Earlier this summer, the United States announced santions1 against several Hong Kong based companies for their role in facilitating the trade of Russian sourced gold. Over the last two years, Hong Kong has seen its Russian gold imports quadruple2, surpassing the UAE as the largest hub for Russian gold. While Hong Kong itself has not imposed restrictions on Russian gold, many countries including the US and UK have issued import bans3 on it. This leaves Hong Kong based firms vulnerable to secondary sanctions, as well as to money laundering schemes attempting to move the proceeds of Russian traded gold through the international financial system.
Due to its close proximity to mainland China, as well as its role as a leading international trade and finance hub4, Hong Kong is exposed to a range of sanction and trade-based risks. Firms may look to use Hong Kong’s ports and airports to attempt to circumvent international sanctions or trade restrictions, including to access key markets such as China and Russia. Moreover, criminals also may look to use Hong Kong’s financial system to launder the proceeds of these sanction evasion schemes. This extends beyond gold, to other commodities such as technology and oil. There have been recent cases of Hong Kong based companies being linked to the trafficking of Iranian sanctioned oil, for example. In one case5, a Hong Kong company acted as a front for millions of dollars’ worth of transactions linked to the sale of Iranian oil in China.
A New York Times investigation6 last month also found that an array of shell companies with the same Hong Kong address have acquired millions of restricted chips and sensors for military technology companies in Russia, many of which under sanctions by the US and other countries. Chipmakers in countries such as the US sell their products to international distributors and then are no longer legally required to track where their goods go from there. Russia has increasingly turned to international distributors therefore, with Hong Kong firms playing a notable role in this supply chain network. Some of these firms are directly owned by Russian oligarchs with links to Russia’s military industrial base, according to the New York Times’s analysis.
One shell company at the Hong Kong address, Saril Overseas, had no record of exports to Russia until six months after the war began. The company is owned by Russian businessman Alexey Chichenev, according to the New York Times.
Hong Kong’s heightened sanction evasion risk demonstrates key features of the region that leave it exposed to financial and trade-based crimes more generally. Hong Kong’s open economy and global business and financial ecosystem leaves it vulnerable to abuse by criminals looking to commit crimes such as money laundering, cyber fraud, and smuggling of illicit goods. Before carrying out business in Hong Kong, it is important for firms to understand what financial crime risks factors they should be aware of in order to carry out proper due diligence and make informed decisions. Understanding the local and international dynamics at play in the region, including sanction risks, will help firms carry out effective risk management. Our new Hong Kong Country Risk Report provides a comprehensive analysis of this financial crime landscape.
Looking at the nexus between the trade of Russian sourced gold and Hong Kong based trade and financial firms provides some key insights into emerging trends and risks specific to the region.
What are key trends to look out for?
Lower levels of transparency in supply chains
As multinational banks and trade companies remove themselves from the trade in sanctioned commodities such as Russian sourced gold, smaller and more obscure firms take over the trade and financing of these commodities. These firms are often less transparent with their due diligence supply chain and often lack the in-depth compliance oversight of larger firms. This trend can be applied beyond sanctions and export controls, such as to riskier commodities like minerals sourced in countries with high levels of conflict or deforestation.
Cemented status as a transshipment hub
Hong Kong’s geographical location and logistics and transportation infrastructure leaves it vulnerable to abuse by criminals looking to smuggle commodities or products through the region. Hong Kong’s close proximity to mainland China increases this risk, as criminals may look to use Hong Kong as a transshipment hub for entering the Chinese market. There have been recent cases7, for example, where Hong Kong has been used as a transshipment hub for diverting Western-made technology to companies affiliated with the Russian government.
Use of front companies and other corporate vehicles
In one case, the US found a Hong Kong-based front company had been used in evasion schemes of international sanctions, as well as in other transnational organised crime schemes. One key risk is the use of front companies for proliferation or terrorist financing. Hong Kong based front companies, for example, have been linked to8 the facilitation of tens of millions of dollars’ worth of proliferation activities for the Islamic Revolutionary Guard Corps (IRGC) and the Iranian regime’s missile programme. See the Themis Search image below for details on this network.
Heightened exposure to international corruption
Hong Kong is exposed to international corruption due to its interconnectedness with international markets and businesses, as well as its role as a financial hub serving high net worth individuals and political elites. This corruption exposure is heightened by the risk of oligarchs and criminals looking to engage in sanction evasion and transshipment schemes in the region.
Impact of environmental crime and the trade of illicit commodities - Criminals have used Hong Kong as a trade hub for a range of commodities illicitly sourced through illegal mining or land clearing, such as illicit gold and timber. These illicit environmental activities, which are often linked to sanction and trade-based crimes, have considerable impact on local ecosystems and communities and on our environment at large. Illegal logging9 is a particularly high risk for Hong Kong, with mainland China a key market for illegally sourced timber. As already noted, Illegal mining and trafficking of non-renewable resources is another key risk, as Hong Kong serves as a transit point for the trade of illicitly sourced minerals, including gold from sanctioned or conflict-affected areas. Read our recent report, Financial Crimes and Land Conversion: Uncovering the Risk for Financial Institutions, to learn more about the unique risks of illegal deforestation and land clearing.
