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September 19, 2025Public Organization Review2 citationsOpen Access

Stable or Vulnerable? Demystifying an Enigma Facing Hong Kong’s Anti-Money Laundering Efforts

RTRaymond L. M. TangUniversity of Hong Kong BWBo WenUniversity of Michigan PYPaul YipSouthwestern University of Finance and Economics

Key Points

Hong Kong's compliance with AML/CFT standards is rated high at 70 out of 100, yet enforcement gaps persist.
Study examines compliance challenges and enforcement limitations across 194 jurisdictions with FATF data from 2019-2023.
Benchmarking against global standards reveals inconsistencies in monitoring the non-financial sector and prosecution processes.
Findings underscore the need for enhanced governance and more effective regulatory frameworks in financial centres.

Abstract

Abstract This study assesses Hong Kong’s anti-money laundering and counter-terrorist financing (AML/CFT) regime by examining regulatory compliance, prosecution results, supervision of the non-financial sector, and alignment with Financial Action Task Force (FATF) standards. Analysis of 194 jurisdictions with FATF evaluation data (2019–2023) indicates Hong Kong’s technical compliance is high (70/100), but enforcement gaps remain, including limited cross-border prosecutions and inconsistent supervision of the non-financial sector. This study benchmarks AML/CFT measures, underscores the compliance challenges faced by jurisdictions and financial centres, and situates Hong Kong’s issues within the context of global governance using institutional and regulatory theories.

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