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Jul 2024Former apparel manufacturer employee charged by ICAC for using false quotations and receipts to swindle $480,000A former Executive Assistant of an apparel manufacturer was charged by the ICAC today (July 11) for allegedly using false quotations and receipts in relation to repair works of her employer’s properties to swindle approximately $480,000.Rachel Chong Shui-kwan, 32, former Executive Assistant of Sterling and Grant Limited (SGL), faces nine charges of agent using document with intent to deceive her principal, contrary to Section 9(3) of the Prevention of Bribery Ordinance. She was released on ICAC bail, pending her appearance at the Eastern Magistrates’ Courts tomorrow (July 12) for mention.The investigation arose from a corruption complaint. Upon completion of the investigation, the ICAC sought legal advice from the Department of Justice, which advised charges be laid against the defendant. As an Executive Assistant of SLG, the defendant, apart from handling daily administrative work of SGL, was also responsible for handling leasing matters, including renovation and repair works, of two residential units owned by her employer.Before the commencement of each works order, the defendant was required to seek approval from her employer and provide relevant quotation for the latter’s confirmation. After completion of the works, the defendant had to submit the quotation or receipt issued by the responsible contractor to the company for processing payments.Between July 2020 and January 2021, the defendant allegedly submitted false quotations and receipts to SGL on nine occasions, misleading the company that the above documents were issued by a decoration contractor and that the relevant works were completed. As a result, SGL paid a total of around $480,000 to the contractor for settling the works payments.The ICAC enquiries revealed that the abovementioned contractor had never issued the said quotations and receipts. A large proportion of the said payments were eventually deposited into the defendant’s personal bank account.SGL rendered full assistance to the ICAC during its investigation into the case. 08
Jul 2024Financial consultant charged by ICAC in JPY400m investment fraud case pleads guiltyAn ICAC corruption investigation into bank officers earlier revealed that four people had conspired with others to deceive Japanese investors into investing over JPY400 million (about HK$28.4 million) in various companies which took part in investment projects in Africa by falsely representing that those companies’ bank accounts held asset totalling over HK$37 billion, and by using false bank documents. A self-employed financial consultant today (July 8) pleaded guilty to conspiracy to defraud at the District Court.Law Man-fai, 50, self-employed financial consultant, pleaded guilty to three counts of conspiracy to defraud, contrary to the Common Law. Another similar charge against him was left on file at the District Court. Deputy Judge Ms May Chung Ming-sun adjourned the case to July 15 for mention. Law was granted bail.Two co-defendants, Woo Man-ho, 36; and Chan Tak-ching, 37, both former relationship managers of Standard Chartered Bank (Hong Kong) Limited (Standard Chartered Bank), earlier pleaded guilty to a total of four counts of conspiracy to defraud. They were granted bail until August 22 for sentence.The court heard that at the material time, Law was a self-employed financial consultant, while Woo and Chan were relationship managers of Standard Chartered Bank respectively working at its business banking department and priority banking department. The bank would issue documents to confirm the balance of a client’s account held with the bank upon request, but Woo and Chan were not authorised to sign and issue those documents.Between January 2015 and September 2016, Law, Woo and Chan had conspired with another then relationship manager of Standard Chartered Bank and four foreign nationals to defraud various Japanese investors to invest in ADF Capital Limited (ADF) and a number of companies by using false proof of fund letters and corporate refund promissory notes (CRPNs) signed by Woo and Chan, and purportedly issued by Standard Chartered Bank.The four foreign nationals involved were two shareholders-cum-directors of ADF, respectively a Zambian man and a Korean man; a Thai man who was Chan’s client; and a Japanese woman who was the chief executive officer of a company.Law admitted that he had conspired with Woo, Chan and three of the foreign nationals to falsely represent that Standard Chartered Bank was the guarantor of ADF which undertook to pay the relevant investors by issuing eight false CRPNs.Four of the CRPNs involved promised returns totalling US$7.2 million (over HK$56 million). As a result of the false representations, various Japanese investors were deceived into making investments totalling at least JPY400 million (about HK$28.4 million) to ADF and various companies involved in this case. The remaining four CRPNs involved false representations to a certain