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Peter was a branch manager of a bank and a regular customer of a famous nightclub. Because of his extravagant lifestyle, he soon found himself running into financial difficulty. Peter became acquainted with Andy, the nightclub supervisor, who, one day, invited Peter to join him for a drink.


Whilst enjoying their drinks, Andy introduced Peter to another friend, Joe. It transpired that Joe was a money launderer from overseas who was planning to set up his operations in Hong Kong. As Joe was unfamiliar with the local controls over money laundering activities, he asked if Peter could provide him with information relating to his bank's anti-money laundering measures and update him on new procedures from time to time.


Peter, who was in difficult financial situation at the moment, asked Joe for $300,000 as a reward for his assistance. To avoid the detection from the bank, Joe laundered his dirty money through numerous asset management accounts in Peter's branch and Peter helped by turning a blind eye to these activities.

Case Analysis

Peter might breach the Organized and Serious Crimes Ordinance or the Drug Trafficking (Recovery of Proceeds) Ordinance as well as the Anti-Money Laundering and Counter-Terrorist Financing Ordinance. 


Peter also commits a corruption offence under Section 9 of the Prevention of Bribery Ordinance (POBO) for soliciting from Joe an advantage as a reward for leaking confidential information from his bank. He may also violate the Code of Conduct[1] of his bank as he fails to preserve the confidentiality of the bank's internal information.




[1] According to HKMA’s Supervisory Policy Manual CG-3, each authorized institute (AI) (bank) should develop its own Code of Conduct containing certain minimum conduct requirements which include “no member of staff should, during or after termination of his employment with the AI, except in proper course of his duties or with the written consent of the AI, divulge or make use of any secrets or of any correspondence, accounts, connections or dealings of the AI or its customers or of any knowledge gained in relation thereto during his employment.”

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