Hong Kong Customs, in a press release dated 9 September 2026, reported detecting a local company the previous day that had conducted transactions in jewellery containing precious metals and stones valued above HK$120,000 without registration under the Dealers in Precious Metals and Stones Regulatory Regime. Under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), a person carrying on a business of dealing in precious metals and stones registers with Hong Kong Customs before engaging in transactions, cash or non-cash, with a total value at or above HK$120,000, unless exempted. A dealer who is not a registrant and carries out such transactions is liable on conviction to a maximum fine of HK$100,000 and six months’ imprisonment. The investigation is ongoing.
Cap. 615 covers gold in a manufactured or unmanufactured state, and the dealing activities it names include purchasing and selling, importing and exporting, and acting as an intermediary, so the registration test applied in this case is the test that applies to a bullion transaction in Hong Kong. Customs’ published description of the regime sets two categories: Category A for non-cash transactions at or above HK$120,000, and Category B for a dealer also taking cash at that level, which is the category carrying AML/CTF supervision. The threshold is a total transaction value, counts payments received as well as payments made, and includes the equivalent amount in another currency, so a single 1 kg bar invoiced in US dollars and settled by bank transfer sits above it. Which of the two categories a Hong Kong counterparty holds is established at intake, in the same pass as sanctions screening and source-of-funds review, and before an instruction is placed rather than at settlement. A logistics service business that only imports or exports precious metals in the ordinary course of that business falls outside the dealer definition, so registration attaches to the dealer at each end of a movement rather than to the transport operator. A dealer with no place of business in Hong Kong that carries on business there for no more than 60 days in a calendar year is exempt from registration and files a cash transaction report to Customs within one day of a specified cash transaction, or before leaving Hong Kong, whichever is earlier.
Registration under Cap. 615 is a status held with the Commissioner of Customs and Excise. Fineness, weight and Good Delivery status are set by the refiner and the LBMA and are unchanged by it.