Prevention of Money Laundering and Terrorist Financing

1
Prevention of Money Launderingand Terrorist
Financing

• 22 June 2005

2
Outline of our Legal Seminar

• What is Money Laundering and Terrorist Financing
• The Legislation on money laundering in Hong Kong
• Basic policies to combat money laundering and
  terrorist financing
• The general trend and development in anti-money
  laundering in other jurisdictions
• (Break Time)
• Guidelines for banking practice
• Practices in other trades and industries
• Case studies
• Summary Conclusion
• Questions and Answers Session

3
What is Money Laundering?

• Money Laundering covers all procedures which
  change the identity of illegally obtained money
  so that it appears to have originated from a
  legitimate source.

4
3 Stages of Money Laundering

• Placement ( ?? ) physical disposal of dirty
  cash
• Layering ( ?? ) series of transfers of funds to
  disguise the origin
• Integration ( ?? ) use layered funds to
  purchase clean legitimate assets

5
What is Terrorist Financing?

• Terrorist Financing refers to the carrying out
  of transactions involving funds or property that
  are owned or controlled by terrorists or
  transactions that are linked to terrorist
  activities

6
The legislation on Money Laundering and Terrorist
Financing in Hong Kong

• Drug Trafficking (Recovery of Proceeds) Ordinance
  (DTROP) (Cap. 405)
• ?405???(????)??
• Organized and Serious Crimes Ordinance (OSCO)
  (Cap. 455)
• ?455???????????
• United Nations (Anti-Terrorism Measures)
  Ordinance (UNATMO) (Cap. 575)
• ?575? ???(???????)??
• United Nations Sanctions (Afghanistan) Regulation
  under the United Nations Sanctions Ordinance
  (UNSO) (Cap. 537)
• ?537? ???????

7
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• Provisions for investigating suspected assets,
  freezing assets on arrest and confiscation of
  proceeds from drug trafficking

8
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• S.25 specifies a criminal offence if a person
  commits an offence if he deals with property
  knowing or having reasonable grounds to believe
  it represents a persons proceeds of drug
  trafficking
• Dealing includes
• receiving or acquiring the property
• concealing or disguising the property
• disposing of or converting the property
• bringing the property into or removing it from HK
• using the property to borrow money, or as
  security

9
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• ??(dealing),?????????25?????????,?? -
• (a) ????????
• (b) ????????
• (c) ????????
• (d) ?????????????
• (e) ??????,????

10
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• Max penalty
• on conviction upon indictment - HK5,000,000 fine
  and imprisonment for 14 years
• On summary conviction HK500,000 fine and
  imprisonment for 3 years

11
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• In practice, it is likely to cover situations
  where one enters into/is otherwise concerned in
  an arrangement to facilitate the movement of the
  proceeds of drug trafficking/the obtaining of
  credit secured on those proceeds/assisting in the
  investment of those proceeds on behalf of that
  client

12
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• S.25A(1)
• imposes an obligation on a person who
  knows/suspects that any property represents
  proceeds from drug trafficking to disclose such
  knowledge/ suspicion to an authorized officer (
  ???? ).
• Max penalty
• HK50,000 fine and imprisonment for
• 3 months

13
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• An authorized officer includes any police
  officer, any member of the Customs Excise
  Department ( ?? ). and Joint Financial
  Intelligence Unit (JFIU) ( ??????? )
• The JFIU has been established by and is operated
  by the Police and Customs Excise Department. It
  functions as the local and international advisor
  on money laundering matters generally.

14
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• JFIU contact details
• Joint Financial Intelligence Unit ( ??????? )
• 16/F, Arsenal House West Wing,
• Hong Kong Police Headquarters,
• Arsenal Street, Hong Kong
• or
• GPO Box 6555
• Hong Kong Post Office, Hong Kong
• Telephone [phone] or (852) 2860 3404
  
• Fax [phone]
• Email jfiu_at_police.gov.hk 

15
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• S.25A(2) provides that if a person who has made
  the necessary disclosure under S.25A(1) does any
  act in contravention of S.25(1) and the
  disclosure relates to that act he does not commit
  an offence if
• the disclosure is made before he does that act
  and the act is done with the consent of an
  authorized officer or
• the disclosure is made after the person does the
  act and the disclosure is made on the persons
  own initiative and as soon as it is reasonable
  for him to make it