Illicit financial flows and complex, multi-layered laundering networks
Hong Kong’s role as an international financial centre leaves it vulnerable to the illicit financial flows associated with sanction and trade related crimes. Authorities have found complex, multi-layered laundering schemes using Hong Kong based firms moving and hiding illicit proceeds of crimes. This year, the US sanctioned10 a gold laundering network using numerous Hong Kong-based trading companies to route payments related to the sale of Russian origin gold through the international financial system back into the Russian financial system. See the Themis Search image below for details on this network.
What to learn more about financial crime risks in Hong Kong?
Our new report delves into the latest trends across various financial crimes, offering a detailed examination of how these threats evolve and their impact on the socio-economic fabric of Hong Kong. Our threat-based research covers a broad spectrum of interlinking crimes, enabling a comprehensive understanding of financial crime dynamics. Some other key risk areas we cover in the report include:
For a comprehensive analysis, our Hong Kong Country Risk Report offers detailed insights and practical guidance for navigating these challenges effectively.
Stay on top of the ever-changing financial crime landscape by accessing the latest information on emerging criminal techniques and the risks associated with carrying out business with particular industries or in particular jurisdictions.
Significant updates to the Land Conversion and Financial Crime Risk Assessment highlight links between environmental harm and financial crime. Cattle rustling in Nigeria and Cameroon now carries a red risk rating. Other updates cover carbon credit fraud, child labour, corruption in mining, and gold smuggling. A new toolkit search aids detection.
An overview of modern slavery, distinguishing between human trafficking, smuggling, and forced labor. It highlights the global prevalence of exploitation and the importance of understanding these definitions to combat such crimes.
Dubai’s booming real estate market, with over $160 billion in foreign ownership, is vulnerable to financial crimes like money laundering. The UAE now requires real estate professionals to report high-value transactions over AED 55,000 through the Real Estate Activity Report (REAR). Criminals, such as Daniel Kinahan, have exploited property investments to hide illicit funds. The article urges strict compliance and awareness to enhance financial transparency and prevent abuse within the sector.
Examines how digital platforms and cryptocurrencies facilitate human trafficking, allowing traffickers to operate anonymously and at scale, posing challenges for law enforcement.
Investigates how sanctions intersect with trade-based financial crimes in Hong Kong, highlighting the complexities businesses face in navigating regulatory compliance.
Financial crimes cause more than economic damage—they deeply affect mental health. A UK survey found 60% of fraud victims experienced emotional distress, with many reporting panic attacks and weight changes. In Ghana, exposure to corruption correlated with anxiety and depression in young adults. The blog calls for greater recognition of these hidden harms and urges a more empathetic approach to tackling financial crime, emphasizing both psychological and financial well-being.
Environmental crime disproportionately impacts women, worsening existing gender inequalities. Illegal logging and mining fuel gender-based violence and trafficking, especially in regions like the DRC and Peru. Women environmental defenders face targeted abuse, while climate change increases hardships for women reliant on natural resources. Consequences include water scarcity, child marriage, and health risks from extreme heat. Tackling environmental crime is essential for protecting women’s rights, safety, and health in vulnerable communities.
AI is transforming financial crime prevention by enhancing detection, streamlining compliance, and lowering costs. The blog highlights how generative AI and tools like graph neural networks improve due diligence and empower institutions. While criminals exploit AI for fraud, its ethical use—combined with human oversight—can democratise compliance and boost resilience. Themis advocates for embracing AI’s potential to fight financial crime effectively, focusing on collaboration between technology and human expertise.
Explores the application of fuzzy logic in Anti-Money Laundering (AML) systems, emphasising its role in improving name-matching accuracy and reducing false positives, thereby enhancing compliance efficiency.
This book focusses on the challenges faced by law enforcement in North West USA and in British Columbia to combat illegal logging, as well as those of the timber-industry communities established since the late 19th century to maintain meaningful and financially viable lives.
Lebanon’s economic collapse—driven by debt, corruption, and political instability—has led to hyperinflation and a reliance on cash, increasing exposure to financial crime. In October 2024, the FATF added Lebanon to its grey list for failing to meet anti-money laundering and counter-terrorism financing standards. This listing hinders foreign investment and remittances. In response, Lebanon has pledged a two-year reform plan to improve financial transparency and rebuild international confidence.
The UK treats proceeds from foreign cannabis businesses as criminal property under the Proceeds of Crime Act, even if earned legally abroad. Despite exceptions for overseas conduct, cannabis-related activities typically exceed the 12-month sentencing threshold, making them ineligible. This legal grey area has prompted calls for reform. Until clarified, businesses and individuals handling foreign cannabis funds in the UK should act cautiously and seek legal guidance to avoid potential money laundering risks.
