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The recording of our webinar “Insider Dealing Under Hong Kong Law” is now available on YouTube.
In this session, we examined Hong Kong’s insider dealing regime under Parts XIII and XIV of the Securities and Futures Ordinance (SFO). The discussion covered the seven circumstances that constitute insider dealing, the definitions of “securities”, “listed securities”, “connected persons”, “related corporations” and “inside information”, and the key elements of the offences (including the requirements that information be specific, not generally known, and likely to have a material effect on price).
We also reviewed the principal defences (including the Chinese walls defence, the innocent purpose defence, the market information defence and the off-market dealing defence), the civil and criminal consequences of insider dealing, the powers and procedures of the Market Misconduct Tribunal, criminal penalties, private rights of action, officers’ duties, and the SFC’s use of section 213 restoration orders. Key cases discussed included Young Bik Fung, Yiu Hoi Ying Charles, Cheng Chak Ngok, Tiger Asia, Du Jun and the recent Dickson Concepts matter.
The session further addressed the SFC’s 2023 proposals (still not implemented) to expand the territorial scope of the insider dealing regime to cover overseas-listed securities and conduct outside Hong Kong, together with an overview of the SFC’s Market Sounding Guidelines that took effect in May 2025.
The session is intended for listed issuers, sponsors, legal advisers, directors, INEDs, company secretaries and compliance professionals who need a practical working knowledge of Hong Kong’s insider dealing framework and its enforcement.