16
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• S.25(A)(3)
• Disclosure made under the Ordinance shall not be
  treated as a breach of any confidentiality
  obligations imposed by contract etc.
  Accordingly, no liability for damages will attach
  upon such disclosure

17
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• S.25A(4)
• Disclosure can be made by person in employment to
  appropriate person in accordance with procedures
  made by employer. Such disclosure is equivalent
  to disclosure to an authorized officer

18
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• S.25(A)(5)
• Person who knows or suspects that a disclosure
  has been made under S.25A(1) must not disclose to
  any other person any matter likely to prejudice
  any investigation. Otherwise, he commits an
  offence
• Max penalty
• on conviction upon indictment HK500,000 fine and
  imprisonment for 3 years.
• On summary conviction HK100,000 fine and
  imprisonment for 1 year

19
Drug Trafficking (Recovery of Proceeds) Ordinance
(DTROP) (Cap. 405)?405???(????)??

• S.26
• No witness in any civil or criminal proceedings
  shall be obliged to reveal the identity of the
  person making the disclosure except in
  proceedings for an offence under section 25, 25A
  and 26 of the DTROP, or where court takes the
  view that justice cannot be fully served without
  revealing the identity of the person making the
  disclosure

20
Organized and Serious Crimes Ordinance (OSCO)
(Cap. 455)?455???????????

• S.25
• Extends the money laundering offence to cover the
  proceeds of all indictable offences in addition
  to drug trafficking
• Examples of indictable offences ( ????? ) include
  any crime or offence for which a magistrate is
  authorized or empowered or required to commit the
  accused person to prison for trial before the
  court e.g. theft, robbery, kidnapping

21
Organized and Serious Crimes Ordinance (OSCO)
(Cap. 455)?455???????????

• S.3 to S.5
• An authorized officer may apply to court for
  order requiring information material to be
  produced/ search warrant to be granted

22
Organized and Serious Crimes Ordinance (OSCO)
(Cap. 455)?455???????????

• S.25, S.25A and S.26
• modelled upon S.25, S.25A and S.26 of DTROP
• Reference to drug trafficking becomes reference
  to indictable offences
• Same penalties apply as in DTROP

23
United Nations (Anti-Terrorism Measures)
Ordinance (UNATMO) (Cap. 575)?575?
???(???????)??

• UNATMO is directed towards all terrorists.
• UNATMO criminalizes the supply of funds and
  making funds or financial (or related) services
  available to terrorists or terrorist associates,
  permit terrorist property to be frozen and
  subsequently forfeited

24
United Nations (Anti-Terrorism Measures)
Ordinance (UNATMO) (Cap. 575)?575?
???(???????)??

• Terrorist means a person who commits, or
  attempts to commit, a terrorist act or who
  participates in or facilitates the commission of
  a terrorist act
• Terrorist associate means an entity owned or
  controlled, directly or indirectly, by a
  terrorist

25
United Nations (Anti-Terrorism Measures)
Ordinance (UNATMO) (Cap. 575)?575?
???(???????)??

• Terrorist act is defined as the use or threat
  of action that would have the effect of
• causing serious violence against a person
• causing serious damage to property
• endangering a persons life
• creating a serious risk to the health or safety
  of the public or a section of the public
• seriously interfering with or seriously
  disrupting an electronic system or
• seriously interfering with or seriously
  disrupting an essential service, facility or
  system, whether public or private
• and

26
United Nations (Anti-Terrorism Measures)
Ordinance (UNATMO) (Cap. 575)?575?
???(???????)??

• the use or threat is
• intended to compel the Government or to
  intimidate the public or a section of the public
  and
• made for the purpose of advancing a political,
  religious or ideological cause

27
United Nations (Anti-Terrorism Measures)
Ordinance (UNATMO) (Cap. 575)?575?
???(???????)??

• ?????? ?
• (A) ??????????
• (B) ??????????
• (C) ????????????????
• (D) ????????????????????
• ????
• (E) ???????????????
• (F) ???????????????????