company that Standard Chartered Bank was the guarantor of ADF which undertook to pay US$50 million (over HK$390 million) for the CRPNs.Woo and Chan earlier admitted their involvements in the scam, and their issuance of false proof of fund letters which falsely represented that the Zambian man’s company had funds of US$1.5 billion (about HK$11.6 billion) available for investments in Africa, and that the Thai man had asset of 3.3 billion euros (about HK$25.5 billion) in the bank account held with Standard Chartered Bank.The ICAC enquiries revealed that Standard Chartered Bank had never held the abovementioned asset on behalf of the Thai man, while the Zambian man’s company had never held any bank account with the bank.Co-defendant Leung Ho-yin, 38, former relationship manager of Standard Chartered Bank, pleaded not guilty to two counts of conspiracy to defraud. Another co-defendant Catherine Kum Kit-ching, 55, manager of ADF, pleaded not guilty to one count of conspiracy to launder crime proceeds. The duo will appear again at the District Court on July 11 for mention.Standard Chartered Bank had rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Wong Hay-yiu, assisted by ICAC officer Janice Chan. 04
Jul 2024Funeral agent charged by ICAC guilty of bribery over servicesA funeral agent, earlier charged by the ICAC, was today (July 4) convicted at the Kowloon City Magistrates’ Courts of offering a bribe of $3,000 to a fellow church member of a deceased elderly person for securing the business of the latter’s after-death arrangements.Chak Kwok-hung, 43, sales agent of Endless Love Care Service Company Limited (Endless Love), was found guilty of one count of offering an advantage to an agent, contrary to section 9(2)(a) of the Prevention of Bribery Ordinance.In convicting the defendant, Deputy Magistrate Mr Jeffrey Lai said that Chak’s intention to commit the offence was obvious and he regarded such illegal behaviour as a “common practice” in his trade. He ordered the defendant to be remanded in the custody of the Correctional Services Department, and adjourned the case to July 18 for sentence, pending the defendant’s background report and mitigation.The court heard that on March 6, 2023, an elderly person residing in a private residential care home passed away. Prior to his death, the elderly person had given several ten thousand dollars to two fellow church members and entrusted them to take care of his funeral arrangements. Upon learning that unbeknownst to them, Endless Love had taken up the funeral arrangements of the deceased on the same day of his passing, one of the church members visited Endless Love to make enquiries.When receiving the church member at Endless Love, the defendant offered $3,000 as a rebate to the latter for appointing Endless Love to arrange the funeral services for the deceased. The church member rejected the defendant’s offer and left.The prosecution was today represented by prosecuting counsel Eddie Sean, assisted by ICAC officer Allan Fong. 25
Jun 2024Immigration consultant conspiring with client over HK$10m investment entrant fraud charged by ICACA former proprietor of an immigration consultancy was charged by the ICAC today (June 25) for allegedly conspiring with others to deceive the Immigration Department (ImmD) into granting the investment entrant application of a client by assisting the latter to make a false representation about his investment of HK$10 million in Hong Kong.Tam Chi-ming, 50, former sole director-cum-shareholder of Wealth Concepts Consultancy (Greater China) Limited (Wealth Concepts), faces one count of conspiracy to defraud, contrary to the Common Law. He was released on ICAC bail, pending his appearance at the Kowloon City Magistrates’ Courts on Thursday (June 27) for mention.In 2003, the Hong Kong Government implemented the Capital Investment Entrant Scheme (the Scheme) to facilitate the entry for residence by capital investment entrants. The ImmD was responsible for processing the relevant applications. An applicant to be granted a permission to stay in Hong Kong for two years must have net assets of a market value not less than HK$10 million throughout the two years preceding the application; and remain invested not less than HK$10 million in specific permissible investment asset classes within six months after the granting of approval-in-principle by the ImmD (the remain-invested requirement). Applicants may apply for permanent residency of Hong Kong or unconditional stay in Hong Kong respectively upon continuous ordinary residence of or investment in Hong Kong for not less than seven years.Applicants were prohibited from borrowing money for holding specified financial assets. In accordance with the remain-invested requirement, applicants were also not allowed to assign any interest in favour of others in the financial assets concerned. The Scheme was suspended in 2015.At the material time, the defendant was the sole director-cum-shareholder of Wealth Concepts, which provided consultancy services to individuals for immigration to Hong Kong. In 2015, an applicant of the