Hong Kong Court-Appointed Administrators Paid $2.4 Million (HKD 19 Million) to Affected Clients of Hong Kong Wan Kiu Investment for Misappropriating $9.76 Million, Sold Clients Securities without Authorisation & Fabricated Clients Statements
24th July | Hong Kong
Hong Kong court-appointed administrators had paid $2.4 million (HKD 19 million) to affected clients of Hong Kong Wan Kiu Investment Company for misappropriating $9.76 million (HKD 76 million), selling clients’ securities without their authorisation and fabricating clients statements to conceal the fraud. In 2022 November, a Hong Kong court ordered investment firm Hong Kong Wan Kiu Investment Company and Sham & Partners to compensate clients for misappropriating $9.76 million (HKD 76 million), selling clients’ securities without their authorisation and fabricating clients statements to conceal the fraud. Hong Kong Wan Kiu Investment sole director & shareholder is Connie Sham Khi Rose and Sham & Partners is owned by her son (Christopher Sham Ho Ming). Hong Kong SFC (23/7/25): “The Securities and Futures Commission (SFC) today noted that court-appointed administrators had distributed approximately $19 million worth of assets this month as compensation to affected clients of Hong Kong Wan Kiu Investment Company Limited (HKWK) following the approval of the Court of First Instance in January 2025 (Notes 1 to 4). This came after the Court granted final reliefs – including a restoration order in favour of the affected clients of HKWK, alongside an order appointing administrators to recover and administer HKWK’s assets – in November 2022 following legal proceedings brought by the SFC under section 213 of the SFO. The SFC’s legal proceedings arose from an investigation after detecting signs of financial irregularities on the part of HKWK. The SFC’s investigation revealed that HKWK and its sole director and shareholder, Connie Sham Khi Rose, had sold securities of HKWK’s clients without their authorisation, misappropriated the sales proceeds, and falsified client statements to conceal the unauthorised transactions. The SFC subsequently referred the matter to the Police for further investigation which resulted in the criminal prosecution of Sham by the Department of Justice. The criminal proceedings at the High Court against Sham had been concluded. Sham pleaded guilty to misappropriating around $58 million worth of HKWK’s client assets between 2011 and 2019. On 3 July 2025, Sham, aged 88, was sentenced to 160 hours of community service, with the Court taking into account her remorse and the fact that she had already compensated the affected clients of HKWK through resources of her own, her family and friends.” Hong Kong SFC (2022): “It is also believed that part of the misappropriated proceeds in the sum of $76 million was transferred to the bank account of Sham & Partners … … The Court has appointed administrators to recover, receive, administer and distribute assets of approximately HKD 19 million frozen by the interim injunction obtained by the SFC in February 2020 to restrict HKWK and its connected entities from disposing their assets.” Hong Kong Wan Kiu Investment Company is licensed under the Hong Kong Securities and Futures Commission (SFC) – Type 1 (dealing in securities) regulated activity. See below for Hong Kong SFC statement:
“ Hong Kong Court-Appointed Administrators Paid $2.4 Million (HKD 19 Million) to Affected Clients of Hong Kong Wan Kiu Investment for Misappropriating $9.76 Million, Sold Clients Securities without Authorisation & Fabricated Clients Statements “
Notes:
- Please see the SFC’s press release dated 23 November 2022 for details.
- HKWK was licensed under the Securities and Futures Ordinance (SFO) to carry on Type 1 (dealing in securities) regulated activity. Sham was the sole director and shareholder of HKWK, and was the responsible officer and manager-in-charge of anti-money laundering and counter-terrorist financing, compliance, key business line, operational control and review, overall management oversight and risk management of HKWK at the material times. HKWK’s licence was revoked in March 2024.
- The administrators are Mr Fok Hei Yu and Mr Chow Wai Shing Daniel, both of FTI Consulting (Hong Kong) Limited.
