HONG KONG · EAST ↔ WEST
info@lockhartyip.comResponse within 4 hours (UTC+8)
Discuss your matter
Home/Practices/Sanctions & AML
Practice · Sanctions & AML

Which sanctions actually apply to your Hong Kong business?

Sanctions and AML compliance in a neutral jurisdiction: exposure screening, policies, KYC frameworks and contract review for groups operating between Asia, the CIS, the Middle East and Europe.

Hong KongCISMainland ChinaEngland & Wales
20
lawyers across nine focused practices
1000+
matters handled since 2023

What we solve

The problem

Few areas produce more noise and less clarity. The starting point is jurisdictional and dry: Hong Kong implements United Nations sanctions through its own legislation and does not implement unilateral US sanctions. From there, the questions become specific — who are your counterparties, which banks and currencies does the business depend on, and which rules attach to each leg of each transaction.

We treat this as compliance work: measured, documented, defensible. We screen exposure, write the policies, build the KYC framework and review the contracts, so that the position is clear before a bank or counterparty asks — not after.

What we do

Scope of work
Sanctions & AML

Sanctions exposure screening

Mapping of counterparties, ownership chains, goods and payment flows against the sanctions regimes that actually attach to each leg.

Sanctions & AML

AML / CFT policies

Policies and procedures aligned with Hong Kong's anti-money-laundering framework and the standards banks expect of their clients.

Sanctions & AML

KYC frameworks

Internal know-your-customer programmes for groups that onboard their own counterparties and investors.

Sanctions & AML

Contract review with a sanctions element

Sanctions clauses, compliance representations, suspension and termination mechanics — reviewed before signature, not after a freeze.

Sanctions & AML

Dispute defence with a sanctions element

Defence strategy in contract disputes where sanctions are raised, acting with locally licensed counsel where Hong Kong proceedings are involved.

Hong Kong law steps completed with a locally licensed firm.
Sanctions & AML

Neutral-forum contracting

Contract frameworks with HKIAC arbitration clauses for transactions whose parties need a neutral, enforceable forum.

Representative experience

Anonymised
Representative matter

Sanctions exposure audit for a trading group

Screened a commodities trading group's counterparties and payment flows against three sanctions regimes and produced a remediation plan adopted by the board.

Representative matter

AML framework for a private investment office

Wrote the AML and KYC framework for a multi-family investment office onboarding external co-investors.

Representative matter

Defence of a sanctions-based non-payment

Advised a respondent in arbitration where the counterparty invoked sanctions clauses to avoid payment. The tribunal rejected the defence.

Matters are described without identifying parties or amounts. More representative matters.

Recognition

Partners recognised in Chambers and Legal 500.

Recognition sits with the individuals who run your matter — not with a logo. The partners responsible for this practice are listed in the leading independent directories.

How we work
  • 01Initial meeting and conflict check, then a written assessment of your situation.
  • 02A proposal with a clear fee structure and scope before any work begins.
  • 03The matter is run with regular updates and direct partner access.
  • 04A result report and a recommendation on next steps.

Questions clients ask

FAQ
Does Hong Kong apply US sanctions?

No. Hong Kong implements United Nations sanctions through its own legislation and does not implement unilateral US sanctions. That is a statement about Hong Kong law, not about banking practice: banks operating in Hong Kong frequently apply group-level policies that reflect US and EU rules.

Both layers matter. We map the legal position and the practical one, and we put the difference in writing.

Is it lawful to work with CIS counterparties through Hong Kong?

It depends on who the counterparty is, what is being traded and how payment flows — which is precisely what screening establishes. We document what is permitted, flag what is not, and decline work that is designed to disguise either.

What AML obligations does an ordinary Hong Kong company have?

Hong Kong's anti-money-laundering legislation directly regulates financial institutions and designated professions. An ordinary trading company is mostly governed by its banks' expectations and by general record-keeping duties — which is exactly where most practical problems arise. We right-size the framework to the business.

Can a contract protect us if sanctions change mid-performance?

It can allocate the risk. Well-drafted sanctions clauses define what triggers suspension or termination, what happens to money in flight and who bears the cost of a freeze. No clause removes the risk; a good one decides in advance who carries it.

Will you help us structure around sanctions?

No. We advise on compliance: what applies, what is permitted and how to document the position. Work designed to evade sanctions is work we decline — which is also why our files survive scrutiny.

How often should sanctions screening be refreshed?

On every new counterparty; on every material change to an existing one — ownership, goods, payment route; and on changes to the regimes themselves. For active trading businesses we set a screening rhythm rather than a one-off check, because lists move faster than contracts do.

What records evidence compliance if a bank or counterparty asks?

Dated screening results, the methodology used, the decisions taken and their reasoning — kept contemporaneously.

A compliant decision without a record is, for practical purposes, indistinguishable from no decision. Building that record is part of every framework we install.

From the Sanctions & AML cluster

Insights
In preparation

Which sanctions apply in Hong Kong — and which do not

In preparation

Sanctions clauses in supply contracts: allocating the freeze

In preparation

An AML framework banks will recognise

Practitioner notes for this practice are in preparation and will appear in the Sanctions & AML cluster.

Visit the Insights hub
Clear & candid We advise on international and foreign law. On matters of Hong Kong law, we work alongside locally licensed firms. Where a matter touches Hong Kong law — courts, licensing, registries or notarisation — we act together with a locally licensed Hong Kong firm.
Next step

Discuss a Sanctions & AML matter.

A written assessment of your position and options is the usual first step.

Request a consultation
This site uses only strictly necessary cookies. Non-essential cookies are declined by default. Cookie policy