Hong Kong — Country Risk Report

Hong Kong (Asia Pacific • East Asia). Risk report as of the 19 Jun 2026 FATF plenary.

Moderate country risk, with AML/CFT effectiveness gaps. Hong Kong's country risk score is 3.6/10, placing it in the moderate-risk band. The principal score driver is AML/CFT effectiveness, contributing 2.2 of 3.6 points. Separately, the treatment overlays show that Hong Kong is not currently FATF grey- or black-listed, and that Hong Kong has a sectoral sanctions programme. Firms should apply additional scrutiny where exposure involves state-linked entities, restricted sectors, sensitive technology, dual-use goods or politically exposed counterparties.

Recommended treatment

Enhanced due diligence on every relationship, with senior approval and enhanced ongoing monitoring.

At a glance

  • FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
  • Sectoral country-level sanctions programme identified; this is a legal treatment overlay and does not change the numeric country-risk score.
  • Governance and institutions: 2.6/10
  • Corruption (CPI 2025): 76/100, rank #12 of 182
  • Enforcement: 2 live regulator feeds; current totals are loaded from the live evidence API

Country Risk Score: 3.6/10 (Moderate)

Higher score means higher country risk (global average 5.5). Full information available. Composite score. Some evidence is older. Enforcement activity and CPI are context only; FATF listing and sanctions are regulatory overlays except the labelled FATF listing status used where no mutual evaluation exists.

All three underlying risk pillars are available. All three underlying risk pillars are available and weighted using the published formula. Weight sensitivity 3.5–3.7/10.

How this score was calculated

  • AML/CFT effectiveness: 4.8/10 — 45% of this score
  • Technical compliance: 2.7/10 — 20% of this score
  • Governance and institutions: 2.6/10 — 35% of this score

Sanctions treatment: Screen transactions and counterparties. FATF treatment: none.

Show the exact calculation

effectiveness 4.8 × 45% + safeguards 2.7 × 20% + governance 2.6 × 35% = 3.6; sanctions and FATF listing are overlays except a labelled FATF listing substitute where no mutual evaluation exists

Principal risk drivers

  • AML/CFT effectiveness: 4.8/10 × 45% = 2.2 points
  • Governance and institutions: 2.6/10 × 35% = 0.9 points
  • Technical compliance: 2.7/10 × 20% = 0.5 points

Mitigating factors

  • Not currently on the FATF grey or black list.
  • No comprehensive country-wide sanctions programme.
  • Comparatively stronger corruption (2.0/10).
  • Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

  • Customer onboarding (Enhanced): Verify ultimate beneficial ownership and control from more than one source.
  • Payments and transactions (Enhanced): Review transaction purpose, counterparties and the full payment routing.
  • Trade and export activity (Enhanced): Screen goods, end users and potential dual-use exposure.
  • Corporate clients (Standard): Assess state ownership, government links and political exposure.
  • Ongoing monitoring (Elevated): Alert on ownership changes, new designations and status changes.

Recommended controls

  • Verify ultimate beneficial ownership using more than one reliable source.
  • Identify state ownership, government influence and politically exposed persons.
  • Screen entities, directors and beneficial owners against applicable sanctions lists.
  • Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
  • Document transaction purpose and source of funds where cross-border structures are complex.
  • Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

  • State ownership / control
  • PEP involvement
  • Sensitive / restricted sectors
  • Opaque ownership
  • Adverse media
  • Dual-use goods & technology
  • High-risk intermediary routing

FATF status: Not currently listed

Hong Kong is not on the FATF grey or black list as of the 19 Jun 2026 plenary.

Sanctions: Sectoral

  • OFAC — targeted: Hong Kong-Related Sanctions (source)
  • UK — sectoral: UK arms embargo on mainland China and Hong Kong (source)

Source details

International sanctions by issuing body

  • UN: No
  • EU: No
  • UK: Yes (Sectoral)
  • US: Yes (Targeted)

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

  • Government Effectiveness: 83/100
  • Regulatory Quality: 82/100
  • Rule of Law: 73/100

Enforcement activity

RegActions has 2 live regulator feeds mapped to Hong Kong. Current action totals are loaded from the live evidence API rather than the static registry.

The composite RegActions Country Risk Score does not use enforcement volume.

Regulators and legal framework

FATF network

FATF member.

Last mutual evaluation: 2019 · report

National regulators

FIU: Egmont Group member (JFIU)

Framework signals

  • FATF listing: Not currently listed
  • International sanctions: sectoral country programme (legal treatment overlay)
  • Corruption (CPI 2025): 76/100, rank #12 of 182
  • Rule of law (WGI): 2.1/10 risk

Regulatory ecosystem and enforcement visibility

This evidence map is separate from Country Risk v3. It describes official mandates, publication access and RegActions coverage; it does not judge regulatory strength or add points to country risk.

