When police announced the first arrests in the Fun Coffee case at the start of August, reported losses stood at HK$94 million across 225 reports. Ten days later, the Commercial Crime Bureau put it at HK$113 million across 273 reports. That gap is the part worth paying attention to.
On the police account of it, Fun Coffee was sold as a Vietnamese coffee venture, complete with talk of high-tech equipment and “coffee gene optimisation”. Investors bought packages through an app and were paid in USDT, with the top tier promising roughly a 278% annualised return. Authorities arrested six people aged 51 to 64 in Hong Kong on suspicion of conspiracy to defraud, and two more in Macau. Victims came forward slowly, as they do in most investment fraud, and by then the money had moved.
If you have been hit by a crypto scam in Hong Kong, or your bank account has been frozen because scam proceeds passed through it, here is what actually happens next.
How these scams work
Four patterns account for most of what we see.
First, the long con, which is the biggest by value. Someone builds a relationship over weeks or months, through a dating app or a WhatsApp group, then introduces an investment. Police recorded 25 romance scams in the single week of 24 to 30 July this year, with combined losses close to HK$70 million. The largest was a woman in her 50s who sent about HK$26 million over six months, with roughly HK$22 million of it into mule accounts. The app she was shown displayed gains of more than 800%.
Fake platforms are the second. The balance goes up, and the problem appears only at withdrawal, when fees kick in: a tax, an unlock deposit, an “anti-money-laundering verification” payment. Each one is the same scam continuing. If you want the warning signs before money moves, we have written about the red flags worth checking first.
Impersonation of genuinely licensed platforms is the third, and it is the one most likely to catch a careful investor. On 28 July 2026, the SFC added four fraudulent websites to its list of suspicious virtual asset trading platforms after DFX Labs, an SFC-licensed platform, reported that they were impersonating its own site. On 14 August 2026, the SFC published a much longer batch of lookalike domains tied to the HashKey name. A licence protects you only if you reach the licensed platform. Check the SFC’s list rather than a link you were sent.
Fourth and finally, the proceeds of the scam are layered through ordinary Hong Kong accounts: an OTC trader, a small business that took a payment, someone who sold a car. That last group never invested in anything, and it produces the call we take most often.
The frozen account, and what a “letter of no consent” actually is
Once a bank knows or suspects that funds represent the proceeds of an indictable offence, section 25A of the Organized and Serious Crimes Ordinance (Cap. 455) (the “OSCO”) requires it to disclose that knowledge or suspicion. In practice that means filing a suspicious transaction report with the Joint Financial Intelligence Unit.
Under section 25A(2), continuing to deal with the property after disclosure is only a defence to a money laundering charge if the authorized officer consents to the dealing before it takes place. If consent is withheld, the authorized officer issues what is commonly known in practice as a “letter of no consent”. The bank, facing potential liability under section 25 for dealing with property it knows or has reasonable grounds to believe is tainted, then chooses not to process the transaction or release the funds.
Notice who actually takes that step. The bank does. Neither “freeze” nor “letter of no consent” appears in the statutory text of section 25 or section 25A of the OSCO. Both are terms of practice, not of law. That distinction can sound like a technicality, until you try to challenge the restriction on your account.
The lawfulness of the regime is now settled, and not in account holders’ favour. In Tam Sze Leung v Commissioner of Police, the Court of First Instance held in late December 2021 that the “no consent regime”, as operated, was unlawful. The Court of Appeal reversed that in April 2023, upholding the regime’s validity, and the Court of Final Appeal dismissed the final appeal on 10 April 2024, [2024] HKCFA 8, affirming the legality and constitutionality of issuing letters of no consent. Any guide telling you the regime has been struck down predates that judgment.
What that leaves is uncomfortable but manageable. Sections 25 and 25A of the OSCO do not prescribe any statutory time limit on how long a letter of no consent may remain in effect, nor any statutory right of appeal or prescribed application procedure for seeking its withdrawal. In practice, an investigating officer needs to understand where your money came from. Most releases we have handled came from properly documenting the source of funds and engaging early, not from litigation. Judicial review remains available in principle, but after the Court of Final Appeal’s ruling upholding the regime’s constitutionality, the grounds for a successful challenge are narrow, and the process is expensive.
There is a second risk innocent account holders rarely see coming. Section 25(1) of the OSCO catches anyone who deals with property while knowing or having reasonable grounds to believe that it represents the proceeds of an indictable offence, and “reasonable grounds to believe” is assessed objectively, by reference to what a reasonable person would have concluded from the facts known to the account holder, not by reference to the account holder’s own state of mind. You can be a victim of one scam and a suspect in another. If an officer starts asking why you accepted HK$400,000 from someone you had never met, that is the point to call a criminal defence lawyer rather than the point to explain yourself.