Scheme engaged Wealth Concepts to handle his application.Between May 2018 and September 2023, the defendant allegedly conspired together with the applicant and others to defraud the ImmD, inducing the ImmD to grant the applicant’s application for immigration to Hong Kong and the subsequent extensions of stay in Hong Kong.It is alleged that they dishonestly submitted a false application purporting to show that the applicant had met the investment requirement and falsely represented that the applicant had invested a total sum of HK$10 million in the bonds issued by a listed company in Hong Kong and remained the absolute beneficial owner of the investment.The ICAC investigation arose from a corruption complaint. Enquiries revealed that the applicant did not have sufficient funds for meeting the relevant requirements on investment.Had the ImmD known that the applicant had made a falsely declaration on his investment, no approval under the Scheme, as well as the subsequent extensions of stay in Hong Kong, would have been granted to the applicant and his dependants.The ICAC corruption inquiries are ongoing.The ImmD has rendered full assistance to the ICAC during its investigation into the case.The ICAC has kept reviewing various investment entrant and talent admission schemes with the relevant government departments so as to strengthen regulating the schemes to stamp out malpractices. 20
Jun 2024Ex-manager of telecom company charged by ICAC gets 40 months’ jail for HK$16m fraud by concealing mother’s role in supplierA former manager of a telecommunications company, charged by the ICAC, was today (June 20) sentenced to 40 months’ imprisonment at the Court of First Instance of the High Court for deceiving the company into issuing purchase orders worth totalling over HK$30 million and making service payments totalling over HK$16 million to a supplier owned by his mother by concealing his conflict of interest.Cheung Cheuk-man, 46, former manager of PCCW Services Limited (PCCW Services), a subsidiary of PCCW Limited (PCCW), yesterday (June 19) pleaded guilty to one count of fraud, contrary to section 16A(1) of the Theft Ordinance.In sentencing, Ms Justice Esther Toh Lye-ping reprimanded the defendant for committing a premeditated crime which constituted a breach of trust. She took a starting point of five to six years’ imprisonment and reduced the jail term to 40 months, having considered the defendant’s guilty plea, full restitution of the service payments involved in the present case to his former employer and other mitigating factors.The court heard that in November 2014, the defendant was employed by PCCW Services to work as a manager of the network service team of PCCW Solutions Limited (PCCW Solutions), another subsidiary of PCCW, which provided a wide range of information technology and network solutions to its clients. PCCW’s policy stipulated that its employees and subsidiaries must make declarations where potential conflicts of interest arose.Upon the defendant’s recommendation, Go Go Wifi Limited (GGWL) was included in the list of approved suppliers of PCCW and its subsidiaries since January 2016. Between January 2016 and July 2017, the defendant procured PCCW Solutions to issue 29 purchase orders in the sum of over HK$30 million to GGWL, which subsequently received payments of about HK$8.7 million and about US$990,000 from PCCW Solutions.The ICAC investigation arose from a corruption complaint. Enquiries revealed that the defendant’s mother had become the sole director cum shareholder of GGWL since August 2014, but he had never disclosed to his employer his mother’s interests in GGWL.The defendant was responsible for obtaining quotations and confirming receipt of services before release of payments to GGWL for the 29 purchase orders. ICAC enquiries revealed that the defendant had used false quotations purportedly issued by other companies to procure awarding the contracts to GGWL by making it the lowest bidder. On various occasions, the defendant had confirmed to PCCW Solutions in writing that he had no conflict of interest in the purchases concerned.It was also revealed in the ICAC investigation that GGWL had never provided any service in relation to the 29 purchase orders. The services concerned were either provided by other service suppliers or carried out internally by PCCW Solutions.The prosecution earlier withdrew a charge of “money-laundering” against the defendant’s mother, Lee Po-mei, 67.PCCW and its subsidiaries had rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by Senior Public Prosecutor Audrey Parwani, assisted by ICAC officer Wilson Lam.The ICAC encourages public and private organisations to establish clear guidelines and systems of declaration on conflict of interest. Staff should avoid conflict of interest and make declarations in strict adherence to internal guidelines. Concealing any conflict of interest in relation to one’s official duties to benefit himself or his associates may contravene the criminal law, such as the Prevention of Bribery Ordinance if offering or accepting of bribes is involved.
