DEEP ANALYSIS SERIES · 8 CASE FILES

Enforcement Files:
SFC · HKMA · IA

Hong Kong's three regulators' most instructive fine cases — each dissected by statute: what happened, why it matters, the legal analysis, RegSir's take, and the penalty formula decoded in the capstone.

Updated: 2026-10-21 8 articles · ~9 min each Sources: SFC/HKMA/IA announcements, eLegislation, public reporting
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Insurance Industry Enforcement

2024–26 · Insurance AML

The IA's Twin Giants: AIA HK$23m & FWD HK$19.5m

The two largest-ever IA fines — forged PPD declarations, HK$23.8m in split-cash, 58 missed PEPs.

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2026 · Intermediaries

Personal Liability: The Signal Behind HK$429k

Three brokerages fined, three individuals reprimanded, first-ever criminal prosecution — accountability goes personal.

Deep analysis →
2024 · Intermediaries

Unlicensed Referrals: The First IA-ICAC Joint Raid

90%+ of commissions as referral fees, reps as rubber stamps, false declarations — s.64G carries two years.

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2024–25 · Brokers

Small Fines, Big Signals: The Amount Is Not the Point

HK$12,000 over an HK$11.8m PI shortfall; HK$37,270 over a client's lost HK$72,730 — small figures flag big defences.

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2024–25 · Conduct

Integrity Lines: Forged Signature Ban · Fake Degree Bars

Four-month suspension for a photocopied signature; 23–35-month bars for degrees that never existed.

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Banking AML Enforcement

2022–24 · Banking AML

The HKMA Ladder: Unnamed HK$16m to Fubon HK$4m

Four fines in four years — DBS at the cap, one bank anonymous, Fubon mitigated — the s.21 formula decoded.

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Licensed-Corporation Controls

2021–25 · Code of Conduct

UBS Fined Twice: The 12-Year PI Error

Same root cause, two fines — 560 joint accounts misclassified as PI; a chronic compliance condition.

Deep analysis →
2025 · Product Due Diligence

EFG HK$10.85m: Not Knowing What You Sell

A joint SFC–HKMA action — six years of PDD failure exposes the weakest link in the distribution chain.

Deep analysis →
2025 · Client Assets

IBKR HK$586bn: The Price of One Line of Code

One bug, three years, HK$586bn of client securities lent without authority — tech risk is compliance risk.

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2026 · Internal Controls

Control Sweep: Bright Smart & Kylin

Wash-trade surveillance + fund-management failures — the SFC's lens turns to mid-tier firms' daily controls.

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The Framework

2019 · Sponsors

The HK$787m Sponsor Fines: IPO Diligence's Ceiling

The SFC's largest-ever sponsor penalties — four investment banks' diligence failures, the outer limit of gatekeeper duty.

Deep analysis →
Analysis · Penalty Framework

Penalty Arithmetic: Three Regulators, Three Formulas

The "HK$10M or 3×" cap structure + aggravating/mitigating weights — why IBKR drew HK$4.2m and AIA HK$23m.

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