The UK’s 2023–2026 Economic Crime Plan commits £400 million to tackling financial crime, focusing on reducing money laundering, combating kleptocracy, and tackling fraud. It includes reforms to Companies House, cryptoasset regulation, sanctions enforcement, and fraud prevention. While progress has been made since 2019, challenges remain. Critics argue the plan lacks funding and urgency, but success depends on collaboration across government, private sector, and individuals to stop illicit finance and protect society.
Emphasising the critical role of Suspicious Activity Reports (SARs) in combating financial crime. It advocates for fostering a culture of transparency within organisations, encouraging employees to report suspicious activities without fear of retaliation. Highlighting that 42% of fraud cases are detected through tip-offs, the article underscores the importance of internal reporting mechanisms. It also notes a significant increase in SARs and associated account freezes in the UK, demonstrating their effectiveness in disrupting illicit financial activities.
Corrupt elites continue exploiting the UK property market, using offshore structures and relatives to hide assets. Despite the 2022 Register of Overseas Entities, over 18,000 companies failed to comply or obscured ownership. Cases involving Russian and Azerbaijani figures reveal children owning multimillion-pound properties. Themis warns of widespread misuse of family ties and urges stronger enforcement. Updated FATF guidance and UK regulations aim to close transparency gaps and tackle hidden financial crime risks.
Corruption undermines sustainable development and fuels financial crimes, while also impeding diversity, equity, and inclusion (DEI). A joint analysis by Themis and Denominator found a strong inverse correlation: countries with lower corruption levels have higher DEI scores. Corruption disproportionately harms marginalised groups, especially women. Increasing diversity in leadership helps disrupt corrupt networks, though true progress requires democratic values, transparency, and inclusion. Emphasising DEI is crucial for combating corruption and promoting fair, inclusive societies.
A report by Hindenburg Research accuses India’s Adani Group of major corporate fraud, alleging stock manipulation, shell companies, and nepotism. The claims have halved Gautam Adani’s net worth and shaken investor confidence. Adani’s political ties raise concerns over cronyism in India. The scandal underscores the impact of financial crime on markets and highlights the critical need for robust due diligence to detect risks early and preserve economic integrity and transparency.
Corporate failures in supply chain due diligence have led to financial and reputational damage, with cases like Inditex and Sketchers linked to forced labour. The EU’s upcoming Corporate Sustainability Due Diligence Directive (CSDDD) will mandate large companies to address human rights and environmental risks across operations and supply chains. While promising, the directive excludes financial institutions and SMEs, limiting impact. Themis offers tools to assess supplier risk and fight crimes like modern slavery.
On World Wildlife Day and CITES’ 50th anniversary, Themis reflects on the global fight against illegal wildlife trade (IWT), the world’s fourth most lucrative financial crime. Peru’s recent legislation classifying IWT as organised crime marks major progress, but tougher ivory bans have shifted demand to hippo teeth, threatening new species. Despite setbacks, forensic science, AI, and volunteer cyber-spotters are enhancing detection and prosecution, proving that innovation and global cooperation can counter IWT effectively.
Puppy smuggling in the UK has surged post-pandemic due to soaring demand and prices, making it a target for organised crime. Criminals exploit legal loopholes, importing underage, sick, or pregnant dogs under non-commercial regulations. Despite new legislation, weak enforcement and lack of visual checks persist. Case studies reveal networks laundering money through illicit breeding. Buyers must remain vigilant, and due diligence—like using Themis Search—can help uncover breeder criminal links and protect animal welfare.
Romance scams rose by 30% in 2022, with victims losing an average of £8,234—especially impacting men and those aged 65–74. Scammers exploit dating apps and social media, using fake profiles and emotional manipulation to defraud victims. Themis urges individuals to conduct due diligence in dating, just as in business. Tools like Themis Search can uncover red flags, helping users avoid fraud and enabling dating platforms to protect users more effectively.
With crypto’s volatility and under-regulation under renewed scrutiny, its dual role in social good and financial crime is clear. While over $50 million in crypto has supported Ukraine, scammers and sanctioned actors also exploit it. Russia’s use of crypto to bypass sanctions, particularly via the UAE and the Central African Republic, raises serious concerns. Themis urges enhanced due diligence, sanctions screening, and compliance to mitigate crypto’s abuse in fraud, laundering, and geopolitical manipulation.
How the Russian invasion of Ukraine has exacerbated human trafficking risks, particularly for women and children. With over 2.5 million people fleeing Ukraine, traffickers exploit the chaos, offering false promises of shelter or work. Existing trafficking networks in Eastern Europe, especially in Moldova, Poland, and Italy, capitalize on the lack of coordination at border crossings. The OSCE recommends immediate measures to inform refugees about potential risks and deceptive offers.
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