Recent ICAC Cases

A former bank manager who admitted taking bribes after being charged by the ICAC was today (September 18) sentenced at the District Court to four years’ imprisonment for conspiring with an employee of a fintech company (the Company) and other associates to accept Tether cryptocurrency worth over US$470,000 in total (approximately HK$3.7 million) to illegally authenticate multiple false instruments as guarantees for various insurance-related investment transactions without the bank’s authorisation.

Lam Chun-yin, 32, former relationship manager of China Construction Bank (Asia) Corporation Limited (CCB (Asia)), earlier pleaded guilty to one count of conspiracy for an agent to accept advantages, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance and section 159A of the Crimes Ordinance.

In sentencing, Judge Mr Ernest Lin Kam-hung remarked that criminality of the defendant in this case was higher than in other similar cases since it involved forged bank documents that undermined Hong Kong’s reputation as an international financial centre and exposed the bank concerned to significant potential risk. The judge took a starting point of six years’ imprisonment and reduced the sentence by one-third due to the defendant’s guilty plea. With no exceptional circumstances warranting further reduction, the defendant was sentenced to four years in prison.

The judge also ordered the defendant to make restitution of approximately HK$3.7 million, equivalent to the amount of the bribes involved, to CCB (Asia).

An ICAC spokesperson noted that the Commission cracked down on the bribery scheme even though corrupt individuals attempted to conceal their corrupt activities by using cryptocurrency to channel bribe payments indirectly. The ICAC had applied to the court for arrest warrants of other individuals implicated in the case.

CCB (Asia) is a subsidiary of China Construction Bank Corporation (CCB) in Hong Kong. At the material time, the defendant was a relationship manager of Consumer Banking Division at the Causeway Bay retail branch of CCB (Asia), responsible for providing retail banking services to individual customers. His duties never involved processing any applications for business credit facilities and Letter of Credit (L/C), and the bank had never authorised him to handle such matters.

At the material time, the Company, an overseas fintech firm named Vesttoo Limited (Vesttoo) (currently ceased operations), operated a digital platform to facilitate insurance-related investment transactions. Investors were required to provide standby L/Cs issued by banks as guarantees to ensure that if they could not cover relevant losses, the issuing bank would assume ultimate payment responsibility.

Yu Po Holdings Limited (Yu Po) became an investor via the Company in early 2022. Under arrangements made by a crime syndicate, the defendant falsely represented himself as the contact point of CCB for issuing standby L/Cs for Yu Po.

The defendant admitted that between April and June 2022, he conspired with a department head of the Company and his associates to accept bribes in Tether, worth over US$470,000. In exchange, the defendant authenticated multiple standby L/Cs falsely claiming to be issued by CCB and two collateral letters falsely claiming to be issued by Yu Po and endorsed by CCB, totalling over US$1.6 billion.

The incident was uncovered in an internal investigation by CCB (Asia), after which the bank lodged a corruption complaint with the ICAC and rendered full assistance. The ICAC enquiries revealed that neither CCB nor its sister companies had issued any of the relevant standby L/Cs and collateral letters. These false instruments would have caused potential economic and reputational damage to both CCB and CCB (Asia).

The prosecution was today represented by Senior Public Prosecutor Douglas Lau, assisted by ICAC officers Cody Chung and Carson Lau.

A former bank manager, charged by the ICAC, admitted today (September 9) at the District Court that he had conspired with an employee of a fintech company (the Company) and associates to accept bribes worth totalling over US$470,000 in cryptocurrency Tether for illegally authenticating multiple false instruments as guarantees for various insurance-related investment transactions without the bank’s authorisation.

Lam Chun-yin, 32, former relationship manager of China Construction Bank (Asia) Corporation Limited (CCB (Asia)), pleaded guilty to one count of conspiracy for an agent to accept advantages, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance and section 159A of the Crimes Ordinance. Another charge of conspiracy to use false instruments against the defendant was left on the court file.

Judge Mr Ernest Lin Kam-hung adjourned the case to September 18 for sentencing, and remanded the defendant in the custody of the Correctional Services Department.

CCB (Asia) is a subsidiary of China Construction Bank Corporation (CCB) in Hong Kong. At the material time, the defendant was a relationship manager of Consumer Banking Division at the Causeway Bay retail branch of CCB (Asia), responsible for providing retail banking services to individual customers. His duties never involved processing any applications for business credit facilities and Letter of Credit (L/C), and the bank had never authorised him to handle such matters.