- In February 2020, the SFC obtained an interim injunction order (Injunction) under section 213 of the SFO against HKWK and related parties to freeze their assets. Prior to obtaining the Injunction, the SFC issued a restriction notice against HKWK in November 2019 to prohibit HKWK from carrying on any regulated business for which it is licensed under the SFO and disposing of and dealing with any property held by it or held on behalf of its clients until further notice. Please see the SFC’s press release dated 5 November 2019 for details.
Hong Kong Court Orders Hong Kong Wan Kiu Investment & Sham & Partners to Compensate Clients for Misappropriating $9.76 Million, Sold Clients Securities without Authorisation & Fabricated Clients Statements

24th November 2022 – A Hong Kong court has ordered investment firm Hong Kong Wan Kiu Investment Company and Sham & Partners to compensate clients for misappropriating $9.76 million (HKD 76 million), selling clients’ securities without their authorisation and fabricating clients statements to conceal the fraud. Hong Kong Wan Kiu Investment sole director & shareholder is Connie Sham Khi Rose and Sham & Partners is owned by her son (Christopher Sham Ho Ming). Hong Kong SFC: “It is also believed that part of the misappropriated proceeds in the sum of $76 million was transferred to the bank account of Sham & Partners … … The Court has appointed administrators to recover, receive, administer and distribute assets of approximately HKD 19 million frozen by the interim injunction obtained by the SFC in February 2020 to restrict HKWK and its connected entities from disposing their assets.” Hong Kong Wan Kiu Investment Company is licensed under the Hong Kong Securities and Futures Commission (SFC) – Type 1 (dealing in securities) regulated activity. See below for Hong Kong SFC statement:
Hong Kong SFC Statement:
Hong Kong Court orders Hong Kong Wan Kiu Investment Company Limited and its connected entities to compensate clients
23/11/22 – The Court of First Instance has ordered Hong Kong Wan Kiu Investment Company Limited (HKWK), its sole director and shareholder, Ms Connie Sham Khi Rose, and Sham & Partners Limited (SPL) to compensate clients of HKWK in legal proceedings brought by the Securities and Futures Commission (SFC) under section 213 of the Securities and Futures Ordinance (SFO) (Note 1). SPL, incorporated in Hong Kong, is solely owned by the son of Connie Sham, Mr Christopher Sham Ho Ming. The SFC’s investigation found that HKWK and Connie Sham had:
- sold securities of HKWK’s clients without their authorisation;
- misappropriated the sales proceeds which belonged to HKWK’s clients; and
- fabricated authorisation documents and account statements of HKWK’s clients to conceal the unauthorised transactions.
It is also believed that part of the misappropriated proceeds in the sum of $76 million was transferred to the bank account of SPL. The Court has appointed administrators to recover, receive, administer and distribute assets of approximately $19 million frozen by the interim injunction obtained by the SFC in February 2020 to restrict HKWK and its connected entities from disposing their assets. Prior to obtaining the interim injunction, the SFC issued a restriction notice against HKWK in November 2019 (Notes 2 to 4). The SFC also alleges that HKWK and Connie Sham have contravened, amongst others, section 300 of the SFO by employing a device, scheme or artifice with intent to defraud or deceive, or engaging in an act, practice or course of business which is fraudulent or deceptive, or would operate as a fraud or deception in transactions in securities.
Notes:
- HKWK was licensed under the SFO to carry on Type 1 (dealing in securities) regulated activity. Connie Sham is the sole director and shareholder of HKWK, and was the responsible officer and manager-in-charge of anti-money laundering and counter-terrorist financing, compliance, key business line, operational control and review, overall management oversight and risk management of HKWK at the material times.
- The administrators are Mr Fok Hei Yu and Mr Daniel Chow Wai Shing of FTI Consulting (Hong Kong) Limited.
- The terms of the interim injunction orders under which the funds were frozen were subsequently continued and varied.
- Under the restriction notice, HKWK was prohibited from carrying on any regulated business for which it is licensed under the SFO and disposing of and dealing with any property held by it or held on behalf of its clients until further notice. Please see the SFC’s press release dated 5 November 2019 for details.
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