HONG KONG Trends and Developments Contributed by: Gareth Hughes, Emily Lam, Philip Rohlik and Tiffany Wu, Debevoise & Plimpton
ket appearance for the shares of the listed company through multiple nominee accounts. Furthermore, the former executive director of the listed company was suspected of accepting advantages from the former chairperson of the listed company and improperly misappropriating client shares with a market value of approximately HKD9 million. These acts, if proven, would represent a breach of fiduciary duties and a clear violation of Hong Kong’s anti-bribery laws. The investigation is still ongoing. The joint operation demonstrates Hong Kong’s stead - fast efforts in upholding market integrity through co- ordinated enforcement efforts. This case underscores the necessity of maintaining a secure compliance sys - tem and diligent record keeping, as well as cultivating a culture of integrity to mitigate the risk of breaching anti-corruption and market manipulation laws. The Sports Governance and Integrity Alliance Enhancing sports governance in Hong Kong has been one of the ICAC’s major initiatives. Following the publication of the Integrity and Corruption Prevention Guide for local national sports associations (NSAs) in 2024 to set key standards for good governance, the ICAC has made further efforts to enhance govern - ance standards and integrity in the sports industry by launching the Sports Governance and Integrity Alli - ance (SGIA) on 28 August 2025 jointly with the Hong Kong Jockey Club (HKJC), the Sports Federation & Olympic Committee of Hong Kong, China (SF&OC), and The Hong Kong Chartered Governance Institute (HKCGI). The establishment of the SGIA is intended to kick-start a three-year collaborative initiative aimed at raising the governance standards of local NSAs, and to position Hong Kong as a clean, fair and internation - ally competitive hub for major sporting events. Within this new initiative framework, the SF&OC will be tasked with setting standards, the HKJC will con - tribute resources, the HKCGI will enhance governance principles, and the ICAC will safeguard integrity. This will include the creation of sports programmes, the holding of a symposium on sports governance and the launching of sports governance certification courses, which are initiatives aimed at enhancing the NSA’s governance and integrity.
It is further hoped that the launch of SGIA will help raise awareness and mitigate corruption risks in the sports sector. This is particularly significant given the ICAC operation “Tenacity,” conducted in March 2025, in which the ICAC uncovered a syndicate suspected of football match-fixing and illegal gambling. A num - ber of individuals were charged for offering bribes to football players for manipulating match results and facilitating the syndicate’s illegal gambling business. Operation “Heron” On 9 May 2025, the ICAC announced the completion of Operation “Heron”. The operation targeted a syn - dicate of 16 individuals involved in selling electronic cigarettes through an online shop and bribing logis - tics company staff to store and deliver the electronic cigarettes to customers. This case highlights not only the challenges related to the enforcement of the statu - tory ban on e-cigarettes, but also the ICAC’s steadfast efforts action in tackling any forms of corruption. Electronic cigarettes have been banned in Hong Kong since April 2022. Following the ban, the logistics com - pany involved amended its policy and declined to accept any delivery requests for electronic cigarettes. Staff were also required to inspect parcels received from customers. Despite these measures, the syndi - cate bribed staff at the logistics company into circum - venting the policy and successfully delivered about 200 parcels of electronic cigarettes each day. Staff accepted bribes of up to HKD20 per parcel, totalling approximately HKD370,000. The individuals arrested included the mastermind, his wife and parents, as well as three additional associ - ates who assisted in the operation of the illegal online business. Nine other staff members of the logistics company, including a branch supervisor and frontline station staff, were believed to have facilitated the dis - tribution of the illicit goods. In the course of the execution of the search warrants, the ICAC raided multiple locations, including private residences, two business stations of the logistics com - pany, and a warehouse operated by the syndicate. From the warehouse, investigators seized 200,000 vaping products with a market value of HKD20 mil - lion – the largest single seizure recorded since the
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