The Hong Kong government’s Money Laundering and
Terrorist Financing Risk Assessment report
has paid little attention to the risks posed by certain type of
activities, including those linked to virtual currencies and
trade finance arrangements, to the surprise of market
One of the most striking features of the report is in
section three which outlines the enforcement landscape between
2013 and 2017. Even though there has been an almost
threefold growth in suspicious transaction reports, the number
of prosecutions has decreased over the same period, including a
decrease in sentences and confiscation or proceeds orders.
There has also been a lack of high profile enforcement cases
which would have a stronger deterrent effect.
Another interesting statistic is the discrepancy between the
number of requests made (low) versus the number of requests
received (high) under the mutual legal assistance framework.
This indicates that...