What is the Client Name Screening Tool (the “Tool”):
The Tool is a Microsoft Excel–based application developed by the Law Society to support members in fulfilling compliance obligations related to targeted financial sanctions, terrorism financing, and proliferation financing of weapons of mass destruction. The Tool is primarily designed to screen names against the United Nations Security Council Consolidated Sanctions List (“UN Consolidated Sanctions List”), which contains the names of all individuals, groups, undertakings, and entities that are subject to sanctions measures imposed by the UN Security Council. These measures include asset freezes, travel bans, and arms embargoes, depending on the specific sanctions regime. It is the primary reference point for compliance with international targeted financial sanctions. Beyond sanctions screening, the Tool incorporates AI-driven searches of publicly available information to identify adverse news linked to a client and help to detect politically exposed persons (“PEPs”). All searches and findings are consolidated and presented in an AI-generated client due diligence report. The Tool strengthens compliance processes by documenting both sanctions checks and broader risk assessment.
The Law Society has developed the Tool with the aim of providing a practical and supportive resource, particularly for firms that do not have access to commercial screening solutions available on the market. While the Tool is regularly tested and its accuracy verified against the UN Consolidated Sanctions List to ensure reliability in this core function, members should remain mindful of the inherent limitations of the Tool and the fact that adverse news and PEP searches may not always be exhaustive. Firms are reminded to exercise their professional judgment and review links generated by the Tool, which form the basis of the client due diligence report.
What are the requirements:
Practice Direction P (Table of Mandatory Requirements, subsection 2 “How” (vi) and footnote 2) sets out the requirement — where appropriate, members should screen clients, beneficial owners, and connected parties against the “UN Consolidated Sanctions Lists”—which include designated individuals and entities, terrorists and terrorist associates. Members also have a statutory duty to report suspicious transactions involving designated parties to the Joint Financial Intelligence Unit (“JFIU”) via a Suspicious Transaction Report (“STR”).
Why the Tool was developed:
The Law Society recognises that members may face challenges in meeting sanctions screening requirements, whether due to limited access to affordable tools, the complexity of sanctions lists, or resource constraints. Conducting manual reviews of the UNSC Sanctions List provided in a pdf format is both labour-intensive and susceptible to human error. Recognising these challenges, the Law Society has developed a free, user-friendly Tool to help firms meet compliance obligations with confidence and without financial strain. As the AML supervisory framework evolves, the Tool will provide practical support in demonstrating compliance readiness.
Key features of the tool:
Members may also note that any changes to the existing UN Sanctions List are automatically reflected in the Tool. The Law Society regularly publishes updates to the UN Sanctions List under the section titled “Where do I find lists of designated persons and entities?” on its website.
Background and summary overview of the Tool have been published in the Hong Kong Lawyer Journal, dated August 2025, for members’ reference.
Hong Kong fully implements targeted financial sanctions in compliance with the United Nations Security Council Resolutions (“UNSC Resolutions”), pursuant to the United Nations Sanctions Ordinance (Cap. 537) (“UNSO”) (its 12 subsidiary regulations) and the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575) (“UNATMO”).
Hong Kong does not implement sanctions above and beyond those imposed by the United Nations Security Council (“UNSC”). The Security Bureau maintains lists of designated individuals and entities under the UNATMO, which covers the UNSC Resolution 1373 relating to terrorism financing, while the Commerce and Economic Development Bureau (“CEDB”) maintains list of designated individuals and entities under the UNSO.
Before engaging in a business relationship or providing legal advice, members should ensure that they do not deal with designated individuals and entities sanctioned by the UNSC. Members are required to screen the names of their clients, their representatives, beneficial owner(s) and connected parties against the names (and aliases) of designated individuals and entities on a risk sensitive basis.
The Hong Kong Government or its regulators, including the Law Society, do not issue or maintain any form of sanctions or designated individuals and entities list but they do have a supervisory role within the targeted financial sanctions regime in relation to firms’ systems and controls for complying with these legal requirements.
Sanctions imposed by foreign governments do not form part of the international targeted financial sanctions regime and have no legal status in Hong Kong. As a result, firms in Hong Kong are under no statutory obligation to comply with sanctions regimes implemented outside Hong Kong law. Nevertheless, firms must remain alert to the extraterritorial application of certain foreign sanctions regimes. Several major regimes — most notably those of the United States, the European Union, and the United Kingdom — extend their reach beyond national borders and can affect persons and businesses operating internationally. The U.S. regime is particularly far-reaching, but EU and UK measures also carry significant cross-border consequences.
