failures On 11 December 2025, the SFC reprimanded and fined EFG Bank AG (“ EFG ”) $10.85 million for failures in product due diligence, record-keeping, and late reporting during the period from January 2015 to December 2020 (the “ Relevant Period ”). The SFC’s action followed an investigation triggered by a self-report from EFG and findings referred by the Hong Kong Monetary Authority (“ HKMA ”). Case Details EFG, registered to conduct regulated activities including dealing in securities, advising on securities, and asset management under the Securities and Futures Ordinance, failed to adequately assess special features of 322 bonds during product due diligence. It also neglected to update internal policies promptly in line with regulatory changes and did not provide customers with sufficient information or warning statements for certain complex products prior to transactions. Additionally, EFG did not maintain product due diligence records for 141 bonds and delayed reporting its suspected failures to the SFC, despite identifying them in July 2020. These breaches contravened the Code of Conduct for Persons Licensed by or Registered with the SFC and the Management, Supervision and Internal Control Guidelines for Persons Licensed by or Registered with the SFC. Enforcement Act In determining the sanctions, the SFC considered EFG’s remedial actions to strengthen its product due diligence framework, its cooperation with the HKMA and SFC investigations, and its commitment to implement Enhanced Complaint Handling Procedures (“ ECHP ”). Under the ECHP, EFG will review complaints from customers who acquired any of the 351 affected products during the Relevant Period, ensuring fair resolution. An impact assessment by EFG indicated potential failures in considering special features for these 351 products. For more details of the background, please refer to Statement of Disciplinary Action (appended with a list of the 351 products) SIGNIFICANCE: This enforcement action highlights the SFC’s emphasis on robust internal controls, timely compliance with evolving regulations, and proactive self-reporting in the financial sector. For institutions like EFG, which intersect with banking, securities, and potentially insurance-linked activities, such failures can erode investor trust and expose clients to undue risks. The case serves as a reminder for all regulated entities to prioritize comprehensive due diligence, accurate record-keeping, and swift disclosure of issues to maintain market integrity and avoid severe penalties. The implementation of ECHP demonstrates a balanced approach, allowing for remediation while reinforcing accountability. Enforcement News - LISTCO 5. SFC Convicts and Sentences Former Vice President of Computershare to Imprisonment and Fine for Insider Dealing SFC’s press release dated 4 December 2025 & 18 December 2025 . The SFC prosecuted Mr. CHOI Chun Wai (“ CHOI ”), former Vice President of Computershare Hong Kong Investor Services Limited (“ Computershare ”), a global provider of share registration and investor services, for insider dealing in the shares of ENM Holdings Limited (“ ENM ”) ( 128.HK ), listed on the Main Board of the Stock Exchange of Hong Kong Limited since 1972. Computershare was engaged by ENM to despatch and collect proxy forms, and to act as the scrutineer for the voting process at a court meeting related to ENM's proposed privatisation. CHOI, while employed as a vice president of Corporate Services, was involved in coordinating and monitoring the voting process. He accessed inside information indicating the privatisation would fail and sold his shares ahead of the public announcement, avoiding a significant financial loss. Case Details Date Event 2 June 2023 ENM and the Offeror (Solution Bridge Limited) jointly announced a proposed privatisation of ENM by way of a scheme of arrangement under section 673 of the Companies Ordinance, offering $0.58 per share for cancellation of approximately 55.72% of ENM's issued share capital, subject to 75% approval from disinterested shareholders at a court meeting scheduled for 26 September 2023. 22 September 2023 CHOI learned from proxy forms that the required voting threshold for the privatisation could not be met, constituting inside information. 25 September 2023 CHOI sold all his 1,500,000 ENM shares, despite knowing the inside information. 27 September 2023 ENM announced the lapse of the privatisation, causing ENM’s share price to fall 10.26% to close at $0.35, resulting in CHOI avoiding a loss of around $289,500. Court Order On 4 December 2025, the Eastern Magistrates’ Courts convicted CHOI of insider dealing following a prosecution by the SFC. CHOI pleaded guilty. The Eastern Magistrates’ Courts then sentenced CHOI to two months of imprisonment on 18 December 2025. He was ordered to pay a fine of $289,500 (equivalent to the losses avoided) and the SFC's investigation costs of $120,407. The Court noted that although CHOI showed remorse, insider dealing is a serious offense warranting an immediate custodial sentence. SIGNIFICANCE: The SFC’s Executive Director of Enforcement, Mr. Michael DUIGNAN, stated: “ The conviction underscores the SFC’s commitment to tackle insider dealing and enhance the integrity of Hong Kong’s financial markets. The immediate jail sentence by the Court serves as a strong deterrent. The misuse of non-public information for personal gain, particularly market professionals in a position of trust, is unacceptable and will have serious consequences. The SFC will continue to take robust enforcement action to protect investors and uphold a level playing field for all market participants. ” 6. SFC Obtains Order to Freeze $101 Million Belonging to Suspected Shadow Director in Corporate Misconduct Case Involving Teamway (1239.HK) On 16 December 2025, the SFC obtained a court order from the Court of First Instance to freeze more than $101 million in cash held in the personal bank account of Mr NG Kwok Fai (“ NG ”), a suspected shadow director of Teamway International Group Holdings Limited ( 1239.HK ) (“ Teamway ”). This action was taken by consent between the SFC and NG in ongoing legal proceedings under section 214 of the SFO, stemming from allegations of corporate misconduct. The freeze follows NG and others agreeing to pay $192 million in compensation to independent public shareholders of the delisted Combest Holdings Limited (“ Combest ”) for related misconduct. Case Details The SFC's investigation revealed that NG and Mr YANG Zhihui (“ YANG ”) allegedly gained control of Teamway and acted as shadow directors, transforming it into a "listed shell" for injecting new businesses while prejudicing the company's interests through a series of transactions. The SFC claims that the below individuals breached their fiduciary duties by approving these transactions or allowing NG and/or YANG to dominate company affairs: Name Position/Role Mr LIU Liangjin; Mr HE Xiaoming; Ms XIE Yan; Mr LING Zheng; Ms NGAI Mei; Mr XU Gefei; and Ms DUAN Mengying The seven former executive directors (“ ED ”) Mr CHAN Chun Kau; Mr LAM Chi Wai; and Mr Joshua LEE Chi Hwa The three Former independent non-executive directors (“ NED ”) Additionally, the former company secretary, Ms CHOI Yee Man (“ CHOI ”), is accused of negligence or recklessness in her duties. This case spans several years, involving interconnected corporate actions and related proceedings. Below is a timeline of key events: Date Event 2015 NG and YANG acquired a 75% interest in Teamway through a nominee, becoming shadow directors and planning to transform it into a "listed shell" by injecting new businesses to replace its original packaging operations. 2015–2022 NG and YANG, as shadow directors, allegedly engineered prejudicial transactions, with former directors approving them and the company secretary failing in oversight duties. May 2020 SFC commenced court proceedings under sections 212 and 214 of the SFO against NG, Mr LIU Tin Lap (“ LIU ”), and Mr LEE Man To (“ LEE ”) for misconduct related to Combest. Source: SFC’s press release dated 21 May 2020 . 8 November 2022 SFC initiated section 214 proceedings against Teamway and 13 individuals, including NG, YANG, the seven EDs, three NEDs, and the company secretary. September 2024 SFC and Combest, NG, LIU, and LEE reached an agreement via the Carecraft procedure to dispose of Combest proceedings. Source: SFC’s press release dated 16 September 2024 . 