28
United Nations (Anti-Terrorism Measures)
Ordinance (UNATMO) (Cap. 575)?575?
???(???????)??

• A list of terrorists or terrorist associates
  is published in the Gazette from time to time
  pursuant to S.10 of the United Nations Sanctions
  (Afghanistan) Regulation and S.4 of the UNATMO

29
United Nations (Anti-Terrorism Measures)
Ordinance (UNATMO) (Cap. 575)?575?
???(???????)??

• S.12(1) requires a person to report his knowledge
  or suspicion of terrorist property to an
  authorized officer who includes a police officer,
  a member of CE, Immigration and ICAC
• Failure to disclose will constitute an offence
  and attracts a fine of HK50,000 max. and
  3-months imprisonment
• Similar to DTROP and OSCO, disclosure pursuant to
  the UNATMO shall not be regarded as breach of
  confidentiality obligations imposed by contract
  etc.

30
United Nations Sanctions (Afghanistan) Regulation
under the United Nations Sanctions Ordinance
(UNSO) (Cap. 537)?537? ???????

• UNSO provides for a prohibition on making funds
  available to designated terrorists

31
Basic policies to combat money laundering and
terrorist financing

• All relevant institutions should
• issue a statement of policies and procedures for
  dealing with money laundering and terrorist
  financing reflecting the current statutory and
  regulatory requirements
• regularly review the policies and procedures on
  prevention of money laundering and terrorist
  financing to ensure their effectiveness
• adopt customer acceptance policies and procedures
  which are sensitive to the risk of money
  laundering and terrorist financing

32
Basic policies to combat money laundering and
terrorist financing

• conduct customer due diligence (CDD) depending
  on different types of customers, business
  relationships or transactions
• ensure that the content of relevant industry
  Guidance Note is understood by all employees
• promote employees awareness and vigilance to
  guard against money laundering and terrorist
  financing

33
Basic policies to combat money laundering and
terrorist financing

• Policies should cover the following aspects
• Communication of group policies on anti-money
  laundering and terrorist financing
• Account opening and customer identification
• Maintenance of records
• Compliance with relevant legislation
• Co-operation with relevant law enforcement
  authorities, including timely disclosure of
  information
• Internal audit to ensure compliance with
  policies, procedures, and controls on anti-money
  laundering

34
Systemic Approach to Identifying Suspicious
Transactions recommended by JFIU

• Step one Recognition of a suspicious financial
  activity indicator or indicators
• Step two Appropriate questioning of the customer
• Step three Review of information already known
  about the customer in deciding if the apparently
  suspicious activity is to be expected from the
  customer
• Step four Consideration of Steps 1-3 above to
  make a subjective decision on whether the
  customers financial activity is genuinely
  suspicious or not

35
Points to note on CDD

• Client identification
• Take all necessary steps to establish true
  identity of client
• Individual/origin/background/profile
• Corporations
• identification of directors/searches/credit
  reference /identification of shareholders
• beware of companies with nominee shareholders and
  bearer shares/ownership structures/place of
  incorporation/nature of business and activities
• Determine risk profile of customers - PEPs,
  casinos, NCCTs (details of which can be found on
  FATF website)

36
Points to note on CDD

• Client identification - to continue
• Examples of low risk customers include
• financial institutions authorized and supervised
  by the HKMA, the Securities and Futures
  Commission and the Office of the Commissioner of
  Insurance
• public companies subject to regulatory disclosure
  requirements
• Trust accounts/Nominee accounts/Client accounts
• Reliance on intermediaries for CDD
• Periodic reviews of existing information

37
Points to note on CDD

• Additional CDD measures
• obtain self-declarations and comprehensive
  profile
• information re source of funds
• anticipated account activity etc.