It is therefore essential for firms to:
The three most common types of measures imposed by the UNSC, these are:
As of August 2022, there were 12 countries and two organisations whose designated persons were subject to sanctions or other restrictions.
Targeted financial sanctions are aimed at specifically named individuals, groups, undertakings and entities collectively referred to as “designated persons” and are measures for asset freezing and prohibitions to prevent funds or other assets from being made available, directly or indirectly, for the benefit of specified designated persons who are sanctioned.
In practice, sanctions restrictions mean that a legal practitioner cannot:
The Security Bureau maintains lists of terrorists and terrorist associates under the UNATMO, while the CEDB maintains list of designated individuals and entities under the UNSO. The Consolidated UNSC Sanctions List contains all names of designated individuals and entities in one document. All lists are regularly updated, therefore member firms and sole practitioners that do not utilise automatic screening solutions should regularly check for Sanctions updates and name screen against the most up to date Consolidated UNSC Sanctions List.
Please click here to access the lists:
Lists of persons and entities subject to financial sanctions under the United Nations Sanctions Ordinance, Chapters 537 and its subsidiary legislation, please click here.
United Nations (Anti-Terrorism Measures) Ordinance, Chapter 575 - names of persons designated as terrorists or terrorist associates by the Committees of the United Nations Security Council, please click here.
The Consolidated United Nations Security Council Sanctions List (includes all individuals and entities subject to sanction measures), please click here.
The Security Bureau notifies the respective regulators, including the Law Society of Hong Kong, of any changes to the UN Sanction Lists and of any updates to the list of terrorists and terrorist associates maintained under the UNAMTO.
Latest Updates to Lists of Designated Individuals and Entities
Members are legally obliged to report to the Joint Financial Intelligence Unit (“JFIU”) if they know or suspect that:
If, before providing legal services or during the relationship, a legal professional has identified a designated person or an association with such person or formed a suspicion that there may be a sanctions violation, they must:
Remember that even if you did not provide legal services and declined to act for the client, you are still required to report the case to JFIU. Not doing so is a criminal offence which may result in criminal prosecution or a monetary penalty.
Members should also consider submitting an STR to the JFIU if there is a suspicion of money laundering (“ML”), terrorist financing (“TF”) or proliferation financing (“PF”). There are offences under existing ML and TF laws that are relevant when dealing with sanctions-related matters:
| Legislation | Penalty |
|---|---|
| UNSO | Contravention of sanctions under the UNSO shall be punishable on conviction on indictment by an unlimited fine and imprisonment for a term not exceeding 7 years. |
| UNATMO | Contravention of the relevant provisions under the UNATMO shall be punishable on summary conviction by a fine of HKD100,000 and imprisonment for two years, or on conviction on indictment by an unlimited fine and imprisonment for 14 years. Section 12(1) of the UNATMO requires a person to report his knowledge or suspicion of terrorist property to an authorized officer (e.g. the JFIU). Failure to make a disclosure under this section constitutes an offence under section 14(5). The maximum penalty upon conviction of this offence is a fine of HK50,000 and imprisonment for three months. |
Commerce and Economic Development Bureau (Commerce, Industry and Tourism Branch)
The CEDB has overall responsibility in implementing the United Nations Sanctions in Hong Kong. Individuals or entities affected by targeted financial sanctions as a result of mistaken identification or confusion with individuals or entities on the relevant sanctions lists may submit written requests for clarification to the Commerce, Industry and Tourism Branch of CEDB, after requesting an explanation from the institution that froze the assets.
Contact Details:
23/F West Wing
Central Government Offices
2 Tim Mei Avenue Tamar
Hong Kong
Tel: 3655 5170
E-mail: citbenq@cedb.gov.hk
Trade and Industry Department
The Trade and Industry Department (“TID”) is responsible for implementing trade sanctions.
The TID maintains a list of circulars regarding the UNSO regulations related to trade. For details, please click here.
List of countries subject to United Nations Sanctions and scope of trade-related sanctions are available at the TID website, please click here.
Contact Details:
Tower 3 Concorde Road
Kowloon City
Hong Kong
Tel: 2392 2922
E-mail: enquiry@tid.gov.hk
| Disclaimer The contents are intended to provide a general guide to the subject matter only and should not be treated as a substitute for specific advice concerning individual situations. While every effort has been made to ensure the accuracy of the content provided, it does not constitute legal advice and cannot be relied upon as such. The Law Society does not accept responsibility for liabilities arising from reliance upon the content provided. |