2 June 2025 Court ordered NG, LIU, and LEE to pay $192 million in compensation to Combest's independent public shareholders. Source: SFC’s press release dated 2 June 2025 . Enforcement Act The SFC is seeking compensation orders totaling $532 million against NG, YANG, and the 10 former directors for losses incurred by Teamway and its subsidiaries, along with disqualification orders against them and CHOI from serving as directors or managing any listed or unlisted corporation in Hong Kong. The asset freeze against NG remains in effect until the proceedings are resolved or further court order. SIGNIFICANCE: This enforcement action highlights the SFC's commitment to combating corporate misconduct in listed entities, particularly where shadow directors exploit control to prejudice company and shareholder interests. By freezing assets and seeking substantial compensation and disqualifications, it underscores the importance of fiduciary duties, transparency, and accountability in Hong Kong's financial markets. Company with listed affiliations should review governance practices to mitigate similar risks, as such cases can erode investor confidence and trigger broader regulatory scrutiny across financial sectors. 7. SFC Secures Conviction and Eight-Month Prison Sentence in False Trading Prosecution Involving China All Access Shares On 4 December 2025, the Shatin Magistrates’ Courts convicted Ms WONG Yuk Lan (“ WONG ”), Administration Controller of China All Access (Holdings) Limited (former stock code: 633.HK ) (“ China All Access ”), for false trading in the company’s shares, following a prosecution initiated by the SFC. Case Details The case stemmed from WONG’s actions as the “Spouse” of Mr Chan Yuen Ming, the company’s Chairman, who held a beneficial interest in 381,400,000 China All Access shares through a securities margin account under Creative Sector Limited, a company he wholly owned and controlled. Between 29 and 31 December 2014, WONG placed a series of bid orders for China All Access shares via her personal securities account. These orders were executed in the final minutes before market close and at prices above prevailing market levels. The court determined that WONG had no genuine intent to purchase the shares but aimed to create a false or misleading appearance of market demand to alleviate margin call pressures on Creative’s account. Court Order This offense violates section 295 of the SFO, which prohibits actions intended to create a false or misleading appearance regarding the market for, or price of, securities. Magistrate Mr Jeffrey SZE Cho Yiu emphasized during sentencing that WONG’s misconduct harmed market integrity by fabricating an illusion of active trading. WONG was subsequently sentenced to eight months in prison on 17 December 2025, and ordered to pay the SFC’s investigation costs. SIGNIFICANCE: This enforcement action underscores the SFC’s dedication to preserving market integrity and deterring manipulative practices that undermine investor confidence in Hong Kong’s financial markets. By securing a conviction and prison sentence for false trading, it highlights the severe consequences of creating artificial market appearances to evade financial pressures, such as margin calls. Financial professionals and firms should strengthen internal controls and compliance measures to prevent similar misconduct, as such cases can lead to reputational damage, regulatory penalties, and broader scrutiny across interconnected sectors. 8.SFC Suspends Dealings in Dashan Education (9986.HK) Shares over Significant Overstatement of Corporate Bank Balances On 3 December 2025, the SFC directed The Stock Exchange of Hong Kong Limited (“ Stock Exchange ”) to suspend dealings in the shares of Dashan Education Holdings Limited ( 9986.HK ) (“ Dashan ”) effective from 9:00 am, under the Securities and Futures (Stock Market Listing) Rules (“ SMLR ”). This measure aims to maintain a fair and orderly market and protect investors amid an ongoing SFC investigation into suspected financial irregularities. Case Details The SFC's inquiry revealed discrepancies in bank statements related to a software development project (April 2022 to November 2023) and a UK company acquisition (September 2022), including omitted circular fund flows and overstatements of bank balances totaling RMB36.4 million as of 30 June 2023 (19% of net asset value) and RMB76.3 million as of 31 December 2023 (55% of net asset value). These findings suggest the transactions may not have been genuine or at arm's length, with potential fabrication of documents to conceal issues, raising concerns about management integrity, particularly involving executive director Mr. ZHANG Hongjun (“ ZHANG ”), internal controls, and market disclosures. Follow-up Action Dashan has not provided satisfactory explanations, and the SFC suspects the September 2024 trading resumption was based on misleading information. Trading had been halted at Dashan's request since 28 November 2025 pending inside information release. See HKEX News 28 November 2025 for more information. SIGNIFICANCE: This suspension emphasizes the SFC's role in upholding market transparency and investor protection by addressing potential financial misrepresentations in listed companies. It highlights risks associated with overstated assets, inadequate internal controls, and management accountability, which could impact stakeholder confidence and prompt enhanced due diligence for financial intermediaries dealing with similar entities. As the investigation continues, it may lead to further regulatory actions, underscoring the need for robust compliance frameworks in Hong Kong's capital markets. [End of ComplianceOne Newsletter – December 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

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 are as follows: ComplianceOne Newsletter – September 2024 The topics discussed in this monthly newsletter are as follows: Statistics showed Hong Kong’s securities industry extends earnings growth into first half of 2024 SFC announces arrangements to facilitate distribution of research reports of eligible ETFs under Stock Connect SFC issues new guides for visiting and returning professionals to highlight pragmatic licensing options LET and Summit Ascent were required to repurchase shares to protect independent minority shareholders SFC reprimands and fines Profitech Securities Limited $3.99 million for several regulatory breaches SFC bans former Goldman Sachs employee for six months for misusing facilitation trade and misrepresentation MARKET NEWS 1. Statistics showed Hong Kong’s securities industry extends earnings growth into first half of 2024 On 25 September 2024, the SFC issued the financial review of the securities industry illustrating that Hong Kong’ s securities industry posted further growth in total net profits for the six months ended 30 June 2024 amidst higher average daily market turnover and increases in the number of active cash and margin clients. A snapshot of the key takeaways: During the first half of 2024, the total net profits of all securities dealers and securities margin financiers rose 50% to HKD19 billion, or up 29% from a year ago; The total income for the first six months in 2024 ended flat, as higher net commission income, underwriting fees and trading profits were offset by the lower income from asset management and corporate finance advisory! Reduction in non-interest overheads was the main drivers of the increase in profits; Dealing activities in virtual assets generated a total revenue of HKD77 million for the first year; Transactions of non-exchange traded investment products also reached a record high of HKD1,238 billion. SIGNIFICANCE: The promising performance of the industry is attributed to the enhanced breadth and depth of the products and services offered over the time; as well as the improved business environment that active cash and margin clients reaching an all-time high of around 4.87 million, demonstrating the securities industry remain robust and resilient. The principal of “survival of the fittest” always prevail, those participants remaining in the market should be the ones which can adapt to weather the tough times in past few years. 