The Securities and Futures Commission (SFC) has prohibited Ms Wong Lai Suen, a former responsible officer (RO) and executive director of MTF Securities Limited (MTF), from re-entering the industry for six months from 4 June 2025 to 3 December 2025 for failing to properly manage credit risks and to identify and report suspicious trading patterns of clients (Notes 1 to 3).

The SFC’s investigation found that shortly after three cash clients had opened their accounts and deposited only $10,000 with MTF in January 2021, MTF granted each of them a trading limit ranging from $4 million to $5 million despite no application was received from the clients (Note 4).

The trading limits were granted at the request of MTF’s substantial shareholder. No proper due diligence was done on those clients’ financial status and in one case, the trading limits granted to the client was 10 times his declared annual income.

Soon after the trading limits were granted, the three clients utilised the limits to conduct transactions which were not commensurate with the financial situations of two of them. The transactions also demonstrated suspicious features which should arouse reasonable suspicion of potential market misconduct and money laundering.

However, MTF failed to identify such transactions as suspicious, follow up on them or ensure that they were reported to both the Joint Financial Intelligence Unit and the SFC in a timely manner.

The SFC is of the view that MTF failed to maintain effective policies and procedures to ensure the proper management of credit risks and an effective ongoing monitoring system to identify, examine and report suspicious trading patterns, in breach of the Code of Conduct as well as other regulatory requirements on risk management and anti-money laundering and counter-financing of terrorism (Notes 5 and 6).

The SFC considers that MTF’s failures were attributable to Wong’s failure to discharge her duties as an RO and a member of the senior management of MTF at the material time.

The SFC’s Executive Director of Enforcement, Mr Christopher Wilson, said, “Senior management of a licensed corporation must not blindly follow marching orders from the firm’s shareholders or controllers. When faced with an unusual or suspicious request, the ROs should exercise independent judgment and, where appropriate, conduct proper due diligence before acting on the request.”

“It is the duty of ROs and senior management of a licensed corporation to ensure that effective policies and controls are in place to prevent the firm from being used to facilitate wrongdoing including market misconduct and money laundering,” Mr Wilson added.

In deciding the disciplinary sanction against Wong, the SFC has taken into account that:

• MTF’s failures are serious as they could undermine public confidence in, and damage the integrity of, the market;
• a deterrent message needs to be sent to the market that such failures are not acceptable;
• Wong was forthcoming about her shortcomings in the assessment of suspicious transactions during the SFC’s investigation; and
• Wong has an otherwise clean disciplinary record.

Notes:

1. Wong was accredited to MTF and approved to act as its RO for Type 1 (dealing in securities) regulated activity from 2 November 2016 to 20 April 2021. Wong is currently not licensed by the SFC.
2. Wong was also MTF’s manager-in-charge of (i) overall management oversight; (ii) operational control and review; (iii) finance and accounting; and (iv) information technology at different intervals.
3. MTF was licensed to carry on (among others) Type 1 (dealing in securities) regulated activity under the Securities and Futures Ordinance between 19 November 2004 and 14 June 2023.
4. A trading limit was the gross accumulated unsettled amount that MTF granted to, and expected to be settled by, an individual client on two trading days after the date of the transaction.
5. Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission.
6. Please refer to the Statement of Disciplinary Action for the relevant regulatory requirements.