Hong Kong — Country Risk Report

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

High country risk, with governance and transparency concerns. Hong Kong's country risk score is 6.0/10, placing it in the high-risk band. The principal driver is weak voice and accountability. Hong Kong is not currently FATF grey- or black-listed. Hong Kong is not subject to comprehensive country-wide sanctions. 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.

At a glance

  • FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
  • Comprehensive country sanctions: none identified. Targeted sanctions exposure: programmes in place, screen applicable lists
  • Government effectiveness and rule of law: 2.6/10
  • Corruption (CPI 2025): 76/100, rank #12 of 182
  • Enforcement: 244 actions from 2 regulators

Country Risk Score: 6.0/10 (High)

Higher score means higher country risk (global average 4.6). Full information available. Some evidence is older. Enforcement activity and CPI are shown for context but do not change the score.

All three parts of the score are available.

How this score was calculated

  • Financial crime controls: 4.2/10 — 50% of this score
  • Government effectiveness and rule of law: 2.6/10 — 30% of this score
  • International sanctions: 5.4/10 — 20% of this score
  • The FATF assessment is more than five years old.
  • sector-wide international sanctions means the score cannot be lower than 6.0. This minimum set the final score.
Show the exact calculation

aml 4.2 × 50% + governance 2.6 × 30% + sanctions 5.4 × 20% = 4; sanctions-sectoral floor 6 applied; final 6

Principal risk drivers

  • Sectoral sanctions exposure

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 (High): Additional ownership and control verification may be required.
  • Payments and transactions (High): Review transaction purpose, counterparties and geographic routing.
  • Trade and export activity (High): Screen goods, end users and potential dual-use exposure.
  • Corporate clients (High): Assess state ownership, government links and political exposure.
  • Ongoing monitoring (High): Apply alerts for ownership changes, sanctions and geopolitical developments.

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 tracks 244 enforcement actions from 2 regulators in Hong Kong.

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 exposure
  • Corruption (CPI 2025): 76/100, rank #12 of 182
  • Rule of law (WGI): 2.1/10 risk

Sector exposure

  • Banking & payments (Low): No FATF listing, rule-of-law governance within normal range
  • Trade & export controls (High): Sectoral sanctions: UK arms embargo on mainland China and Hong Kong
  • Crypto & virtual assets (Low): No FATF listing, accountability governance within normal range
  • Real estate & luxury assets (Low): Corruption indicators within normal range for high-value assets
  • State-linked & procurement (Low): Political-stability and corruption governance within normal range

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: Targeted programmes 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 2026-07-17)
  • 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 2026-07-31; follow-up 2023-02; base assessment 2019-09
  • World Bank governance indicators: current; data 2024
  • UN, UK, EU and US sanctions regimes: current; data 2026-08-13

Contextual signals are public evidence only and do not change the immutable v2 score.

Download evidence PDF · CSV · JSON

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. 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 6.0/10 (High risk), where a higher score means higher country risk. The score combines financial crime controls, government effectiveness and rule of law, and international sanctions. Transparency International's 2025 Corruption Perceptions Index scores Hong Kong 76/100 (rank #12 of 182).

What due diligence applies to Hong Kong?

Enhanced due diligence. 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 tracks 244 enforcement actions from 2 regulators in Hong Kong. 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)