Monday, February 29, 2016

SFC Circular to Licensed Corporations Licensed for Dealing in Securities on Protecting Client Assets against Internal Misconduct

The Hong Kong Securities and Futures Commission (“SFC”) has issued a circular on protecting client assets against internal misconduct at licensed corporations (“LCs”) licensed for dealing in securities. The SFC has observed that some LCs have weak internal controls and lax management supervision. This renders them susceptible to the threat of internal misconduct, which could result in theft and fraud against client assets. Internal misconduct may be perpetrated not only by front office staff, but also by back office staff, collusion between front and back office staff, or collusion between staff and third parties.

Tuesday, February 2, 2016

BRP Opens First Office in Asia

Maroon is pleased to announce that our partners BRP Bizzozero & Partners, experts on the management of cross-border risks, have set up their subsidiary in Singapore with a successful launch event held at the Arts House last month.

This is the firm's first foray into Asia, after already having operations in Geneva, Zurich, London and Luxembourg. BRP (Asia) Private Limited will provide the firm with a foothold in the Asian market and a platform to work closer with clients in the region.

BRP is widely recognised for its Country Manuals that provide guidance on compliance in cross-border financial services. In addition to the Country Manuals Private Banking, of which BRP has already published Country Manuals for over 110 jurisdictions, other Country Manuals cover areas such as asset management, taxes and financial products.

News on the launch of BRP (Asia) was also recently featured in reputable finance media outlet, Finews. Click here to see the article.

Those interested to know more about BRP's services may contact Maroon at or contact BRP (Asia) directly at

Monday, February 1, 2016

Illicit Personal Dealing through Other Persons’ Accounts

Personal dealing, or personal trading has become a relatively recurring topic in a time where miscreants in the financial industry are inventing new ways to circumvent laws and internal policies. In the past monthsHong Kong has seen several cases of enforcement actions taken against representatives of financial institutions with regards to personal dealing activities.
Most recently, the Securities and Futures Commission ("SFC") banned a representative licensed under the Securities and Futures Ordinance ("SFO) from re-entering the industry for 10 months for side-stepping the personal dealing policies of his employers. He hid his personal securities transactions from his employers by operating them through the personal securities account of his friend who was also a licensed representative in another firmThe friend has also been suspended by the SFC for a period of three months for abetment. The conduct of both representatives was in breach of the SFC's Code of Conduct which requires licensed corporations to actively monitor the personal trading activities of their employees. As a result of their actions, their respective employers were not able to ensure that there were no conflicts of interests or misconduct arising from their personal trading activities.