Hong Kong Case Law: Decisions & Judgments

Topic

Proceeds of crime

Legal area

Court

22 Jan 2026

香港特別行政區訴趙俊名 ANTHONY

Citation

[2026] HKDC 129
Court

District Court
Case number

DCCC424/2021

The court found that the prosecution had adduced sufficient prima facie evidence (timing of cheque encashment, seizure location, defendant's admissions and absence of legitimate records) to establish on a relative likelihood that the HK$220,000 was criminal proceeds, shifting the evidential burden to the putative owner; the owner failed to give a credible, reliable explanation or corroborative evidence to rebut the inference, so the court ordered forfeiture under s102 CPRO.
22 Jan 2026

香港特別行政區訴趙俊名 ANTHONY

Citation

[2026] HKDC 129
Court

District Court
Case number

DCCC405/2021

[2026] HKDC 129
16 Dec 2025

HKSAR v. CHAU YU TUNG

Citation

[2025] HKCA 1135
Court

Court of Appeal
Case number

CACC62/2025

The one‑third enhancement under section 27 OSCO was properly applied on the basis of evidence of increasing prevalence and harm from stooge‑account money‑laundering; the sentencing judge gave detailed reasons, applied appropriate starting points, allowed a one‑third guilty plea discount and correctly applied totality, rendering the overall sentence not manifestly excessive and the leave application rightly refused.
25 Nov 2025

HKSAR v. LEUNG KA MAN

Citation

[2025] HKCA 1055
Court

Court of Appeal
Case number

CACC449/2025

Extension of time to seek leave was granted; the applicant presented a reasonably arguable ground that his post-sentence testimony warrants an increased discount within a 40–50% range; accordingly leave to appeal and bail pending appeal were granted because the arguable appeal coupled with likely substantial time served justified bail.
17 Nov 2025

HKSAR v. LEUNG CHI MING ERIC

Citation

[2025] HKDC 1972
Court

District Court
Case number

DCCC1445/2024

On the evidence the prosecution proved on the balance of probabilities that the $12,906 seized from the defendant constituted proceeds of drug trafficking within s56(1) Cap 134; the defendant's explanation was not credible and he failed to rebut the prima facie case, therefore forfeiture was properly ordered.
2 Jun 2025

HKSAR v. LUNG HON LAM AND ANOTHER

Citation

[2025] HKCA 522
Court

Court of Appeal
Case number

CACC260/2024

Leave to appeal against conviction was granted because there are reasonably arguable grounds that the judge erred in finding the underlying business to be a sham, may have misapplied HKSAR v Wong Chor Wo by treating business accounts as equivalent to lending an account, and did not sufficiently analyse the 'reasonable grounds to believe' element, rendering the convictions potentially unsafe.
24 Apr 2025

HKSAR v. LUNG HON LAM

Citation

[2025] HKCA 362
Court

Court of Appeal
Case number

CACC260/2024

Bail pending appeal was refused because, although there were arguable points about whether the trial judge correctly applied Wong Chor Wo and whether the evidence supported the finding that the applicant entered the alleged conspiracy or that UGTL was a sham absent proof of a predicate offence, those issues required fuller consideration on appeal; the court directed the applicant's leave application be expedited.
7 May 2024

香港特別行政區訴詹培忠及另二人

Citation

[2024] HKDC 1411
Court

District Court
Case number

DCCC439/2022

The application to stay was dismissed because the court found no evidence of deliberate or planned prosecutorial delay or abuse of process; the lengthy investigation was ongoing and involved complexity justifying time taken; alleged witness loss or memory deterioration was not proven to cause prejudice; and a stay is a remedy of last resort.
13 Sept 2023

香港特別行政區訴李兆平

Citation

[2023] HKDC 1280
Court

District Court
Case number

DCCC221/2021

Court held on the balance of probabilities that the defendant had benefitted from the specified offences; assessed the value of the benefit at HKD12,324,514 (after deducting returned amount) and determined the defendant's realisable property at the time of the order to be HKD1,577,222.64 (bank accounts 1–5 plus withdrawn bail money). Accordingly a confiscation order for HKD1,577,222.64 under OSCO was made with a six-month payment period and default imprisonment of two years four months to be served concurrently with the existing 48‑month sentence.
11 May 2023

HKSAR v. HA BUT-YEE

Citation

[2023] HKCFI 1208
Court

Court of First Instance
Case number

HCCC319/2016

The court found on the balance of probabilities that D2’s receipts and trading gains arose from a continuous course of criminal conduct involving general assistance and information from D1 across 356 calls; those receipts fell within s2(6) OSCO as payments in connection with the offence, certifying proceeds at HK$125,664,254.30 and ordering confiscation of the agreed realisable assets HK$63,000,000 with specified payment and default sanctions.