Skip to content

Swiss Chinese Law Association — Geneva

SCLA | Swiss Chinese Law Association

Legal Observatory / Finance and Payments

Legal Update China Hong Kong SAR Rules in force

Hong Kong Customs Investigates Unregistered High-Value Cash Transaction Under AML/CTF Ordinance

Hong Kong Customs detected an unregistered local company conducting cash transactions for luxury watches exceeding HK$120,000 without required Category B registration.

What Changed

  • Hong Kong Customs detected an ongoing case involving a local company executing high-value cash watch transactions without Category B registration.
  • Under Cap. 615, dealing in precious metals and stones with transactions at or above HK$120,000 requires registration, with cash transactions restricted to Category B registrants.
  • Violations carry criminal penalties upon conviction, including a fine up to HK$100,000 and six months imprisonment.

Hong Kong Customs detected an enforcement case on October 22, 2026, involving a local company that conducted cash transactions for watches containing precious metals and stones valued at over HK$120,000 without holding a Category B registration. The case arises under the Dealers in Precious Metals and Stones Regulatory Regime, enforced pursuant to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) in Hong Kong SAR. The investigation into the company remains ongoing.

Under Cap. 615, unless exempted, any entity or individual seeking to carry on a business of dealing in precious metals and stones and engage in any transaction—whether making or receiving a payment—with a total value at or above HK$120,000 in Hong Kong SAR is required to register with Hong Kong Customs. Specifically, no person other than a Category B registrant is permitted to conduct cash transactions with a total value at or above HK$120,000 in the course of dealing in precious metals and stones.

Hong Kong Customs emphasized that any dealer who carries out, claims to carry out, or purports to be authorized to carry out cash transactions at or above the HK$120,000 threshold without Category B registration commits a criminal offence. Upon conviction, offenders face a maximum statutory fine of HK$100,000 and imprisonment for up to six months. Customs reminded all industry participants that they must obtain the appropriate registration prior to executing any cash or non-cash transactions reaching or exceeding HK$120,000.

Entities and individuals dealing in high-value goods, luxury watches, precious metals, and stones in or through Hong Kong SAR must ensure strict regulatory compliance with registration requirements before accepting or executing high-value cash payments. Customs provides application forms, guidelines, and procedures online via the Dealers in Precious Metals and Stones Registration System (www.drs.customs.gov.hk) and its official website. Suspected unregistered transactions of HK$120,000 or more can be reported via Customs' dedicated hotline, email, or online reporting form.

Who May Be Affected

Dealers, retailers, traders, and businesses in Hong Kong SAR engaging in cash or non-cash transactions involving precious metals, stones, and luxury watches valued at or above HK$120,000.

Cross-Border Context

Cross-border traders and businesses operating in or transacting through Hong Kong SAR must comply with local AML/CTF registration requirements before conducting high-value transactions involving precious metals or stones.

What to check next

  • Check registration requirements on the Dealers in Precious Metals and Stones Registration System website (www.drs.customs.gov.hk)
  • Review AML/CTF compliance guidelines on Hong Kong Customs' official website

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

Keep the issues that matter to you in view

Subscribe to SCLA updates and choose your interests.