Anti-Money Laundering

Hong Kong maintains a rigorous anti-money laundering and counter-terrorist financing enforcement regime. Individuals and businesses face serious criminal liability under multiple ordinances, while regulated entities must meet extensive compliance obligations. We advise on both the criminal defence and regulatory compliance dimensions of AML matters.

Money Laundering Offences & Defence

Money laundering is primarily prosecuted under the Organized and Serious Crimes Ordinance (Cap. 455) and the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405). Offences include dealing with property known or reasonably believed to represent proceeds of an indictable offence, and failure to report knowledge or suspicion of money laundering. The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) imposes additional obligations on financial institutions and designated non-financial businesses. We advise on the elements of these offences, the mental-element thresholds, and the defences available under Hong Kong law.

Regulatory Investigations & Compliance

The HKMA, SFC, and Customs and Excise Department each have enforcement roles in the AML/CFT framework. Investigations may arise from suspicious transaction reports, regulatory inspections, or referrals from overseas authorities. We advise individuals and institutions on responding to regulatory enquiries, managing the interface between regulatory and criminal investigations, and developing remediation strategies where compliance deficiencies have been identified.

If you are facing an AML investigation or need advice on compliance obligations, get in touch for practical guidance.