Page 56 - 期货和衍生品行业监管动态（2024年1月）

期货和衍生品行业监管动态

(AML/CFT) and other regulatory requirements between March 2016 and October

2018 (Note 2).

The SFC considers that CIFHKL’s failures were attributable to Wong’s failure to

discharge his duties as an RO and a member of the senior management of CIFHKL

during the material time.

The SFC’s investigation found that CIFHKL, without conducting adequate due

diligence, was unable to properly assess and manage the money laundering and

terrorist financing and other risks associated with permitting its clients to use client

supplied systems (CSSs) in placing orders. The SFC also found that CIFHKL failed

to conduct proper enquiries on client deposits which were incommensurate with the

clients’ declared financial profiles and establish effective ongoing monitoring system

to detect and assess suspicious trading patterns in client accounts (Notes 3 & 4).

In deciding the disciplinary sanctions against Wong, the SFC took into account

that:

● the failures of him and CIFHKL to diligently monitor clients’ activities and

put in place adequate and effective AML/CFT systems and controls are

serious because their failings could undermine public confidence in, and

damage the integrity of, the market;

● a strong deterrent message needs to be sent to the market that such failures

are not acceptable; and

● he has an otherwise clean disciplinary record.

Notes:

1. Wong was licensed under the Securities and Futures Ordinance to carry on

Type 2 (dealing in futures contracts) regulated activity and was accredited to

CIFHKL and approved to act as its RO from 25 November 2015 to 2 March

2020. Wong was also CIFHKL’s MIC of key business line and overall

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