AFRC reprimands former CPAs, Mak Kwong Yiu, Chan Lai Yee and Wong Shuk On, for CPA misconduct and imposes fines totalling HK$760,000 following criminal convictions for conspiracy to defraud

The Accounting and Financial Reporting Council (AFRC) has sanctioned Mr Mak Kwong Yiu (Mak), Ms Chan Lai Yee (Chan) and Ms Wong Shuk On (Wong) (collectively, Regulatees) for CPA misconduct, following an earlier judgment handed down by the Court of Final Appeal (CFA) in November 2025¹, which restored their criminal convictions for conspiracy to defraud handed down by the District Court in 2021.

The Accounting and Financial Reporting Council Ordinance (AFRCO) provides that a certified public accountant (CPA) is guilty of CPA misconduct if convicted by a Hong Kong court or elsewhere of an offence involving dishonesty.  Given that the Regulatees were members of the Hong Kong Institute of Certified Public Accountants (HKICPA) at the relevant times and were convicted of offences involving dishonesty, the AFRC found that they were each guilty of CPA misconduct.  The AFRC has therefore (a) issued a public reprimand to each of Mak, Chan and Wong and (b) imposed a pecuniary penalty of HK$400,000, HK$200,000 and HK$160,000 on them respectively.

The case arose from certain bond placements by Convoy Financial Holdings Limited (Company)², a company formerly listed on The Stock Exchange of Hong Kong Limited (HKEX), which was delisted on 4 May 2021.  At the relevant time, Mak, Chan and Wong held senior executive and management roles at the Company, which included serving as Chief Executive Officer, Chief Financial Officer and Manager of the Finance and Accounts Department, respectively.

The CFA found that, Mak, assisted by Chan and Wong, orchestrated a scheme to interpose an intermediary as a disguise in the bond placements.  This enabled the diversion of over HK$25 million to a connected entity in which Mak held an indirect interest, thereby circumventing the compliance requirements under the connected transaction rules of HKEX.  As a result, the Regulatees were convicted of two counts of conspiracy to defraud against (a) the Company, its board of directors and shareholders, and potential investors, and (b) the HKEX respectively.

In deciding the appropriate disciplinary sanctions, the AFRC has considered all the relevant circumstances, including the nature, seriousness, duration, frequency and impact of the misconduct, as well as the relevant aggravating and mitigating factors.  

Specifically, the AFRC considers criminal conduct involving fraud and dishonesty to be fundamentally incompatible with the standards expected of the accounting profession.  Such misconduct – particularly by those in senior executive and management roles – is considered extremely serious, and would ordinarily warrant exclusionary sanctions.  However, the Regulatees were professional accountants in business and have never held practising certificates, and ceased to be HKICPA members in 2023.  Had the Regulatees remained HKICPA members, the AFRC would have considered it appropriate to suspend or revoke their registrations.

Ms Hester Leung, Head of Discipline, said, “Professional accountants in business play a critical role in upholding strong corporate governance, effective internal controls and high-quality financial reporting.  This responsibility is particularly critical for those serving listed entities, where public accountability and market integrity are at stake. When individuals in such roles engage in fraudulent or dishonest misconduct, or deliberately circumvent regulatory requirements, they seriously undermine public confidence and bring discredit to the profession. The AFRC will take firm and decisive action against such misconduct to safeguard market integrity, uphold professional standards and protect the public interest.”

For details of the decision, please refer to the Statement of Disciplinary Action.

[1] HKSAR v Mak Kwong Yiu & Ors [2025] HKCFA 20

[2] Previous stock code: 01019

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