38
Record Keeping

• Keep records to enable a sufficient audit trail
  to be followed
• Keep records for at least such periods prescribed
  by the relevant industry regulators i.e. HKMA and
  other relevant legislation
• For each account
• beneficial owner
• volume, origin and destination of funds flowing
  through the account
• person giving instructions

39
Record Keeping

• For selected transactions
• origin of the funds
• form in which funds were transferred
• person giving instructions
• destination of funds

40
Procedures for disclosures

• Coordinate through a central point, say, senior
  compliance officer
• Keep register of reports made to compliance
  department and to JFIU

41
Education and Training

• Put programmes in place for training staff on an
  ongoing basis

42
The General trend and development in anti-money
laundering and terrorist financing

• The position in other jurisdictions
• 1988 - UN Convention against Illicit Traffic in
  Narcotic Drugs and Psychotropic Substance
• 1989 - Establishment of FATF 33 members, 31
  countries governments and 20 observers - Forty
  Recommendations drawn up in 1990
• 1996 - Recommendations were revised (1st Revised)
  FATF endorsed by 130 countries

43
The General trend and development in anti-money
laundering and terrorist financing

• 1997 - DTROP S.25, UNSO
• 8.9.97 Law Society - Money Laundering Guidance
  Notes for Solicitors - cir 97-280(SD) DTROP and
  OSCO
• 2000 - OSCO
• HKMA Guideline on Prevention of Money Laundering

44
The General trend and development in anti-money
laundering and terrorist financing

• 2001
• September - 9.11 Event
• October - expanding FATF mandate to terrorist
  financing
• 2002 UNATMO, DTROP Cap 405 (1.1. 2003)

45
The General trend and development in anti-money
laundering and terrorist financing

• 2003
• Financial Action Task Force (Revised) FATF Forty
  Recommendations extending the effects to lawyers
  Recognized by International Monetary Forum (IMF)
  and World Bank
• Money Laundering Cir 03-428 (SD)
• 2004 - S25A DTROP
• 22.10.2004 FATF further amendments

46
The General trend and development in anti-money
laundering and terrorist financing

• 2005
• Law Society Money Laundering Cir 05-291 (SD)
  30.5.2005
• Bill
• OUR TALK ON 18 JUNE 2005

47
Members of Financial Action Task Force

• Argentina
• Australia
• Austria
• Belgium
• Brazil
• Canada
• Denmark
• European Commission
• Finland
• France
• Germany

• Greece
• Gulf Cooperation Council
• Hong Kong, China
• Iceland
• Ireland
• Italy
• Japan
• Luxembourg
• Mexico

• Netherlands
• New Zealand
• Norway
• Portugal
• Singapore
• Spain
• Sweden
• Switzerland
• Turkey
• United Kingdom
• United States

48
Effect of the Laws/Regulations

• Overview
• Drug Trafficking (Cap 405)
• Organized and Serious Crimes (Cap 455)
• United Nations (Anti-Terrorism Measures)
  Ordinance (Cap 575)
• United Nations Sanctions (Afghanistan) Regulation
  under the UNSO (Cap 537)

• Authorized Agent
• S25A ???,??? -???
• S25A, S3 to 5 Confidentiality or Professional
  Privilege

49
S12(1)
50
Guidelines for Banking Practices

• Hong Kong Monetary Authority Guidelines
• Applies directly to all banking and deposit
  taking activities in Hong Kong carried out by
  authorized financial institutions

51
Hong Kong Monetary Authority Guidelines

• HKMA Guidelines Section 5.21 effectively pass the
  responsibility for the verification of customer
  identity and apparent legitimacy from the bank to
  the intermediary
• A know-your-customer policy and procedure (KYC
  policy) for financial institutions
• A sample of KYC Questionnaire for client is shown
  in the attached file.

52
Examples of Suspicious Transactions

• Unusually large cash deposits
• Substantial increases in cash deposits
• Individual or company whose account shows
  virtually no normal banking or business related
  activities
• Fictitious information provided for account
  opening
• Back-to-back deposit/loan transaction with
  subsidiaries/ affiliates of overseas financial
  institutions in known drug trafficking areas
• Investment management services requested by
  clients where source of funds is unclear or not
  consistent with the clients apparent standing

53
Examples of Suspicious Transactions

• Building up of large balances, not consistent
  with known turnover of customers business, and
  subsequent transfer to accounts held overseas
• Unexplained electronic fund transfers
• Changes in employee characteristics e.g. lavish
  life styles
• Any dealing with an agent where identity of
  ultimate beneficiary or counterparty is
  undisclosed
• Customers repay problem loans unexpectedly
• Request to borrow against assets where the origin
  of the assets is not known

