SFC reprimands and fines Wu Hon Cheung $50,000

9 Jan 2018

The Securities and Futures Commission (SFC) has reprimanded Mr Wu Hon Cheung, a former account executive of Sun Hung Kai Investment Services Limited (Sun Hung Kai), and fined him $50,000 for failing to keep proper records of a client’s order instructions, in breach of the Code of Conduct (Notes 1 & 2).

The SFC found that between August 2014 and January 2015, Wu failed to use Sun Hung Kai’s tape-recorded phone to record instructions as required by the Code of Conduct after receiving order instructions from a client on his mobile phone.  Wu also failed to record the order details and order receipt time for some of the client orders in his manual trade blotter in accordance with Sun Hung Kai’s internal requirements (Note 3).

In deciding the disciplinary action against Wu, the SFC took into account all relevant circumstances, including Wu’s otherwise clean disciplinary record.

The SFC stresses that keeping proper records of client orders, which helps to protect the interests of clients, is a fundamental duty expected of licensed individuals.



  1. Wu is licensed under the Securities and Futures Ordinance to carry on business in Type 1 (dealing in securities) regulated activity and was accredited to Sun Hung Kai Investment Services Limited between 18 January 2012 and 16 January 2015.  Wu is currently accredited to China Industrial Securities International Brokerage Limited.
  2. Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission (Code of Conduct).
  3. Paragraph 3.9 of the Code of Conduct requires a licensed person to use a telephone recording system to record order instructions which are received from clients through the telephone.  The use of mobile phones for receiving client order instructions is strongly discouraged.  However, where orders are accepted by mobile phones, staff members should immediately call back to their licensed person’s telephone recording system and record the time of receipt and the order details.  The use of other formats (e.g. in writing by hand) to record details of clients’ order instructions and time of receipt should only be used if the licensed person’s telephone recording system cannot be accessed.

A copy of the Statement of Disciplinary Action is available on the SFC website.

Page last updated : 9 Jan 2018