Anti-Corruption 2025

HONG KONG Trends and Developments Contributed by: Gareth Hughes, Emily Lam, Philip Rohlik and Tiffany Wu, Debevoise & Plimpton LLP

Operation Demarcation is testimony to the grow - ing collaboration between anti-corruption agen - cies. Following its completion, the ICAC deputy commissioner explained that “the joint operation fully demonstrates the close collaboration and determination of the two cities’ law enforcement agencies in tackling cross-boundary corruption and other crimes”, while the SFC executive director remarked that “the SFC will continue to work closely with the ICAC and other local and extraterritorial law enforcement agencies to maintain market integrity”. Joint operations between the ICAC and the Competition Commission The ICAC and theCompetition Commission (CC) conducted their first joint operation on 16 and 17 April 2024, which neutralised a syndicate engag - ing in corruption and tender-rigging in relation to building maintenance. This operation was fol - lowed later in the year by another joint operation code-named “Shotgun”, which took place on 21 and 22 August 2024. In the first operation, the companies and individ - uals concerned were alleged to have engaged in corruption and anti-competitive activities, contravening the Prevention of Bribery Ordi - nance (POBO) and the First Conduct Rule of the Competition Ordinance. The ICAC arrested 20 individuals, including the mastermind and lead - ership members of the syndicate. Critically, the investigations arose from a corruption complaint in relation to building maintenance lodged with the ICAC by members of the public. The ICAC frequently stresses the importance of whistle- blowing and public engagement in anti-corrup - tion; this investigation shows precisely why such actions are so valuable. Operation “Shotgun”, meanwhile, concerned two separate but parallel investigations by the

ICAC and the CC. The ICAC investigation tar - geted the renovation projects of two residen - tial estates in Hong Kong Island in which cor - ruption was suspected. At the same time, the investigation conducted by the CC concerned the renovation projects of 38 residential estates and buildings, and industrial buildings in Hong Kong Island, Kowloon and the New Territories. Both investigations are ongoing and are, once again, illustrative of the growing shift toward a collaborative approach amongst anti-corruption agencies in Hong Kong. “Rocket Gun” and “Beacon Tower” The ICAC apprehended a total of 148 individuals suspected of obtaining fraudulent work-related professional qualifications in two recent signifi - cant law enforcement operations code-named “Rocket Gun” and “Beacon Tower”. These arrests stemmed from allegations of falsify - ing employment documents and engaging in corrupt practices. The individuals arrested are accused of deceiving recognised training course providers (TCPs) associated with the Labour Department (LD) to acquire professional certifi - cates for excavation work and misrepresenting their qualifications to the Electrical and Mechani - cal Services Department (EMSD) for electrical worker registrations. Operation Rocket Gun: allegations of bribery and forgery in excavator certifications Operation Rocket Gun resulted in the arrest of 111 individuals, including the ringleader, employ - ees and owners of five engineering firms, staff from two TCPs and approximately 100 construc - tion workers. ICAC officers executed search warrants at various locations and confiscated suspected falsified employment documents and other incriminating evidence.

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