54
The Securities Industry

• Equally vulnerable to money laundering and
  terrorist financing
• Likely to be used in Layering stage whereby
  cash can be transformed into various forms of
  assets such as securities, bonds, futures
  contracts etc
• Securities are highly liquid and therefore prove
  attractive to money launderers

55
SFC Guidance Note - April 2003

• Provide comprehensive guidance to the securities
  industry in developing appropriate policies and
  procedures to combat money laundering and
  terrorist financing
• For use primarily by corporations licensed under
  SFO and associated entities which are not
  authorized financial institutions

56
Consultation paper on Proposed Revised Prevention
of Money Laundering and Terrorist Financing
Guidance Note (April 2005)

• To bring in line with new set of anti money
  laundering and anti terrorist financing
  recommendations issued by FATF in June 2003 and
  Oct 2004
• To provide guidance on areas of practical
  application e.g.identification of individual
  customers ,measures to mitigate risk posed by non
  face to face customers

57
Examples of suspicious transactions

• Large or unusual settlements of transactions in
  cash or bearer form
• A client who deals with a broker only in cash
  rather than through banking channels
• Requests by customers for investment management
  services where the amount of funds is not
  consistent with the customers apparent standing
• FATF issued a paper in April 2002 on guidance for
  financial institutions in detecting terrorist
  financing
• Gazette notices

58
The Insurance Industry

• Similar to the securities industry, the insurance
  industry has its own guidance note in Nov 2000 to
  guard against money laundering. The Guidance
  Note is supplemented by 2 further guidance notes
  published in June 2003.

59
Insurance Industry Guidance Note

• The Guidance Note and other supplements apply to
  all authorized insurers, insurance agents and
  insurance brokers carrying on a long-term
  business which are not financial institutions
  authorized by the HKMA

60
Insurance Industry Guidance Note

• The Guidance Note
• explains what is money laundering and terrorist
  financing
• sets out the principal HK legislation governing
  these matters
• sets out policies and procedures in dealing with
  possible money laundering together with detailed
  guidance on customer verification and retention
  of records and
• gives examples of suspicious transactions

61
Examples of Suspicious Transactions

• Purchase of large single-premium insurance
  policies and their subsequent rapid redemption
• Request for early encashment of single premium
  policies, for cash or settlement to an individual
  third party
• A money launderer may arrange with groups of
  people to assign any legitimate claims on their
  policies to be paid to money launderer

62
Legal Industry

• Law Society Guidance Notes For Solicitors
• (Circular 97-280 attached)
• Aware of the legislation
• alert to any unusual circumstances
• make further enquiries of their clients where
  appropriate
• Institute anti-money laundering procedures
• appoint a compliance officer
• staff training
• establish internal reporting procedures
• establish record keeping procedures

63
Law Society Guidance Notes For Solicitors

• The Office Manual of K. C. Ho Fong are in
  compliance to the Law Society Guidance Note.
  Extracts from our office manual are attached

64
Case Study - Case 1

• Based on
• HKMA Guidelines Section 5.21 states
• Where the applicant for business who is acting
  on behalf of another person is an intermediary
  with which the financial institution has an
  established business relationship and where the
  institution is fully satisfied as to its
  reputation, conduct and good faith, it shall be
  reasonable for the institution to accept a
  written assurance from the applicant for business
  that evidence of the underlying principals has
  been obtained, recorded and retained, and that
  the applicant is satisfied as to the source of
  funds
• The guidelines effectively pass the
  responsibility for the
• verification of customer identity and
  apparent legitimacy
• from the bank to the intermediary

65
Case 1 ...

• The case
• Mr. A, qualified
• accountant

Company B, subsidiary of major accounting firm

• Buy 2 shelf companies C and D both registered
  in Western Samoa
• No enquirers on beneficial owners of the shelf
  companies, relying on professional relationship
  with Mr. A
• Open bank accounts in name of company C and
  company D with a bank in HK

• Bank made no background enquiries due to its
  established professional relationship with
  Company B.