2. SFC announces arrangements to facilitate distribution of research reports of eligible ETFs under Stock Connect On 9 September 2024, the SFC issued a circular to set out the conditions that allow intermediaries to distribute research reports of eligible Mainland exchange-traded funds (ETFs) under Stock Connect in Hong Kong. Ever since its inclusion of ETFs under the Stock Connect (ETF Connect) in July 2022, the scheme was highly welcomed by investors in both markets. In view of the recent expansion and increasing diversity of eligible securities, China Securities Regulatory Commission (CSRC) has clarified that the existing relevant requirements for Mainland securities companies to forward research reports of eligible Hong Kong stocks under Stock Connect on the Mainland can apply to research reports of eligible Hong Kong ETFs under Stock Connect. Such reciprocity in access to information helps enhance Mainland and Hong Kong investors’ understanding of the products in each other’s market, as well as facilitate trading and liquidity in both markets. It should be noted that the SFC would not consider these research reports as advertisement or invitation as prohibited by section 103(1) of the SFO, subject to the following conditions: Distribution Party : The reports are distributed by an intermediary licensed in Type 4 regulated activities; or in Type 1 regulated activities in an incidental manner. Preparation : The intermediary preparing the reports should be responsible for it, and be compliant with the applicable requirements in the Code of Conduct; and to ensure that the information is factual, fair and neutral. Disclosure : The reports should contain prominent and adequate disclosures of conflicts of interest and warning statements with respect to any relation or interests between the intermediary and the subject ETFs in the reports. SIGNIFICANCE: As Ms Christina Choi, the SFC’ s Executive Director of Investment Products, had said, “ the latest arrangement will facilitate the circulation of product information with a clear, compliant and professional method. ” 3. SFC issues new guides for visiting and returning professionals to highlight pragmatic licensing options On 2 September 2024, the SFC published two new quick reference guides to assist visiting and returning professionals in understanding the SFC's pragmatic licensing regime, complementing the five popular quick reference guides published in 2023. Let us take a snapshot of the arrangements for “returning professional” which is a more common phenomenon nowadays in Hong Kong. Theme: The new guideline in licensing regime provides flexibility for former practitioners intending to return to the industry in Hong Kong after an interval of less than eight years to perform regulated activities (RAs) with alternative means to satisfy the competence requirements . Time Intervals of returning: A prerequisite here is that the RA the returning professional is planning to carry on should be with the same examination requirements (namely, the same LRP) and in the same role (namely, the same RIQ) as previously licensed , then if: within three years: enjoy full exemption from all examinations (under both the RIQ and LRP requirements); within three years to eight years: enjoy conditional exemptions from both RIQ and LRP requirements by only completing additional CPT hours before re-applying for a license (if subject to same RIQ and LRP requirements). Remarks: LRP: Local Regulatory Framework Paper RIQ: Recognised Industry Qualifications SIGNIFICANCE: With illustrative case studies, the two new guides offer useful information about licensing options and processes as well as various conditions for examination exemptions, in order to facilitate a smooth and compliant transition to the Hong Kong financial markets for these professionals. The more flexibility is provided in the second case where the years of absence from being licensed is above the three years threshold to within eight years. According to the quick reference guide leaflet, in order to be eligible for conditional exemptions , the applicant has to complete five CPT hours per RA applied, and per year of absence , with at least 50% of the CPT hours are in local regulatory knowledge. Suffice it to say that if the applicant has been licensed four years ago for an RA, it is required to complete 20 CPT hours (10 hours in regulatory knowledge) instead of having to re-take the LRP again. ENFORCEMENT NEWS 4. LET and Summit Ascent were required to repurchase shares to protect independent minority shareholders On 27 September 2024, it was announced that the SFC had commenced legal proceedings under the section 214 of the SFO in the Court of First Instance to seek a share repurchase order to protect the interests of independent minority shareholders (the “Minority”) of LET Group Holdings Limited (LET) and Summit Ascent Holdings Limited (Summit) as a result of alleged misconduct of Mr Lo Kai Bong (LO), chairman, executive director and controlling shareholder of both companies. As the alleged misconduct of LO had resulted in suspension of trading of the shares of LET and Summit and it was not certain when the shares could be resumed for trading. In order to protect the Minority, LO, LET and Summit were required by the Court to repurchase the shares from the Minority at a price and in a manner determined by the Court. The SFC investigation further revealed that LO deliberately disregarded the Listing Rules and the Code on Takeover and Merger in disposing of the assets of LET and Summit in Russia in 2024 despite of disapproval by other directors of LET and Summit in a non-compliant manner. Though the disposal was later terminated, the SFC alleged that LO had failed to apply due care and diligence in performing his duties in both companies. 5. SFC reprimands and fines Profitech Securities Limited $3.99 million for several regulatory breaches On 30 September 2024, the SFC reprimanded and fined Profitech Securities Limited (Profitech) HKD3.99 million for failures to comply with the Securities and Futures (Financial Resources) Rules (FRR) and other regulatory requirements. Key findings in the SFC investigation were that Profitech: (i) failed to maintain its required liquid capital of HKD3 million in compliance with the FRR between February and June 2021 and since July 2022; (ii) improperly repledged client securities collateral to its execution broker for 17 months for financial accommodation without a valid client standing authority; (iii) failed to ensure that the aggregate market value of its repledged securities collateral should not exceed the repledging limit; (iv) recklessly provided financial accommodation to two new clients for HKD15.6 million without reasonable credit controls and risk management measures; (v) failed to notify SFC of a change in its holding company’s shareholding structure within seven business days. The above-mentioned failures of Profitech constituted breaches of the SFO, the Securities and Futures (Licensing and Registration) (Information) Rules, the Securities and Futures (Client Securities) Rules and the Code of Conduct. SIGNIFICANCE: Observation of the findings directly revealed how insufficient the internal controls measures Profitech was managed as a licensed corporation; as SFC had pointed out in considering its disciplinary sanction note including Profitech’s repeated and prolonged failures to maintain the required liquid capital, the gravity of the improper repledge of client securities and failure to rectify the irregularities despite repeated reminders from SFC, it all rendered the SFC to its suggestion for Profitech to engage an independent reviewer to review its relevant internal controls! 