Jurisdiction - Hong Kong
Reports and Analysis
Hong Kong – US And Asia Authorities Increase Their Focus On Money Laundering.

24 November, 2014


Overnight news wires have reported a major investigation into casino operator, Wynn Resorts, over concerns regarding the company’s money-laundering controls. The reports note that prosecutors from the Manhattan and Las Vegas US Attorney’s offices, together with the Internal Revenue Service and Drug Enforcement Administration, are cooperating in the investigation of the Las Vegas-based company.


The probe comes as US authorities step up their investigations of money transfers that potentially involve the proceeds of criminal activities. The press reports note that Wynn Resorts has also been asked to provide details of its biggest customers between 2011 and 2013, including the top 100 patrons from North America and the top 50 clients in Asia, Europe and Latin America.


The report highlights the importance of anti-money laundering compliance in the US. But the US is not the only jurisdiction in which enforcement authorities are closely scrutinising money transfers. Hong Kong’s position as a global financial centre, coupled with its proximity to Macau, ensures that AML compliance will continue to be a significant issue for local regulators and law enforcement bodies.


In 2013, the Hong Kong police froze assets valued at HKD 873m (USD 112m) as a result of money-laundering investigations, while the Joint Financial Intelligence Unit received 33,000 reports of suspicious financial transactions in the same year. On the criminal prosecution front, Carson Yeung, the former owner of Birmingham City Football Club, was convicted on charges of laundering HKD 721m (USD 92m) and sentenced to six years imprisonment. What is more, the recently enacted Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance, which imposes significant customer due diligence requirements on banks and other financial institutions, highlights the importance that local authorities place on maintaining strict AML compliance controls.


Organisations in Hong Kong and around the world are under increasing pressure to improve AML compliance. The Herbert Smith Freehills Corporate Crime and Investigations team is currently advising a number of global and regional financial sector and other clients on AML compliance and related issues. Please contact us if you would like more information on our experience in this area.


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For further information, please contact:


Kyle Wombolt, Partner, Herbert Smith Freehills

[email protected]


Robert Hunt, Partner, Herbert Smith Freehills

[email protected]


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