SFC suspends Pun Hong Hai for 10 months

The Securities and Futures Commission (SFC) has suspended Mr Pun Hong Hai, a former responsible officer (RO), chief executive officer and manager-in-charge of overall management oversight of Freeman Commodities Limited (Freeman), for 10 months from 11 June 2025 to 10 April 2026 for supervisory failures (Note 1).

The SFC found that Pun failed to discharge his duties as an RO and a member of the senior management of Freeman to ensure the company maintained appropriate standards of conduct and adhered to proper procedures. In this capacity, he also failed to adequately manage the risks associated with Freeman’s business.

Specifically, Pun’s failures were related to the use of customer supplied systems (CSSs) by Freeman’s clients for placing orders and the company’s monitoring of suspicious money movements and trading patterns in client accounts between June 2017 and December 2018 (Notes 2 and 3).

In deciding the sanction, the SFC took into account all relevant circumstances, including the need to send a strong deterrent message to remind the market that senior management of licensed corporations will be held accountable for failing to discharge their duties.

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Notes:

1. Pun was licensed under the Securities and Futures Ordinance to carry on Type 1 (dealing in securities), Type 2 (dealing in futures contracts), Type 4 (advising on securities), Type 5 (advising on futures contracts) and Type 9 (asset management) regulated activities. Pun was accredited to Freeman, now known as Arta Global Futures Limited, and approved to act as its RO from 29 November 2016 to 6 September 2021. Pun is currently not accredited to any licensed corporation.
2. CSSs are trading software developed and/or designated by clients that enable them to conduct electronic trading through the internet, mobile phones and other electronic channels.
3. The CSSs were connected to Freeman’s broker supplied systems (BSSs) through an application programming interface (a set of functions that allows applications to access data and interact with external software components or operating systems). BSSs are trading facilities developed by exchange participants or vendors that enable the exchange participants to provide electronic trading services to investors through the internet, mobile phones and other electronic channels.
4. The SFC’s disciplinary action against Pun is related to its ongoing disciplinary action against a related entity. The SFC will not disclose the details of its disciplinary action against Pun until the conclusion of its action against that entity.