6. SFC bans former Goldman Sachs employee for six months for misusing facilitation trade and misrepresentation On 23 September 2024, it was announced that the SFC banned Mr Dennis Cheng Chung Sing (Cheng), a former trader of Goldman Sachs (Asia) L.L.C. and Goldman Sachs (Asia) Securities Ltd (collectively, Goldman Sachs), from re-entering the industry for six months from 20 September 2024 to 19 March 2025 The investigation found that on 24 August 2020, Cheng erroneously placed a client order for buying 2,232,000 shares of company X to 232,000 shares into the system, resulting in an under-execution of two million shares. Cheung reported the case to Goldman Sach’s management only four day later, and he dishonestly conceal the trade execution error by the following means: (i) arranging a facilitation trade to buy the under-executed two million shares to fill the client order; (ii) misrepresenting to his colleagues that he had consent from client for the trade facilitation; (iii) booking the lower price for the original trade instead of the higher price for the trade facilitation. As a result, the SFC considered Cheng’ s conduct was in breach of the Code of Conduct and he was not fit and proper to be a licensed person. SIGNIFICANCE: Errors in trade executions are not uncommon in daily dealing activities. Licensed corporations should have internal control measure in place to govern any remedial procedures to be taken in a timely manner, including immediate reporting to senior management, notification to client with their consent for any compensating arrangements, as well as any subsequent reconciliations of the post error trade arrangements. Licensed corporations have to review their internal controls and procedures, and assess if they can be implemented as efficiently as designed for any specific purpose. 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 Insurance Newsletter – July 2025 The topics discussed in this monthly newsletter are as follows: 1. Practice Note: Commission Up to 70% in the first year, with the remainder paid over 5 years 2. Compulsory RO-CPD Requirement for Responsible Officers 3. Anti-Scam Consumer Protection Charter 3.0 Regulatory News 1. Practice Note: Commission Up to 70% in the first year, with the remainder paid over 5 years On 30 July 2025, the IA released a Practice Note . It builds on Guideline GL16, which covers long-term insurance business (excluding investment-linked policies). The goal is simple: ensure insurance companies pay commissions to agents and brokers in a way that encourages fair treatment of customers. This practice guideline shall come into effect on 1 January 2026 . Who Does This Apply To? Insurers: All authorized insurance companies in Hong Kong that issue participating policies with regular premiums. Intermediaries: Licensed individual agents, agencies, and broker companies who sell and service these policies. Key Rule: How Commissions Must Be Paid To avoid "front-loading" (paying too much too soon, which might lead to pushy sales and poor after-sales service), commissions must be spread out: Up to 70% can be paid in the first policy year (from the start date to 12 months later). The remaining at least 30% must be paid evenly over the next minimum 5 years (policy years 2 to 6) – or over the full premium payment term if it's shorter than 5 years. Example - a policy where the total commission is $100 (based on premiums paid): Policy Year Before 1 January 2026 After 1 January 2026 Commission paid % of total commission Commission paid % of total commission Year 1 $100 100% $70 70% Year 2 $0 Nill $6 6% Year 3 $0 Nill $6 6% Year 4 $0 Nill $6 6% Year 5 $0 Nill $6 6% Year 6 $0 Nill $6 6% Year 7 $0 Nill $0 Nill Under the existing practice (“ Before 1 January 2026 ”), with all commissions paid in the first year, intermediaries may have reduced incentive to provide ongoing service from year 2 onward, potentially leading to policies receiving less attention or being neglected. For the new practice (“ After 1 January 2026 ”), the spreading of commissions ensures that intermediaries remain motivated to carefully handle and service policies over subsequent years to secure the remaining payments, promoting better long-term customer care. The new practice applies to the total commission per policy, including basic pay, overrides (to managers), and bonuses tied to sales volume (unless exempted – see below). Exceptions (When Spreading Isn't Required) You can skip the 70/30 split if the below scenarios apply, but still required to follow GL16's fair treatment rules: Scenario Remarks Overriding commission (Agents only) Applies to: Commissions for producing agents (who introduce, arrange, and serve policies) and overriding commissions for agent managers (who oversee producing agents). Exception: Overriding commissions are exempt if calculated using objective non-financial performance metrics, such as policy persistency rates, product variety in portfolios, customer feedback, and agent retention rates, to ensure adherence to "treating customers fairly." Volume-Based bonus commission (Agents only) Applies to : Bonuses for licensed insurance agents contingent on meeting sales volume targets (e.g., minimum premium volume), where eligibility and amount are uncertain until targets are met. Exception : Exempt if the bonus incorporates objective non-financial metrics (e.g., persistency rates, product diversity, customer feedback, agent retention) alongside volume. Note for Brokers : Volume-based commissions are outright prohibited for licensed insurance brokers per a 2006 circular from the Office of the Commissioner of Insurance. Fixed salaries Exception : Fully exempt for fixed remuneration packages, which are contractually guaranteed regardless of policy arrangements, servicing, or premium volumes. Bank channels (bancassurance) Exception: Allowed departure for commissions in the bancassurance channel (e.g., banks as insurance agencies under the Banking Ordinance), provided they adhere to overriding principles in GL16. The IA and Hong Kong Monetary Authority (“ HKMA ”) will monitor and act if needed. Policy Holders Who Are Professional Investors Exception : Departure permitted for commissions on policies with policyholders qualifying as Professional Investors (per Securities and Futures Ordinance and Rules), subject to: Establishing effective controls to verify PI status during onboarding and KYC processes. Confirming the policyholder meets PI criteria. Ensuring commission structures continuously comply with GL16's overriding principles. SIGNIFICANCE: This Practice Note strengthens regulatory oversight of long-term insurance conduct, promoting sustainable practices that prioritize policyholder protection over short-term sales. By mandating commission spreading, it reduces risks of misconduct, enhances industry integrity, and supports fair treatment amid fluctuating policy benefits. Insurers are encouraged to consult the full document and FAQs for guidance; the IA may update it based on market developments. For inquiries, contact the IA at relevant channels. 2. Compulsory RO-CPD Requirement for Responsible Officers The IA has officially rolled out the compulsory Continuing Professional Development (“ CPD ”) requirement for Responsible Officers (“ ROs ”) (here refer as “ RO-CPD ”) of all licensed insurance broker companies. Effective from 1 August 2025 . Key Details of the Requirement RO must complete at least 2 RO-CPD hours focused specifically on management and control functions during each assessment period. The RO-CPD hours fall under the " Ethics or Regulations " category and count toward the existing 15-hour annual CPD requirement for ROs. RO-CPD Course Details, and how to attend The IA will organize the courses, delivered through the two key broker industry bodies: Professional Insurance Brokers Association (“ PIBA ”) The Hong Kong Confederation of Insurance Brokers (“ CIB ”) Further details on training sessions for the 2025/26 assessment period will be announced soon. ROs must attend at least one session per period through either body. Consequence of Non-Compliance Non-compliance should not be taken lightly. Failure to meet the RO-CPD without reasonable excuse may result in: Disciplinary Action : As detailed in the IA's "Penalty Framework for Non-compliance with CPD" (from the circular dated 23 July 2021 ). Impact on Fit and Proper: May question the individual's ongoing suitability to serve as an RO. Increased Scrutiny : IA could apply heightened regulatory oversight to the associated broker company. SIGNIFICANCE: Given the growing complexity of these duties, the IA believes it's essential for ROs to dedicate time to enhancing their skills in management and control functions. This builds on positive feedback from a pilot scheme launched in the 2024/25 assessment period, which was well-received by the industry and successfully raised awareness about RO responsibilities. 