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Swiss Chinese Law Association — Geneva

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Legal Observatory / Finance and Payments

Legal Update China Hong Kong SAR Rules in force

Hong Kong Customs Detects Unregistered Cash Transactions by Precious Metals and Stones Dealer

Hong Kong Customs detected an unregistered dealer conducting cash transactions for precious metal and stone watches exceeding HK$120,000.

What Changed

  • Hong Kong Customs detected an illicit high-value cash transaction of watches containing precious metals and stones on October 8, 2026.
  • Conducting cash transactions at or above HK$120,000 without Category B registration breaches the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
  • Offenders face criminal liability with statutory penalties of up to a HK$100,000 fine and six months imprisonment.

Hong Kong Customs has detected a case involving a local company conducting cash transactions for watches containing precious metals and stones valued at over HK$120,000 without holding a Category B registration. The enforcement action occurred on October 8, 2026, and an investigation remains ongoing.

Under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), any person seeking to carry on a business of dealing in precious metals and stones and engage in any transaction (making or receiving payment) with a total value at or above HK$120,000 in Hong Kong must register with Hong Kong Customs.

The regulatory regime establishes strict requirements for high-value cash transactions. Namely, no person other than a Category B registrant is permitted to carry out a cash transaction with a total value equal to or exceeding HK$120,000 in the course of dealing in precious metals and stones. Any dealer who is not a Category B registrant and carries out, purports to carry out, or claims to be authorized to carry out such cash transactions commits a statutory offence. Upon conviction, offenders are liable to a maximum fine of HK$100,000 and imprisonment for up to six months.

Hong Kong Customs reminded dealers operating in precious metals and stones that they are required to obtain the appropriate registration prior to executing cash or non-cash transactions at or above the HK$120,000 threshold. Guidance materials, registration forms, and procedural instructions are accessible through the Dealers in Precious Metals and Stones Registration System (www.drs.customs.gov.hk) or the official Hong Kong Customs portal.

Customs also encouraged members of the public to report any suspected non-compliant transactions involving precious metals and stones valued at or above HK$120,000 conducted without registration using the 24-hour hotline (182 8080), dedicated crime-reporting email address ([email protected]), or online reporting portal.

Who May Be Affected

Dealers in precious metals and stones, luxury goods retailers, and companies carrying out high-value cash transactions in Hong Kong SAR.

Cross-Border Context

Cross-border trading entities and businesses operating in or dealing with Hong Kong SAR must ensure proper regulatory registration before completing cash transactions of HK$120,000 or above.

What to check next

  • Dealers in Precious Metals and Stones Registration System website (www.drs.customs.gov.hk)
  • Hong Kong Customs Anti-Money Laundering supervision webpage

This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.

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