Hui was the responsible officer and senior management officer responsible. He was also one of the people responsible for ensuring that the third-party fund transfers were in compliance with anti-money laundering rules.

The SFC found that Guoyuan’s breaches were partly attributable to Hui’s failure to discharge his duties to ensure that all reasonable measures were taken to mitigate the risks of money laundering and terrorist financing. In particular, Hui failed to ensure that:

• Guoyuan conducted proper enquiries and followed up on some of the third party fund transfers despite the presence of a number of red flags suggesting that they were unusual and/or potentially suspicious; and
• Guoyuan’s procedures for dealing with the transfers were effective.

The SFC took Hui’s otherwise clean disciplinary record into account.