3. Anti-Scam Consumer Protection Charter 3.0 In a united stand against rising financial frauds and scams, the Hong Kong Monetary Authority (“ HKMA ”), Securities and Futures Commission (“ SFC ”), the IA, and Mandatory Provident Fund Schemes Authority (“ MPFA ”) have unveiled the Anti-Scam Consumer Protection Charter 3.0 . Effective from 9 July 2025 . Building upon the foundations laid by Charters 1.0 (2023) and Charter 2.0 (2024) , Charter 3.0 expands the fight against scams by forging partnerships with technology and telecommunications firms. This collaborative framework aims to disrupt fraud at its core through six key principles outlined in the annex. These focus areas include: Charter 3.0 Principles include: 1. Reporting Functions for Users Participating Institutions will allow users to file reports related to suspected financial frauds and scams, and will endeavor to address them in a reasonable manner, once found to be in violation of the Participating Institutions’ policies. 2. Reporting Channels for Financial Regulators Participating Institutions will provide a direct and efficient process for the Financial Regulators to report suspected financial frauds and scams, and to follow up on such reports. 3. Checking of Advertisers Participating Institutions will adopt a risk-based approach to facilitate verification, applying measures that are necessary and proportionate. 4. Internal Monitoring Processes Participating Institutions will put in place and update from time to time internal rules, policies, processes, and tools to monitor advertisements and content that promote financial products or services on their platforms, with a view to creating a safe online environment for users. 5. Enforcement of Terms of Service Participating Institutions will enforce their own terms of service by detecting and removing financial scam advertisement or content that violate their platform policies. 6. Collaboration on Public Awareness Participating Institutions will work together with the Financial Regulators and the financial industry on raising public awareness about frauds and scams and promoting cybersecurity. This will include Participating Institutions’ collaboration with the Financial Regulators, financial institutions, or other agencies where appropriate, to launch anti-deception promotional campaigns to educate the Hong Kong public. The launch event featured engaging discussions among executives from regulators, tech giants, and telecom providers on emerging scam trends and joint strategies to protect the public. SIGNIFICANCE: Julia Leung, Chief Executive Officer, SFC: "Charter 3.0 is a meaningful step forward, bringing in major technology and telecommunications companies to join the fight against online scams. It positions Hong Kong as a leader in safeguarding the financial world’s digital future, building a safer, more responsible online landscape." Clement Cheung, Chief Executive Officer, IA: "The Charter 3.0 represents collaborative efforts to forge a robust alliance against financial frauds. The IA will leverage this platform to strengthen public education and empower policyholders against sophisticated swindlers." With scams evolving rapidly in the digital age, Charter 3.0 emphasizes cross-sector collaboration to preempt threats. It aligns with global calls for action and reinforces Hong Kong's role as a secure financial hub. [End of ComplianceOne Insurance 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

The topics discussed in this monthly newsletter for insurance are as follows: ComplianceOne Insurance Newsletter - Aug 2024 The topics discussed in this monthly newsletter are as follows: Statistics showed total gross premium increased in Hong Kong in 2024-1H The latest “Conduct In Focus” published by the IA provided various guidelines to the industry. Reminder to submit Audited Financial Statements and Auditor’s Report under Section 73(1) of the IO (Cap.41) before the deadline. AIA was fined HKD 23 million for delays in identifying politically exposed persons (PEPs). Former insurance agent was sentenced to prison for mishandling premium payments. I A banned individuals for making use of false documents in applying for registration as licensed insurance agents. IA Regulatory Updates 1. Statistics showed total gross premium increased in Hong Kong in 2024-1H On 30 August 2024, the IA released a report highlighting a 5.1% increase in total gross premiums to $310.9 billion for the first half of 2024, showcasing the industry’s resilience and growth. Key Highlights: Long Term Business: Total revenue premiums reached $273 billion (up 5.5%). Individual Life and Annuity (Non-Linked) business grew by 6.9% to $243.3 billion. New office premiums increased by 12.3% to $115.9 billion. General Business: Gross premiums rose to $37.9 billion (up 2.4%). Accident & Health business saw a 12.5% increase to $11.7 billion. Motor Vehicles business grew by 8.5% to $2.8 billion. SIGNIFICANCE: These statistics underscore the robust growth and stability of Hong Kong’s insurance sector, highlighting its ability to adapt and thrive amidst changing market conditions. The significant rise in premiums across various segments indicates strong consumer confidence and a healthy demand for insurance products. This growth not only reinforces Hong Kong’s position as a leading international insurance hub but also emphasizes the importance of maintaining stringent regulatory standards to ensure continued trust and integrity in the industry. 2. The latest “Conduct In Focus” published by the IA provided various guidelines to the industry. The IA published its latest issue of Conduct In Focus on 16 August 2024, presenting the latest complaint statistics and disciplinary actions. The role of insurance brokers in the life insurance market. Topics include: Standards to prevent unlicensed selling, especially to Mainland China visitors. Fair commission structures. Best practices for renewal notices. A call for insurers and brokers to join the SMS Sender Registration Scheme to protect customers from scams. Benefits of using online self-service portals. The IA has also restructured its Market Conduct Division to enhance prevention and deterrence. Starting 23 September 2024, the IA will charge fees for processing insurance intermediary licensing applications and related notifications, following the end of a five-year waiver period. This new fee structure aims to sustain the IA’s regulatory functions. SIGNIFICANCE: Featured article delves into the role of insurance brokers in the life insurance market, focusing on the standards, controls, and procedures required by the IA. The issued emphasize that this will continue to be a key focus of future regulatory and enforcement efforts, including a more comprehensive consideration of how to ensure commission structures align with the “fair treatment of customers” principle. 3. Reminder to submit Audited Financial Statements and Auditor’s Report under Section 73(1) of the IO (Cap.41) before the deadline. The IA reminds licensed insurance broker companies of their obligation to submit audited financial statements and an auditor’s report under Section 73(1) of the Insurance Ordinance (Cap. 41) (“IO”) within six months after the end of each financial year. This requirement ensures transparency and compliance with financial regulations. Failure to comply may result in fines and enforcement actions. If a broker company cannot meet the deadline due to circumstances beyond its control, it must apply for an exemption under Section 79 of the IO before the deadline. SIGNIFICANCE: Applications for extensions submitted from 23 September 2024 onwards will incur a fee. No extensions will be granted after the deadline has passed. Enforcement News 4. AIA was fined HKD 23 million for delays in identifying politically exposed persons (PEPs) The IA conducted an on-site inspection of AIA International Limited’s Hong Kong branch under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). The IA found issues with the company’s AML system, leading to delays in identifying politically exposed persons (PEPs) and conducting enhanced due diligence . As a result, the IA ordered AIA to submit a report by an independent advisor validating remediation measures and imposed a HK$23 million penalty. AIA has since implemented measures to strengthen its AML controls and governance. SIGNIFICANCE: In recent enforcement news, the IA is firmly upholding robust AML controls to maintain trust and integrity in the insurance industry, with a particular emphasis on due diligence process requirements. 