SFC suspends former Agg. Asset Management responsible officer Chow Tsz Lam for 12 months for fund management failures

On September 4, 2025, the Securities and Futures Commission ("SFC") suspended Mr. Chow Tsz Lam, a former responsible officer ("RO") and manager-in-charge of various core functions of the now dissolved Agg. Asset Management Limited (Agg), for 12 months from 2 September 2025 to 1 September 2026. This disciplinary action stems from an SFC investigation that found Agg invested up to 100% of its fund assets in debentures issued by companies controlled by Mr. Ng Ka Shun, the sole shareholder and another RO of Agg. Consequently, Agg failed to avoid conflicts of interest and appropriately manage risks associated with the fund. Additionally, the SFC discovered that Agg invested in debentures that appeared to have been constructed for the purpose of inflating the fund’s net asset value.

The SFC also took disciplinary action against Ng for his role in making investment decisions for the fund and for his primary responsibility in these failures. The suspension of Chow was based on findings that he failed to discharge his duties as an RO and a member of the senior management of Agg to ensure that the firm acted in the best interests of the fund and its investors, and complied with applicable regulatory requirements. Factors considered in the decision for the disciplinary sanction included Chow’s cooperation with the SFC, his lesser level of responsibility compared to Ng, the lack of a finding of dishonesty against him, the report he made to the SFC that triggered the investigation, and his otherwise clean disciplinary record.

Chow was licensed under the Securities and Futures Ordinance ("SFO") to engage in Type 1 (dealing in securities), Type 4 (advising on securities), and Type 9 (asset management) regulated activities. He was accredited to Agg and approved to act as its RO from 4 May 2017 to 11 April 2019. At the time of his suspension, Chow was not accredited to any other licensed corporation. Between 13 July 2017 and 11 April 2019, Chow served as Agg’s Manager-in-Charge of Compliance, Anti-money Laundering and Counter-terrorist Financing, Operational Control and Review, and Risk Management. On 3 April 2020, the SFC issued a restriction notice to Agg, prohibiting it from carrying on any business that constituted regulated activities under the SFO. Agg was subsequently struck off the Companies Register and dissolved on 5 July 2024. Ng was banned for life and fined $1.7 million for window-dressing Agg’s financial resources and mismanaging two funds. The SFC’s press releases dated 3 April 2020 and 23 December 2024 provide detailed information on these disciplinary actions. A copy of the Statement of Disciplinary Action can be accessed on the SFC website.