On 9 April 2026, The Securities and Futures Commission (SFC) reprimanded and fined Impression Investment Limited (Impression) $2 million for significant internal control deficiencies and supervisory failures regarding staff personal trading. Furthermore, the SFC has imposed an eight-month industry prohibition on former Responsible Officer (RO) Liu Shan for his central role in these regulatory breaches. An investigation revealed that between 2016 and 2021, Liu executed over 2,500 unauthorized personal transactions, frequently trading in the same securities and IPOs as the funds he managed. These activities bypassed internal approval protocols and violated the 30-day holding period requirement, creating unmanaged conflicts of interest. The SFC determined that Impression’s staff dealing policies were effectively non-existent in practice prior to 2021, reflecting a systemic failure to monitor and detect irregularities. While the firm has since implemented remedial post-trade monitoring, the sanctions underscore the SFC’s commitment to ensuring that senior management maintains rigorous oversight to preserve market integrity and investor trust.
Sources: https://apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announcements/news/doc?refNo=26PR55