5. Former insurance agent was sentenced to prison for mishandling premium payments. The IA drew public attention with a press release on 26 August 2024, announcing that a former insurance agent was sentenced to three months and two weeks in prison and ordered to pay compensation for misappropriating HK$60,000 in premiums, which led to a client’s policy lapsing in 2021. The agent was arrested after a police report and pleaded guilty on 22 April 2024, under Section 9 of the Theft Ordinance (Cap. 210). The IA stresses the importance of handling premium payments correctly and advises policyholders to use official payment channels. SIGNIFICANCE: The severe consequences of misappropriating premiums in this case serve as a strong deterrent, warning others in the industry against similar actions. 6. IA banned individuals for making use of false documents in applying for registration as licensed insurance agents The IA has banned four individuals for using false academic certificates to apply for registration as licensed insurance agents between 2014 and 2019. Three individuals used certificates from a non-existent university in Mainland China, while the fourth used a certificate that the issuing institute confirmed was not valid. One individual received a 23-month ban, and the other three received 35-month bans. The IA emphasizes that using false documents undermines industry integrity and public trust. SIGNIFICANCE: The IA emphasizes that using false or forged documents is a serious offense that damages the integrity of the insurance industry. Such actions erode public trust and are unfair to honest practitioners. [End of ComplianceOne Insurance Newsletter – August 2024] 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 SFC and HKMA issued a Joint Circular on 20 October 2023 to provide further guidance on intermediaries’ virtual asset-related activities. We have prepared an executive summary to summarize the key points for easier reference.

The topics discussed in this monthly newsletter are as follows: ComplianceOne Newsletter - December 2023 The topics discussed in this monthly newsletter are as follows: 1. SFC issued key regulatory work and market data in quarterly report 2. SFC would consider authorising spot virtual asset ETF funds for public offering 3. HKMA proposes to implement regulatory regime for stablecoin issuers to secure protection to the public 4. SFC fined Ruifeng Securities Limited $5.2 million and suspended its responsible officer for fund management and account opening failures 5. SFC banned Amy Chow Bik Sum for life for conviction of bribery offence 6. SFC fined Central Wealth Securities Investment Limited $1 million for breach of Financial Resources Rules 7. SFC suspended Hau Bing Leung for 15 months for unauthorized third-party operated securities account MARKET NEWS 1.SFC issued key regulatory work and market data in quarterly report On 7 Dec 2023, the SFC published its latest Quarterly Report to provide operational and financial highlights for the quarter from July to September 2023. Encouraging achievements are as follows. (1) On asset management, exchange-traded funds (“ETFs”) were a bright spot with robust net inflow of HKD16.2 billion, while their average daily turnover (“ADT”) recorded with a healthy growth of 12% to HKD14.8 billion. (2) Besides ETF figures, the number of open-ended fund companies (“OFCs”) was also recorded with an encouraging growth of 87% year-over-year to 187. Hong Kong-domiciled funds recorded net inflows ($11.7 billion) for another quarter. (3) For the listing market, the SFC processed 39 new listing applications in the quarter, including four from pre-profit biotech companies. (4) For licensed activities, the SFC witnessed growth in the number of licence applications received, up 13% from the quarter before and 6% from a year ago. It also granted 33 corporate licences during the quarter, mainly for asset management (Type 9) and advising on securities (Type 4). (5) On the VA front, the SFC stepped up information dissemination on virtual asset trading platforms (“VATPs”) by publishing several VATP lists online, including a list of applicants. SIGNIFICANCE: Though fraught with negative comments that the status of Hong Kong as an international financial centre was fading away, the figures and achievements stated above demonstrate to the world how resilient Hong Kong can be from the previous economic drawback due to COVID-19 epidemic! 2. SFC would consider authorising spot virtual asset ETF funds for public offering A circular dated 22 Dec 2023 set out the requirements under which the SFC would consider authorising investment funds with exposure to virtual assets (“VA”) of more than 10% of their net asset value (“NAV”) for public offerings in Hong Kong ( SFC-authorised VA Funds ) under sections 104 and 105 of the Securities and Futures Ordinance (“SFO”). In the light of rapid evolvement of the VA landscape and the increasing demand for investment products providing exposure to VA, and VA-related ETFs offered in major overseas markets, where accesses to both retail and professional investors are available; the SFC has introduced regimes that allow the offering of certain VA products to the Hong Kong public with appropriate investor protection safeguards. The SFC put forward requirements for SFC-authorized funds with regard to two categories: (i) funds investing directly in the same spot VA tokens tradable on the SFC-licensed VATPs (i.e., direct exposure ); and (ii) funds acquiring indirect investment exposure to such VA (i.e., indirect exposure ) through futures traded on conventional regulated futures exchanges. A snapshot of the requirements on SFC-authorized VA Funds Pre-requisites to start with are that the Funds should meet the applicable requirements in the Overarching Principles Section and the Code on Unit Trusts and Mutual Funds (“UT Code”) in the SFC Handbook for Unit Trusts and Mutual Funds, Investment-Linked Assurance Schemes and Unlisted Structured Investment Products. Additional requirements are applicable to the followings (please refer to original for details): (a) Management companies : good compliance record with competent staff knowledgeable in VA product. (b) Eligible underlying VA : accessible on SFC-licensed VATPs. (c) Investment Strategy : (i) funds with direct or indirect exposure in eligible VA tokens; (iii) only for those traded on conventional regulated futures exchanges; (iii) no leverage in exposure to VA at the fund level (d) Transactions and direct acquisitions of spot VA : (i) transactions and acquisitions of spot VA by SFC-authorised VA Funds should be conducted through SFC-licensed VATPs, or authorized financial institutions where subscriptions can be in form of “in-cash” or “in-kind” types; (ii) both in-kind and in-cash subscription and redemption are allowed for SFC-authorised spot VA ETFs. (e) Custody : (i) the custodian function of the VA Fund should only be delegated to SFC-licensed VATPs or any authorised financial institutions ("AIs”); (ii) VA holdings owned by clients should be segregated, and stored most in cold wallet for safety purpose; (iii) the private keys should be securely stored. (f) Valuation : an indexing approach based on VA trade volume across major VA trading platforms should be adopted. (g) Service Providers : it is necessary to ensure all service providers are competent. (h) Disclosure and Investor education : the offering documents, including the product key facts statements (“KFS”), of SFC-authorised VA Funds should disclose the investment limits and key risks related to the funds’ VA exposures. (i) Distribution : refer to the relevant requirements for intermediaries and distribution of SFC-authorised VA Funds as set out in the Joint Circular (dated 22 Dec 2023 SIGNIFICANCE: Hong Kong maybe the first pioneer in allowing the public offering of spot VA ETF , and it further consolidates the status of Hong Kong being the international financial centre for licensing regime of digital assets. The HKEX should also ensure the infrastructures should be adaptable and aligned to keep pace with the rapid and ever-evolving VA landscape in order to maintain the competitiveness and attractiveness of Hong Kong as an international financial centre as well. 3. HKMA proposes to implement regulatory regime for stablecoin issuers to secure protection to the public In an announcement on 27 Dec 2023, the Financial Services and the Treasury