Transparency Index: not scored · Evidence disposition: local-authority-evidence · Mapped official authorities: 5.

Evidence level: Level 3: Enforcement visible. The ladder uses the authority evidenceLevel schema directly and does not infer a level from a URL, site access or RegActions feed count.

  1. 1. Identity confirmed — The authority and its mandate are evidenced by official directory provenance.
  2. 2. Regulatory activity visible — A qualified authority-owned route has provisional dated activity in the first-page scan.
  3. 3. Enforcement visible — A qualified authority-owned enforcement route has provisional dated activity in the first-page scan.
  4. 4. Score eligible — Shown only when the authority evidence schema explicitly records score-eligible; no authority currently does.
How to read activity and enforcement visibility

Only qualified authority-owned routes can support Level 2 or Level 3. External official context and unqualified candidates do not promote the evidence level. Blocked and unavailable sources remain unknown.

Enforcement visibility: 1 authorities are classified enforcement-visible by the authority evidence schema, based on qualified authority-owned route evidence and provisional first-page month observations. This is not a validated engagement frequency.

Authorities and mandate evidence

  • Hong Kong Monetary Authority — Level 3: Enforcement visible · Official site reachable

    Mandates: Central bank, Prudential supervision · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

    Official authority site

    Provisional first-page scan signal

    Signal: low-frequency · Observed month count: 1 · Latest observed month: 2024-10.

    Provisional automated first-page date scan on an authority-owned qualified route. It is not a validated publication frequency or effectiveness measure.

    Scan contract and precision

    automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

    Publication candidates and qualification

    • Official authority-owned enforcement route: Banking Conduct and Enforcement

      Authority-owned and approved for the human-reviewed route contract.

      Route type: enforcement_archive · Source scope: authority-owned · Qualification: approved-for-human-contract · Provisional scan signal: low-frequency-first-page-signal · Observed months: 1 · Latest observed month: 2024-10

    • Unqualified publication candidate: Opening Remarks at FiNETech8 on “Navigating Quantum Duality”by Carmen Chu

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

  • Insurance Authority (IA) — Level 1: Identity confirmed · Official site challenge-protected

    Mandates: Insurance · Access status: Official site challenge-protected · Research/publication snapshot checked: 2026-08-20

    Official authority site

    Provisional first-page scan signal

    Signal: unknown · Observed month count: unknown · Latest observed month: unknown.

    Source access was limited during this research check, so activity remains unknown. This is not evidence of inactivity.

    Scan contract and precision

    automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

    No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

    Activity and enforcement visibility remain unknown; this access limitation does not establish that the authority has no enforcement activity.

  • Joint Financial Intelligence Unit (JFIU) — Level 1: Identity confirmed · Official site reachable

    Mandates: Financial intelligence · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

    Official authority site

    Provisional first-page scan signal

    Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

    No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

    Scan contract and precision

    automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

    No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

  • Mandatory Provident Fund Schemes Authority — Level 1: Identity confirmed · Official site reachable

    Mandates: Pensions · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

    Official authority site

    Provisional first-page scan signal

    Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

    No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

    Scan contract and precision

    automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

    Publication candidates and qualification

    • Unqualified publication candidate: 工作概覽

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: enforcement_archive · Source scope: authority-owned · Qualification: manual-review-required · Provisional scan signal: no-dated-first-page-signal · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 僱主

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 計劃成員

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 自僱人士

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 強積金中介人

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 強積金受託人

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 職業退休計劃僱主及管理人

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 執法統計數據

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 提防詐騙

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 執法提示

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: 版權公告

      Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

  • Securities and Futures Commission — Level 1: Identity confirmed · Official site reachable

    Mandates: Securities · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

    Official authority site

    Provisional first-page scan signal

    Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

    No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

    Scan contract and precision

    automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

    No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

Download regulatory ecosystem PDF · CSV · JSON

Sector exposure

  • Banking & payments (Low): No FATF overlay and governance pillar within normal range
  • Trade & export controls (High): Sectoral sanctions overlay restricts named trade sectors
  • Crypto & virtual assets (Low): No FATF overlay and effectiveness pillar within normal range
  • Real estate & luxury assets (High): BO subscore 6.6/10; CPI context 76/100
  • State-linked & procurement (Low): Current risk pillars show no elevated procurement signal

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

Hong Kong: analysis

Hong Kong's profile is supported by corruption risk and rule of law and institutions, both among the strongest governance readings in the Asia Pacific region. Political stability is also well controlled. Voice and accountability is the weakest domain, reflecting reduced civil liberties. The country carries no FATF listing and no sanctions apply. The 244 tracked enforcement actions by the SFC and HKMA indicate a proactive supervisory culture, which is a key mitigant within the financial sector.