At the material time, the Company, an overseas fintech company Vesttoo Limited (Vesttoo) (ceased operations), was operating a digital platform to facilitate insurance-related investment transactions. Investors were required to provide standby L/Cs issued by banks as guarantees to ensure that, should they be unable to cover relevant losses, the issuing bank would assume ultimate payment responsibility.

Yu Po Holdings Limited (Yu Po) became an investor via the Company in early 2022. Under arrangements made by a crime syndicate, the defendant falsely represented himself as the contact point of CCB for issuing standby L/Cs for Yu Po.

The defendant admitted that between April and June 2022, he conspired with a department head of the Company and his associates to accept bribes in Tether, worth over US$470,000. In exchange, the defendant authenticated multiple standby L/Cs falsely claiming to be issued by CCB and two collateral letters falsely claiming to be issued by Yu Po and endorsed by CCB, totalling over US$1.6 billion.

The incident was uncovered in an internal investigation by CCB (Asia), after which the bank lodged a corruption complaint with the ICAC and rendered full assistance. The ICAC enquiries revealed that neither CCB nor its sister companies had issued any of the relevant standby L/Cs and collateral letters. These false instruments would have caused potential economic and reputational damage to both CCB and CCB (Asia).

An ICAC spokesperson stated that the case involved an individual frontline bank staff member accepting bribes to commit illegal acts. The ICAC had applied to the court for arrest warrants of other individuals implicated in the case. The ICAC has long attached great importance to the integrity of banking practitioners. With the full support of the Hong Kong Monetary Authority, the Hong Kong Association of Banks and the banking industry, the ICAC earlier launched the Banking Industry Integrity Charter to promote an integrity culture within the sector, provide integrity training for bank practitioners to deepen their understanding of relevant anti-corruption law and corruption risks.

The prosecution was today represented by Senior Public Prosecutor Douglas Lau, assisted by ICAC officers Cody Chung and Carson Lau.

Following a corruption complaint, an ICAC investigation revealed that two employees of an e-wallet company had intentionally concealed their conflicts of interest. The duo allegedly funded and operated a technology service vendor while arranging for their spouses to serve as its directors. They further abused their positions to defraud and induce the company to award a contract for developing an application to the vendor for personal gain. The four individuals were charged today (September 8) by the Commission with conspiracy to defraud.

The four defendants are Lee Chun-yu, 46, then senior business development expert of Alipay Payment Services (HK) Limited (APSHK); Liang Jianen, 44, then senior business development manager of APSHK; as well as Lee’s wife, Leung Ka-lee, 43; and Liang’s wife, Sun Qing, 40.

The defendants face one count of conspiracy to defraud, contrary to the Common Law. They were released on bail, pending their appearance at the Eastern Magistrates’ Courts on Thursday (September 10) for plea.

APSHK, a subsidiary of Ant Group Company Limited (Ant Group), operates the Alipay e-wallet in Hong Kong. Ant Group and APSHK have established clear guidelines prohibiting employees from operating or investing in any technology service vendors with which the companies have business dealings, and require employees to declare any conflicts of interest.

At the material time, Lee and Liang were responsible for developing and managing mini-applications (mini-apps) embedded in AlipayHK. In late 2022, Lee arranged Interomni Plus Limited (IPL) as the technology service vendor for a mini-app “EKBooking”, which facilitated users making appointments and payments with medical institutions for vaccination inoculations and health checks via AlipayHK.

The charge alleges that between November 2022 and June 2025, the four defendants conspired together to defraud APSHK by dishonestly registering Leung and Sun as the sole shareholders and directors of IPL, and causing APSHK to engage IPL as the technology service vendor for the “EKBooking” mini-app.

Lee and Liang are further alleged to have operated or invested in IPL during their employment with APSHK, but failing to seek prior approval from Ant Group or APSHK or to report that Leung and Sun were their respective spouses, and failing to declare the relevant conflict of interest.

The ICAC investigation arose from a corruption complaint. Enquiries revealed the above illicit activities. At the material time, IPL charged medical institutions a commission of approximately 5% to 8% on transactions conducted through “EKBooking”.

Ant Group and APSHK rendered full assistance to the ICAC during its investigation into the case.

The ICAC recommends that private sector organisations formulate clear guidelines and mechanisms for declaring conflicts of interest. Staff members are reminded to avoid conflicts of interest and to make timely declarations to their employers. Employees who conceal any conflicts of interest in relation to their official duties to benefit themselves or their associates may constitute a breach of the Prevention of Bribery Ordinance or other criminal laws.