Bureau (“FSTB”) and the HKMA jointly issued a public Consultation Paper on the legislative proposal for implementing the regulatory regime for stablecoin issuers in Hong Kong. An executive summary for your glance as below. Virtual assets and stablecoins Virtual assets (“VA”), often referred to as crypto-assets, are digital representations of value that are cryptographically secured, typically through the use of distributed ledger technology (“DLT”), like blockchain. Given the intrinsic high price volatility which suffocate the growth of VA, the emergence of stablecoins seems to offer a solution to tackle the problem. Stablecoins can be visualized as a VAs which aim to maintain a stable value with reference to certain asset such as fiat currencies. It can be envisaged as exchanging fiat currency with a stablecoin issuer in return or stablecoins of equivalent value, or vice versa. These tokens with stable value on blockchain could help mitigate the abovementioned issues of high volatilities, which could in turn improve the overall efficiency of “on-chain” transactions. Potential use cases and risks of stablecoins With the use of DLT, payment and settlement via stablecoins could become more efficient and transparent, and when used in conjunction with smart contracts, stablecoins could also function as “programmable money” and be used to execute complex transactions. The VA market is still far from maturity and will likely continue to evolve, and stablecoins could become the interface between traditional finance and the VA markets. Yet, from the users’ perspective, they could suffer financial losses and disruption in their supposedly smooth daily payment routines if stablecoin issuers fail to maintain adequate reserve assets to uphold the stable value of the stablecoin, especially in redeeming back to fiat currencies. Formulation of a regulatory regime In the light of the potential risk of stablecoins, under our proposed regime, an issuer of stablecoins would be required to obtain a licence from the HKMA if it issues a stablecoin that references the value of one or more fiat currencies (“ fiat-referenced stablecoin ”) in Hong Kong. The licensee would be required to put in place an effective stabilisation mechanism, such as maintaining a pool of high-quality and highly-liquid reserve assets; and would also need to comply with relevant governance, risk management and AML/CFT measure. In particular, only stablecoins issued by licensed issuers could be offered to retail investors. In an ever-changing and evolving market, there is always a dilemma of safeguarding financial stability and embracing innovation. With this in mind, the HKMA plans to roll out a “sandbox” to facilitate the communication of our supervisory expectations with entities that are interested in issuing stablecoins in Hong Kong. SIGNIFICANCE: According to the Consultation Paper, we have the key takeaways: (1) The consultation period will expire on 29 February 2024. (2) There is a transitional period arrangement. It is proposed that the commencement date will be effective one-month upon gazettal of the proposed new ordinance. The pre-existing fiat-referenced stablecoin (“ FRS ”) issuers currently conducting FRS issuance activities may continue to operate under a non-contravention period of 6 months, on condition that they have submitted an application to the HKMA within 3 months of the commencement of the regime; or otherwise, the FRS issuers will have to close down its business by the end of the 4th month. (3) Making a reference from international practices, it is proposed that the minimum paid-up share capital will be either HKD25,000,000 or a fixed percentage at 2% of the par value of FRS in circulation, whichever is higher will be applied. ENFORCEMENT NEWS 4. SFC fined Ruifeng Securities Limited $5.2 million and suspended its responsible officer for fund management and account opening failures On 4 December 2023, the SFC reprimanded and fined Ruifeng Securities Limited (“RSL”) HK$5.2 million over failures relating to its fund management activities and account opening procedures. It was found that RSL invested about 90 per cent of the fund’s US$94.5 million net asset value into financial instruments which was identified as having various downside factors in their own analysis and such material information was not disclosed in the fund. It was also found that RSL had failed to adopt acceptable account opening procedures for verifying the identities of clients who opened their accounts on a non-face-to-face basis through RSL’s mobile application between 26 November 2018 and 31 July 2020. As a result of this investigation, the SFC also suspended the licence of Mr Fang Zhi for 10 months from 1 December 2023 to 30 September 2024 for failing to discharge his duties as a responsible officer of RSL in charge of its fund management activities. 5. SFC banned Amy Chow Bik Sum for life for conviction of bribery offence It was announced on 13 December 2023 that the SFC had banned Ms Amy Chow Bik Sum, a former assistant customer service manager of OCBC Wing Hang Bank Limited (“OCBC”), from re-entering the industry for life following her conviction of bribery offence. The Kwun Tong Magistrates’ Court found that on 15 July 2021, Chow, who handled residential mortgage applications at OCBC, offered an employee of OCBC Wing Hang Credit Limited (“OCBC Credit”) a rebate of referral fees from an external party as a reward for referring OCBC Credit’s clients to that party, who would in turn arrange mortgage refinancing from other banks or financial institutions. The SFC considers that Chow is not a fit and proper person to be licensed or registered to carry on regulated activities as a result of her criminal conviction . 6. SFC fined Central Wealth Securities Investment Limited $1 million for breach of Financial Resources Rules On 18 December 2023, the SFC reprimanded and fined Central Wealth Securities Investment Limited (“CWSIL”) $1 million for failures in complying with the Securities and Futures (Financial Resources) Rules (“FRR”). It was found that CWSIL made various accounting and calculation errors in the financial returns submitted to the SFC under the FRR which resulted in overstating its liquid capital between April 2019 and December 2020 (Relevant Period) which was otherwise records of deficits after eliminating the errors. CWSIL’s failure to ensure accuracy in the FRR was mainly attributable to its failure to appoint qualified and competent persons to prepare and review the FRRs, coupled with the fact that its responsible officers were not familiar with the FRR requirements as well. SIGNIFICANCE: The assurance of a qualified and competent staff to conduct the financial returns was a prerequisite to ensure compliance with the FRR under the SFC. With the rapid development and fast-changing regulatory regime in the financial industry, particularly in the recent and buoyant environment with the virtual assets and non-conventional businesses under the regime of regular regulated activities, a precise and accurate financial return prepared by competent staff is of high priority for senior staff with respect to risks management which is the pillar for sustainability of a licensed corporation. 7. SFC suspended Hau Bing Leung for 15 months for unauthorized third-party operated securities account On 27 December 2023, the SFC had suspended the license of Mr Hau Bing Leung (“HAU”), former account executive of Chee Tak Securities Limited (“CTSL”), for 15 months from 22 December 2023 to 21 March 2025. It was found in the investigation that between 1 July 2018 and 5 March 2020, Hau had allowed a third party to operate the securities account of a client at CTSL without obtaining the client’s written authorisation. Having been verbally authorized by the client, the third party and HAU also even carried out personal trades in the client’s securities account; even worse was that HAU prevented CTSL from monitoring the operation of that client’s account and his personal dealings. SIGNIFICANCE: The incidence revealed the deficiency in risk control and trades monitoring, and subsequently exposed the client to potential loss from unauthorized trading and CTSL to potential liability in case of disputes arising from trades in the account concerned. 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 To unsubscribe, please click “ unsubscribe ”.