Jul 2024Former apparel manufacturer employee charged by ICAC for using false quotations and receipts to swindle $480,000A former Executive Assistant of an apparel manufacturer was charged by the ICAC today (July 11) for allegedly using false quotations and receipts in relation to repair works of her employer’s properties to swindle approximately $480,000.Rachel Chong Shui-kwan, 32, former Executive Assistant of Sterling and Grant Limited (SGL), faces nine charges of agent using document with intent to deceive her principal, contrary to Section 9(3) of the Prevention of Bribery Ordinance. She was released on ICAC bail, pending her appearance at the Eastern Magistrates’ Courts tomorrow (July 12) for mention.The investigation arose from a corruption complaint. Upon completion of the investigation, the ICAC sought legal advice from the Department of Justice, which advised charges be laid against the defendant. As an Executive Assistant of SLG, the defendant, apart from handling daily administrative work of SGL, was also responsible for handling leasing matters, including renovation and repair works, of two residential units owned by her employer.Before the commencement of each works order, the defendant was required to seek approval from her employer and provide relevant quotation for the latter’s confirmation. After completion of the works, the defendant had to submit the quotation or receipt issued by the responsible contractor to the company for processing payments.Between July 2020 and January 2021, the defendant allegedly submitted false quotations and receipts to SGL on nine occasions, misleading the company that the above documents were issued by a decoration contractor and that the relevant works were completed. As a result, SGL paid a total of around $480,000 to the contractor for settling the works payments.The ICAC enquiries revealed that the abovementioned contractor had never issued the said quotations and receipts. A large proportion of the said payments were eventually deposited into the defendant’s personal bank account.SGL rendered full assistance to the ICAC during its investigation into the case. 08
Jul 2024Financial consultant charged by ICAC in JPY400m investment fraud case pleads guiltyAn ICAC corruption investigation into bank officers earlier revealed that four people had conspired with others to deceive Japanese investors into investing over JPY400 million (about HK$28.4 million) in various companies which took part in investment projects in Africa by falsely representing that those companies’ bank accounts held asset totalling over HK$37 billion, and by using false bank documents. A self-employed financial consultant today (July 8) pleaded guilty to conspiracy to defraud at the District Court.Law Man-fai, 50, self-employed financial consultant, pleaded guilty to three counts of conspiracy to defraud, contrary to the Common Law. Another similar charge against him was left on file at the District Court. Deputy Judge Ms May Chung Ming-sun adjourned the case to July 15 for mention. Law was granted bail.Two co-defendants, Woo Man-ho, 36; and Chan Tak-ching, 37, both former relationship managers of Standard Chartered Bank (Hong Kong) Limited (Standard Chartered Bank), earlier pleaded guilty to a total of four counts of conspiracy to defraud. They were granted bail until August 22 for sentence.The court heard that at the material time, Law was a self-employed financial consultant, while Woo and Chan were relationship managers of Standard Chartered Bank respectively working at its business banking department and priority banking department. The bank would issue documents to confirm the balance of a client’s account held with the bank upon request, but Woo and Chan were not authorised to sign and issue those documents.Between January 2015 and September 2016, Law, Woo and Chan had conspired with another then relationship manager of Standard Chartered Bank and four foreign nationals to defraud various Japanese investors to invest in ADF Capital Limited (ADF) and a number of companies by using false proof of fund letters and corporate refund promissory notes (CRPNs) signed by Woo and Chan, and purportedly issued by Standard Chartered Bank.The four foreign nationals involved were two shareholders-cum-directors of ADF, respectively a Zambian man and a Korean man; a Thai man who was Chan’s client; and a Japanese woman who was the chief executive officer of a company.Law admitted that he had conspired with Woo, Chan and three of the foreign nationals to falsely represent that Standard Chartered Bank was the guarantor of ADF which undertook to pay the relevant investors by issuing eight false CRPNs.Four of the CRPNs involved promised returns totalling US$7.2 million (over HK$56 million). As a result of the false representations, various Japanese investors were deceived into making investments totalling at least JPY400 million (about HK$28.4 million) to ADF and various companies involved in this case. The remaining four CRPNs involved false representations to a certain company that Standard Chartered