Intermediary charged by ICAC convicted of conspiracy to defraud over clients’ false early MPF withdrawals
2026-10-22
The ICAC earlier charged a Mandatory Provident Fund (MPF) intermediary with colluding with clients to apply for the early withdrawal of MPF totalling about $4.6 million using false statutory declarations and supporting documents. The intermediary was convicted of conspiracy to defraud and using false instruments at the District Court today (October 22). Three of his clients had previously pleaded guilty to their roles in the scam.
Wong Kam-fai, 37, an MPF intermediary and then insurance agent of FWD Life Insurance Company (Bermuda) Limited (FWD), was found guilty after trial of four counts of conspiracy to defraud and two counts of using a false instrument, contrary to the Common Law and section 73 of the Crimes Ordinance.
Mak Kwok-pui, Ngan Hon-wai and Li Chi-kwan, aged between 52 and 53, the three clients involved, had earlier pleaded guilty to a total of one count of conspiracy to defraud and three counts of using a false instrument.
Deputy Judge Mr Jason Wan Siu-ming adjourned the case to November 5 for mitigation and remanded Wong in the custody of the Correctional Services Department. The case was set for sentencing on November 26.
The investigation arose from corruption complaints filed with the ICAC alleging that MPF intermediaries had accepted bribes to assist MPF scheme members in making false statements to apply for the early withdrawal of their MPF, leading to the prosecution of the four defendants.
The court heard that at the material time, Wong was an FWD insurance agent and an MPF intermediary. Between July 2021 and November 2022, Wong helped multiple clients open MPF accounts with Sun Life Trustee Company Limited (Sun Life), transfer their MPF to Sun Life, and subsequently apply for early withdrawal.
Sun Life is an MPF trustee in Hong Kong. Under a strategic partnership between FWD and Sun Life, insurance agents of FWD would promote Sun Life’s MPF schemes.
MPF scheme members who apply for the early withdrawal of their MPF on the grounds of “permanent departure from Hong Kong” are required to submit statutory declarations and supporting documents such as tenancy agreements or employment proof in their destinations of relocation to their MPF trustees.
Wong had conspired with various clients to falsely represent to Sun Life that those clients intended to relocate to the Chinese Mainland and permanently leave Hong Kong, thereby deceiving Sun Life into approving their applications for the early withdrawal of MPF. However, the ICAC investigation revealed that these clients had never migrated to the Chinese Mainland and had no intention of doing so.
Wong and some of the clients also used false instruments to apply for the early withdrawal of MPF. These false instruments included statutory declarations purportedly signed before a solicitor and an employment agreement. ICAC enquiries revealed that the solicitor had never administered any declarations for the clients involved while the client had never been employed by the Chinese Mainland employer concerned.
Wong successively assisted several clients in illegally making early MPF withdrawals, accepting from each of them fees ranging from several thousand to tens of thousands of dollars. The ICAC has applied to the court for an order to confiscate Wong’s crime proceeds, pending scheduling by the court.
The MPF Schemes Authority, FWD and Sun Life rendered full assistance to the ICAC during its investigation into the case.
The prosecution was today represented by prosecuting counsel Thomas Iu, assisted by ICAC officers Michael Lim and Jenny Chan.
Wong Kam-fai, 37, an MPF intermediary and then insurance agent of FWD Life Insurance Company (Bermuda) Limited (FWD), was found guilty after trial of four counts of conspiracy to defraud and two counts of using a false instrument, contrary to the Common Law and section 73 of the Crimes Ordinance.
Mak Kwok-pui, Ngan Hon-wai and Li Chi-kwan, aged between 52 and 53, the three clients involved, had earlier pleaded guilty to a total of one count of conspiracy to defraud and three counts of using a false instrument.
Deputy Judge Mr Jason Wan Siu-ming adjourned the case to November 5 for mitigation and remanded Wong in the custody of the Correctional Services Department. The case was set for sentencing on November 26.
The investigation arose from corruption complaints filed with the ICAC alleging that MPF intermediaries had accepted bribes to assist MPF scheme members in making false statements to apply for the early withdrawal of their MPF, leading to the prosecution of the four defendants.
The court heard that at the material time, Wong was an FWD insurance agent and an MPF intermediary. Between July 2021 and November 2022, Wong helped multiple clients open MPF accounts with Sun Life Trustee Company Limited (Sun Life), transfer their MPF to Sun Life, and subsequently apply for early withdrawal.
Sun Life is an MPF trustee in Hong Kong. Under a strategic partnership between FWD and Sun Life, insurance agents of FWD would promote Sun Life’s MPF schemes.
MPF scheme members who apply for the early withdrawal of their MPF on the grounds of “permanent departure from Hong Kong” are required to submit statutory declarations and supporting documents such as tenancy agreements or employment proof in their destinations of relocation to their MPF trustees.
Wong had conspired with various clients to falsely represent to Sun Life that those clients intended to relocate to the Chinese Mainland and permanently leave Hong Kong, thereby deceiving Sun Life into approving their applications for the early withdrawal of MPF. However, the ICAC investigation revealed that these clients had never migrated to the Chinese Mainland and had no intention of doing so.
Wong and some of the clients also used false instruments to apply for the early withdrawal of MPF. These false instruments included statutory declarations purportedly signed before a solicitor and an employment agreement. ICAC enquiries revealed that the solicitor had never administered any declarations for the clients involved while the client had never been employed by the Chinese Mainland employer concerned.
Wong successively assisted several clients in illegally making early MPF withdrawals, accepting from each of them fees ranging from several thousand to tens of thousands of dollars. The ICAC has applied to the court for an order to confiscate Wong’s crime proceeds, pending scheduling by the court.
The MPF Schemes Authority, FWD and Sun Life rendered full assistance to the ICAC during its investigation into the case.
The prosecution was today represented by prosecuting counsel Thomas Iu, assisted by ICAC officers Michael Lim and Jenny Chan.