66
Case 1 ...

• The case
• Transactions on Company Cs bank account
• Over HK3 million cash deposit
• No identification on depositor
• No withdrawals made ever

• Origin of the funds
• Over 90 million traced including the 3 million
  in the bank account of company C.
• Beneficial owner of company C arrested in UK for
  dealing in proceeds of drug trafficking

67
Case 1 ...

• The case
• Transactions on company Ds bank account
• Mr. F, beneficial owner of Co D
• used C550K cash from another bank
• (vis T/T
  transaction cost HK7,000)
• - Bank account of co. D in HK
• (vis T/T
  in A - transaction HK10,825)
• - Bank in Western Samoa
• Mr. F also used another C192K cash
• to buy US140K worth of T/chq
• __________________________________________________
  ___
• Origin of the funds
• Mr. F arrested in Australia charged with
  conspiracy to traffic in dangerous drugs and
  dealing in the proceeds of drug trafficking

68
Case 1

• Indicators of money laundering in the case
• Use of shelf companies and company formation
  agencies
• Inconsistent account activity with no normal
  business transactions
• Account used as temporary repository (layering)
• Large cash deposits with no explanation as to
  source of the money
• Uneconomical transactions
• Involvement of off-shore financial centre
  (Western Samoa)

69
Case Study - Case 2

• Based on
• SFC Guidance Note on Money Laundering (Section
  4.5.4) expects staff of SFC regulated
  institutions to
• (know) enough about a customers business and
  financial circumstances to recognize that a
  transaction, or series of transactions, is
  unusual

70
Case 2 ...

• The case
• Mr. Y 7M
• draw cheque
• on Co. X
• 
  Bank 1
• Address public housing unit
• Occupation not recorded
• Business address not recorded

7M cashier order
Active trading of shares of company N
Company Ns shares price rose by 27 in 2 months

• 15M cashier order
• 1.0M cash withdrawn
• 2M cash withdrawn

1.6M cash deposit 17M cashier order

• Co. X (controlled by Mr. P)

Bank 2
71
Case 2 ...
Mr. Y draw 7M cheque on Co. X

• Sudden large sums of money passing through the
  account
• No information on Mr. Ys business activity to
  explain source of funds
• Unusual for low cost handling required to have
  big amount passing through the accounts in
  relatively short time

Bank 1
Bank 2
72
Case 2 ...
Investigation by Police and SFC

• Mr. P (Senior member of triad society)
• Beneficial owner of Co.X
• Major beneficiary of 1.6M profit generated from
  Mr. Ys dealing in Co. Ns shares

• Mr. Y (member of triad society)

Note Insufficient evidence to substantiate
criminal charges However, strong suspicion that
Mr. Y and Mr. P had conspired to create false
trading in Co. N shares
73
Case 2

• Stock broker should have noticed and made a STR

• SFC Guidance Note 4.5.4
• Mr. Ys account was opened specifically to deal
  in the shares of Co. N
• Little information on Mr. Y or his business to
  explain the trading of the shares with
  substantial turnover and frequency
• Investigated by JFIU but not prosecuted
• Reminded by JFIU to set up anti-money laundering
  systems and reporting procedures

74
Summary and Conclusion

• Note the following tips
• Purpose of anti-money laundering and
  anti-terrorist financing legislation
• against crimes
• Establish Internal Policy
• How to identify suspicious acts
• read the relevant industry guidance carefully

75
Summary and Conclusion

• More importantly talk to your supervisor/ manager
  about any suspicious acts/ transactions of
  clients
• Record / File Notes / Document Handling should be
  well-organized and preserved at Godown / Storage
• Good and sensible judgement

76
Prevention of Money Laundering and Terrorist
Financing

• Any Questions?
• Comments?

77
Contacts of K. C. HO FONG

• Office address
• 18th Floor, Henley Building,
• No. 5 Queens Road Central
• Telephone [phone]
• Fax [phone] 1308
• E-mail office_at_kcho-fong.com
• Mr Junius Ho Partner Direct line 2523
  3846
• Ms Anna Chong Consultant Direct line
  2180 8683
• Miss Peggy Liu Consultant Direct line
  2185 7777