Bank was the guarantor of ADF which undertook to pay US$50 million (over HK$390 million) for the CRPNs.Woo and Chan earlier admitted their involvements in the scam, and their issuance of false proof of fund letters which falsely represented that the Zambian man’s company had funds of US$1.5 billion (about HK$11.6 billion) available for investments in Africa, and that the Thai man had asset of 3.3 billion euros (about HK$25.5 billion) in the bank account held with Standard Chartered Bank.The ICAC enquiries revealed that Standard Chartered Bank had never held the abovementioned asset on behalf of the Thai man, while the Zambian man’s company had never held any bank account with the bank.Co-defendant Leung Ho-yin, 38, former relationship manager of Standard Chartered Bank, pleaded not guilty to two counts of conspiracy to defraud. Another co-defendant Catherine Kum Kit-ching, 55, manager of ADF, pleaded not guilty to one count of conspiracy to launder crime proceeds. The duo will appear again at the District Court on July 11 for mention.Standard Chartered Bank had rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Wong Hay-yiu, assisted by ICAC officer Janice Chan. 04
Jul 2024Funeral agent charged by ICAC guilty of bribery over servicesA funeral agent, earlier charged by the ICAC, was today (July 4) convicted at the Kowloon City Magistrates’ Courts of offering a bribe of $3,000 to a fellow church member of a deceased elderly person for securing the business of the latter’s after-death arrangements.Chak Kwok-hung, 43, sales agent of Endless Love Care Service Company Limited (Endless Love), was found guilty of one count of offering an advantage to an agent, contrary to section 9(2)(a) of the Prevention of Bribery Ordinance.In convicting the defendant, Deputy Magistrate Mr Jeffrey Lai said that Chak’s intention to commit the offence was obvious and he regarded such illegal behaviour as a “common practice” in his trade. He ordered the defendant to be remanded in the custody of the Correctional Services Department, and adjourned the case to July 18 for sentence, pending the defendant’s background report and mitigation.The court heard that on March 6, 2023, an elderly person residing in a private residential care home passed away. Prior to his death, the elderly person had given several ten thousand dollars to two fellow church members and entrusted them to take care of his funeral arrangements. Upon learning that unbeknownst to them, Endless Love had taken up the funeral arrangements of the deceased on the same day of his passing, one of the church members visited Endless Love to make enquiries.When receiving the church member at Endless Love, the defendant offered $3,000 as a rebate to the latter for appointing Endless Love to arrange the funeral services for the deceased. The church member rejected the defendant’s offer and left.The prosecution was today represented by prosecuting counsel Eddie Sean, assisted by ICAC officer Allan Fong. 25
Jun 2024Immigration consultant conspiring with client over HK$10m investment entrant fraud charged by ICACA former proprietor of an immigration consultancy was charged by the ICAC today (June 25) for allegedly conspiring with others to deceive the Immigration Department (ImmD) into granting the investment entrant application of a client by assisting the latter to make a false representation about his investment of HK$10 million in Hong Kong.Tam Chi-ming, 50, former sole director-cum-shareholder of Wealth Concepts Consultancy (Greater China) Limited (Wealth Concepts), faces one count of conspiracy to defraud, contrary to the Common Law. He was released on ICAC bail, pending his appearance at the Kowloon City Magistrates’ Courts on Thursday (June 27) for mention.In 2003, the Hong Kong Government implemented the Capital Investment Entrant Scheme (the Scheme) to facilitate the entry for residence by capital investment entrants. The ImmD was responsible for processing the relevant applications. An applicant to be granted a permission to stay in Hong Kong for two years must have net assets of a market value not less than HK$10 million throughout the two years preceding the application; and remain invested not less than HK$10 million in specific permissible investment asset classes within six months after the granting of approval-in-principle by the ImmD (the remain-invested requirement). Applicants may apply for permanent residency of Hong Kong or unconditional stay in Hong Kong respectively upon continuous ordinary residence of or investment in Hong Kong for not less than seven years.Applicants were prohibited from borrowing money for holding specified financial assets. In accordance with the remain-invested requirement, applicants were also not allowed to assign any interest in favour of others in the financial assets concerned. The Scheme was suspended in 2015.At the material time, the defendant was the sole director-cum-shareholder of Wealth Concepts, which provided consultancy services to individuals for immigration to Hong Kong. In 2015, an applicant of the Scheme engaged