SFC revokes the licence of Amber Hill Capital Limited and bans its senior management for life

On August 28, 2025, the Securities and Futures Commission ("SFC") revoked the license of Amber Hill Capital Limited ("AHCL") for facilitating the misappropriation of funds and other dishonest activities related to fund management.

Additionally, the SFC banned AHCL's former senior management, Neo Ng Yu and Simon Ng She Chun, from engaging in all regulated activities for life.

On August 28, 2025, the Securities and Futures Commission ("SFC") investigation revealed that AHCL served as the manager of a segregated portfolio of a Cayman-incorporated fund (Sub-fund) from October 6, 2017, to September 29, 2021.

The investigation uncovered that Neo Ng, along with his connected persons and entities, orchestrated a scheme to misappropriate approximately US$154 million belonging to a client of Nerico Brothers Limited ("NBL") through the Sub-fund. AHCL knowingly facilitated this scheme.

Under the scheme, NBL transferred its client’s funds to the Sub-fund for the purported acquisition of ‘liquidity provider units’ from the Sub-fund between January and August 2021. Although the Sub-fund did not issue or hold any such units, AHCL accepted the funds transferred from NBL. AHCL then directed the Sub-fund to transfer a significant portion of the proceeds to a corporate vehicle owned by Neo Ng and use most of the remaining proceeds for the Sub-fund’s own purposes.

While serving as the fund manager, AHCL represented to the Sub-fund’s auditors and administrators that NBL was one of the brokers used by the Sub-fund for its trading activities and that the majority of the Sub-fund’s cash assets were held in an account maintained with NBL (NBL account).

AHCL also claimed that Neo Ng made three subscriptions totalling US$297 million for the shares of the Sub-fund via a corporate vehicle he controlled, and that the proceeds from his subscriptions were transferred to this purported NBL account. However, the investigation revealed that the Sub-fund was not a client of NBL, nor did it maintain any account with NBL.

The Sub-fund’s cash assets purportedly maintained with NBL did not exist, and the Sub-fund’s cash position was overstated by the purported balance of up to US$451 million at the NBL account between November 2019 and May 2021.

Furthermore, AHCL provided false information and fabricated documents, including fabricated auditors’ reports, about the Sub-fund’s value and financial position to mislead investors and prospective investors between November 2019 and September 2021.

On August 28, 2025, the SFC attributed the misconduct of AHCL to the actions of Neo Ng and Simon Ng. Neo Ng, the mastermind, orchestrated and personally benefited from schemes involving the misappropriation of NBL’s client funds and the artificial inflation of the Sub-fund’s value. Simon Ng conspired with Neo Ng by processing and dissipating the misappropriated funds, providing false information, and fabricated documents.

Taking into account the egregious nature of their conduct, the damage to investor confidence, significant losses to NBL’s client, and their clean disciplinary records, Neo Ng and Simon Ng, both within the definition of 'regulated person' under the SFO, have been subject to disciplinary actions due to their role in AHCL’s business.

Neo Ng, a director of AHCL from 2019 to 2021, was also a substantial shareholder of NBL’s client since 2020 and a director of the client from 2021. He held approximately 75% of the Sub-fund shares as of December 2020. Simon Ng served as manager-in-charge of AHCL’s core functions between 2019 and 2020. AHCL ceased business operations in regulated activities by the end of 2021.