Outlook

Hong Kong's risk fundamentals are strong and are supported by active regulatory enforcement. The primary watch area is the voice and accountability domain and any further evolution of the political and legal environment. Its upper-tier standing on the World Bank governance indicators and CPI ranking provide confidence in the near-term stability of the risk picture.

Key watchpoints

  • Monitor developments in the political and legal environment that may affect the voice and accountability domain.
  • Track SFC and HKMA enforcement activity for changes in supervisory intensity or thematic focus.
  • Watch for any FATF or sanctions developments that could raise the risk profile.
  • Review cross-border financial flows between Hong Kong and mainland China for emerging AML risk patterns.

Assessment currency

  • FATF status: Not listed (as of 19 Jun 2026)
  • Sanctions exposure: Sectoral programme in place (as of Jul 2026)
  • Governance (WGI): Latest dataset incorporated (as of 2024)
  • Corruption (CPI): 76/100 (as of 2025)
  • RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: none. No FATF call-for-action or increased-monitoring status was identified at the latest plenary. This does not establish low risk.

Contextual signals (not scored)

  • FATF network membership: Direct FATF member (present, as of 2026-07)
  • EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
  • Egmont Group FIU: JFIU (present, as of 2026-07-17)
  • Beneficial-ownership register: No live register identified in the source (unavailable, as of 2026-08-23)
  • Transparency International CPI: 76/100, rank 12 (present, as of 2025)

Evidence freshness

  • FATF monitored-jurisdiction status: current; data 2026-06-19
  • FATF mutual evaluation and follow-up ratings: current; data 2026-08-24; follow-up 2023-02; base assessment 2019-09
  • World Bank governance indicators: current; data 2024
  • UN, UK, EU and US sanctions regimes: current; data 2026-08-30

Contextual signals are public evidence only and do not change the current country-risk score.

Download evidence PDF · CSV · JSON

Contextual risk evidence (not scored)

These eight evidence families provide context only. They do not change the v3.1 headline score. Unavailable means no reviewed, country-comparable evidence is currently ingested; it does not mean the risk is absent.

  • Organised crime: Not available. No reviewed country-level organised-crime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
  • Fraud and cybercrime: Not available. No reviewed country-level fraud or cybercrime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
  • Terrorism and proliferation financing: Not available. No reviewed country-comparable terrorism/proliferation threat dataset is currently checked in; FATF listing status remains a separate overlay. Candidate sources are research leads only; they have not been ingested as evidence.
  • Trafficking: Not available. No reviewed country-level trafficking dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
  • Financial secrecy and offshore exposure: Not available. No reviewed, licence-clean financial-secrecy index is currently checked in; jurisdiction type alone is not used as a proxy. Candidate sources are research leads only; they have not been ingested as evidence.
  • Tax cooperation: Not listed in EU Annex I. Annex I is a political/legal tax-cooperation list, not a general AML, corruption, or country-risk score. Source
  • Political stability and conflict: 77/100 WGI percentile. WGI is an institutional perception indicator, not a conflict event feed or a prediction of future violence. Source
  • Beneficial ownership: Not available. The Open Ownership map is a live-register snapshot and absence means no register was identified in that snapshot, not that no register exists. Candidate sources are research leads only; they have not been ingested as evidence.

Regional peer scores

FAQ

Is Hong Kong on the FATF grey list?

No. Hong Kong is not on the FATF grey or black list as of the 19 Jun 2026 plenary. FATF listing is one AML indicator; absence from the list does not by itself make Hong Kong low risk. The next FATF plenary review is scheduled for Oct 2026.

Is Hong Kong subject to sanctions?

Partly. Hong Kong has sectoral sanctions exposure rather than a comprehensive country-wide programme. Sanctions are a legal overlay, not an extra country-risk score. Firms should screen applicable persons, entities and sectors against the OFAC, UK, EU and UN lists.

What is Hong Kong's country risk rating?

RegActions rates Hong Kong at 3.6/10 (Moderate risk), where a higher score means higher country risk. The v3 score combines AML/CFT effectiveness, technical compliance, and governance and institutions. FATF listing and sanctions are shown as overlays and do not add points. Transparency International's 2025 Corruption Perceptions Index scores Hong Kong 76/100 (rank #12 of 182) as context only.

What due diligence applies to Hong Kong?

Enhanced due diligence on every relationship, with senior approval and enhanced ongoing monitoring. This is decision-support based on Hong Kong's FATF status, governance and sanctions signals, and is not a substitute for a firm's own risk assessment.

How much enforcement activity is tracked for Hong Kong?

RegActions has live enforcement coverage from 2 regulators in Hong Kong. The current action total is loaded from the source-linked evidence view rather than this country-risk snapshot. Enforcement volume measures regulator activity, not country risk, so it is shown as evidence but never fed into the RegActions Country Risk Score.

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)