Wealth Concepts to handle his application.Between May 2018 and September 2023, the defendant allegedly conspired together with the applicant and others to defraud the ImmD, inducing the ImmD to grant the applicant’s application for immigration to Hong Kong and the subsequent extensions of stay in Hong Kong.It is alleged that they dishonestly submitted a false application purporting to show that the applicant had met the investment requirement and falsely represented that the applicant had invested a total sum of HK$10 million in the bonds issued by a listed company in Hong Kong and remained the absolute beneficial owner of the investment.The ICAC investigation arose from a corruption complaint. Enquiries revealed that the applicant did not have sufficient funds for meeting the relevant requirements on investment.Had the ImmD known that the applicant had made a falsely declaration on his investment, no approval under the Scheme, as well as the subsequent extensions of stay in Hong Kong, would have been granted to the applicant and his dependants.The ICAC corruption inquiries are ongoing.The ImmD has rendered full assistance to the ICAC during its investigation into the case.The ICAC has kept reviewing various investment entrant and talent admission schemes with the relevant government departments so as to strengthen regulating the schemes to stamp out malpractices. 20
Jun 2024Ex-manager of telecom company charged by ICAC gets 40 months’ jail for HK$16m fraud by concealing mother’s role in supplierA former manager of a telecommunications company, charged by the ICAC, was today (June 20) sentenced to 40 months’ imprisonment at the Court of First Instance of the High Court for deceiving the company into issuing purchase orders worth totalling over HK$30 million and making service payments totalling over HK$16 million to a supplier owned by his mother by concealing his conflict of interest.Cheung Cheuk-man, 46, former manager of PCCW Services Limited (PCCW Services), a subsidiary of PCCW Limited (PCCW), yesterday (June 19) pleaded guilty to one count of fraud, contrary to section 16A(1) of the Theft Ordinance.In sentencing, Ms Justice Esther Toh Lye-ping reprimanded the defendant for committing a premeditated crime which constituted a breach of trust. She took a starting point of five to six years’ imprisonment and reduced the jail term to 40 months, having considered the defendant’s guilty plea, full restitution of the service payments involved in the present case to his former employer and other mitigating factors.The court heard that in November 2014, the defendant was employed by PCCW Services to work as a manager of the network service team of PCCW Solutions Limited (PCCW Solutions), another subsidiary of PCCW, which provided a wide range of information technology and network solutions to its clients. PCCW’s policy stipulated that its employees and subsidiaries must make declarations where potential conflicts of interest arose.Upon the defendant’s recommendation, Go Go Wifi Limited (GGWL) was included in the list of approved suppliers of PCCW and its subsidiaries since January 2016. Between January 2016 and July 2017, the defendant procured PCCW Solutions to issue 29 purchase orders in the sum of over HK$30 million to GGWL, which subsequently received payments of about HK$8.7 million and about US$990,000 from PCCW Solutions.The ICAC investigation arose from a corruption complaint. Enquiries revealed that the defendant’s mother had become the sole director cum shareholder of GGWL since August 2014, but he had never disclosed to his employer his mother’s interests in GGWL.The defendant was responsible for obtaining quotations and confirming receipt of services before release of payments to GGWL for the 29 purchase orders. ICAC enquiries revealed that the defendant had used false quotations purportedly issued by other companies to procure awarding the contracts to GGWL by making it the lowest bidder. On various occasions, the defendant had confirmed to PCCW Solutions in writing that he had no conflict of interest in the purchases concerned.It was also revealed in the ICAC investigation that GGWL had never provided any service in relation to the 29 purchase orders. The services concerned were either provided by other service suppliers or carried out internally by PCCW Solutions.The prosecution earlier withdrew a charge of “money-laundering” against the defendant’s mother, Lee Po-mei, 67.PCCW and its subsidiaries had rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by Senior Public Prosecutor Audrey Parwani, assisted by ICAC officer Wilson Lam.The ICAC encourages public and private organisations to establish clear guidelines and systems of declaration on conflict of interest. Staff should avoid conflict of interest and make declarations in strict adherence to internal guidelines. Concealing any conflict of interest in relation to one’s official duties to benefit himself or his associates may contravene the criminal law, such as the Prevention of Bribery Ordinance if offering or accepting of bribes is involved.