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

在2024年9月26日，天匯合規成功舉辦疫情後的首次同業交流酒會，為業界帶來了一次難得的交流契機。 天匯合規首次同業交流酒會圓滿舉行 在 2024年9月26日，天匯合規成功舉辦疫情後的首次同業交流酒會，為業界帶來了一次難得的交流契機。活動吸引了近五十名來自金融、銀行等行業的專業人士參加。現場氣氛熱烈，參加者們熱情互動，分享了最新的行業動態與創新觀點。 整個活動過程中，與會者們積極交流，深入探討當前市場的挑戰和機遇，並就如何共同推動行業發展提出了寶貴意見。酒會不僅促進了彼此間的了解，還加強了各機構之間的合作聯繫。參加者們對於活動的組織與內容給予高度評價，認為這樣的交流機會對於行業發展具有重要意義。 大家一致表示，期待天匯合規能夠在未來繼續舉辦更多類似的活動，提供更多的交流平台，促進不同領域的專業交流與資源共享。此次酒會不僅加強了業界聯繫，也為未來的合作奠定了堅實的基礎，成為行業內交流的典範。 On September 26, 2024, ComplianceOne successfully hosted its first industry networking event since the pandemic, providing a valuable opportunity for professional exchange. Nearly fifty experts from the financial and banking sectors attended the gathering. The atmosphere was vibrant, with participants eagerly interacting and sharing the latest industry trends and innovative ideas. Throughout the event, professionals engaged in meaningful discussions, exploring current market challenges and opportunities. They also shared insights on how to drive industry growth collaboratively. The event not only fostered mutual understanding but also strengthened inter-organizational connections. Attendees highly praised the event's organization and content, emphasizing its significance for industry development. Participants expressed a strong desire for ComplianceOne to continue organizing similar events in the future, offering more platforms for professional dialogue and resource sharing. This networking event not only enhanced industry connections but also laid a solid foundation for future collaborations, setting a benchmark for industry engagement.

SFC-HKMA Joint Survey on the Sale of Non-exchange-traded Investment Products 2024 SFC-HKMA Joint Survey on the Sale of Non-exchange-traded Investment Products 2024 Sep 2025 The Securities and Futures Commission (“ SFC ”) and the Hong Kong Monetary Authority (“ HKMA ”) published the conducted annual joint survey on the distribution of non-exchange-traded investment products, showing record sales and level of market participation of these products during 2024. The survey reports a 40% surge, reaching a record HKD 6.07 trillion in non-exchange-traded investment product sales in Hong Kong in 2024, reflecting robust market participation and investor confidence. The SFC and HKMA polled 2,477 responded firms, including 2,368 licensed corporations and 109 registered institutions licensed or registered for Type 1 (dealing in securities), Type 4 (advising on securities) or both regulated activities. The survey covered the sale on non-exchange-traded investment products from 01 January to 31 December 2024 (“ reporting period ”) by licensed corporations and registered institutions to non-professional investor clients, individual professional investors, and certain corporate professional investors where intermediaries cannot make use of a waiver of the suitability obligation. The survey indicates that all major non-exchange-traded investment product types recorded “significant” sales growth last year, according to a joint statement issued by the two regulators in September 2025. Product Type Sales Growth (%) Collective Investment Scheme 76% Structured Products 30% Debt Securities 29% According to the finding, sales of authorized collective schemes (“ CIS ”) grew 76% in 2024. Based on the survey, money market funds remained to be the top-selling CIS, followed by bond funds with an increase of 80% in 2024. Meanwhile, sales of structured products and debt securities increase by 30% and 29% year-on-year, respectively. In terms of overall transaction amount sold in 2024, the top product type sold by licensed corporation and registered institutions during the reporting period was structured products (HKD 2.567 trillion or 42%), followed by CIS (HKD 2.244 trillion or 37%) and debt securities (HKD 941 trillion or 15%). Product Type Total Sales (%) Amount in HKD Structured Products 42% $ 2.567 trillion CIS (Authorised Product) 23% $ 1.4 trillion Debt Securities 15% $ 941 trillion CIS (Non-Authorized Product) 14% $ 844 billion Swaps 4% $ 221 billion Repos and others 2% $ 100 billion Market participants observed a notable improvement in market conditions and investor sentiment throughout 2024. This shift was driven by favourable factors, including supportive policy measures from Mainland authorities, anticipations of monetary easing by major central banks, robust performance in global equity markets, and a more optimistic global economic outlook. These conditions encourage investors with a higher risk tolerance to increase their market exposure and allocate capital towards higher-yield instruments, such as equity linked structured products. On the other hand, significant downside risks including ongoing political tensions, prolonged regional conflicts, uncertainty surrounding the trade and foreign policies of the new U.S. administration, and the latent risk of a market correction prompted a more risk-averse segment of the investor base to seek shelter in lower-risk, income-oriented products. This included CIS and debt securities, such as money market funds and sovereign bonds. What to expect from the Regulators? The SFC and the HKMA will initiate a new round of concurrent thematic review of the distribution of non-exchange traded investment products by intermediaries. The upcoming concurrent thematic review will examine selected intermediaries’ policies and procedures, systems and controls, and management oversight concerning the distribution of CIS. The objectives of this review include evaluating intermediaries’ compliance with the suitability requirement under the Code of Conduct, including their practices in performing product due diligence, conducting suitability assessments and providing information to clients. If you have any questions, please feel free to Contact Us .

Guideline on Streamlined approach for SPI