The first 48 hours
Report it properly. The Anti-Scam Helpline 18222 runs around the clock, but the ADCC is explicit about what it is: “The hotline only provides consultation services. If you suspect that you have fallen prey to a scam, please report the case at the nearest police station. For emergency, dial 999.” You can also file through the Police e-Report Centre using its “Report Technology Crime and Deception” form. A call to 18222 alone is not a crime report, and people lose days on that.
If money left by bank transfer, call your own bank the same day. Speed is the one variable you control. Police intervened in 4,060 deception cases in 2025 and intercepted about HK$480 million, and interception works in hours, not weeks.
Preserve evidence before it disappears. Screenshot the app and the balance now, because these platforms go dark quickly. Keep the transaction hashes and receiving wallet addresses, which are where any tracing work starts, along with the chat history, transfer records, the names and account numbers you paid, and the URL you used.
Then stop paying. If the platform wants a fee to release your funds, that fee is the scam. The same goes for anyone offering to recover your money for an upfront payment, a well-established second wave aimed at people who have already lost once.
Who actually does what
Victims lose weeks writing to the wrong body. The police investigate, and they are the only route to a freeze on a receiving account.
The SFC regulates licensed platforms and publishes warnings, including the Alert List and the list of suspicious virtual asset trading platforms. It does not investigate your individual loss and cannot recover your money.
The HKMA supervises banks and, under the Stablecoins Ordinance (Cap. 656), licensed stablecoin issuers. If your complaint is about how a bank handled your account, the HKMA is relevant. If it is about a scam platform, it is not the right door.
Civil recovery: what is possible, and what usually is not
Hong Kong law is in better shape here than most people expect. In Re Gatecoin Ltd (in liquidation) [2023] HKCFI 914, Linda Chan J held that cryptocurrency is property under Hong Kong law and can be held on trust. That opens the door to proprietary injunctions over traceable assets, Mareva injunctions to stop dissipation, and Norwich Pharmacal and Bankers Trust disclosure orders against banks and exchanges to identify who is behind a wallet.
Now the honest part.
These orders are expensive, usually sought urgently and without notice, and the courts hold applicants to a demanding standard. In Wang Weiqing v Zhuo Yihao [2025] HKCFI 4941, the Court of First Instance discharged proprietary and Mareva injunctions obtained over an exchange’s wallet, on grounds including material non-disclosure at the without-notice stage. The court did grant a Bankers Trust order compelling the exchange to hand over account information, which is the more useful half of that judgment. Its practical observation is worth carrying too: it is often more productive to work with an exchange than to go straight to a without-notice application against it.
Three constraints apply to nearly every case. Funds pooled in an exchange’s omnibus wallet are harder to trace than funds in a private wallet. A freezing injunction requires an undertaking in damages, so you need assets to back it. And most exchanges holding the money are offshore, so a Hong Kong order may need recognition elsewhere before it does anything.
The cheap routes do not fit either. The Small Claims Tribunal is capped at HK$75,000 and allows no legal representation, which makes it useless against an unknown defendant behind a foreign wallet.
The same liquidation carries a warning the summaries leave out. When the court came to distribution in Re Gatecoin Ltd (in liquidation) [2025] HKCFI 493, customers who had accepted the exchange’s 2018 terms and conditions ranked as unsecured creditors, while those who had not kept a proprietary interest. Just because cryptocurrency is property does not mean your cryptocurrency is yours.
Recovery works best when the money is still identifiable, when it landed somewhere with a name attached, and when you moved in days rather than months. Any lawyer promising more than that at a first meeting is worth a second look.
If you run a platform or a fintech
Sections 25 and 25A of the OSCO apply to businesses and their staff, not only to banks. Handling proceeds with reasonable grounds to believe what they are carries up to 14 years on indictment, and tipping off a customer that a report has been made is itself an offence under section 25A(5). Operating a virtual asset service business without the required licence is an offence under section 53ZRD of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
Three things are worth doing now. Work through SFC circular 26EC35 of 9 July 2026 on protecting clients against phishing, which sets a compliance deadline of 8 July 2027 and is not a small piece of work. Monitor for domains impersonating your brand and report them to the SFC, as DFX Labs did in July. And settle your process for responding to police enquiries before the first one arrives.
If you are in dealing, custody, advisory or asset management, the consultations have concluded, and the government has said it intends to legislate. No deeming arrangement has been proposed, so expect a hard commencement date rather than a grace period. If you would rather get ahead of that, we can review your regulatory position now.
When to get a lawyer involved
Call someone the same week if your account has been frozen and the bank will not say why, if police have asked to interview you about funds that passed through your account, if you have lost enough that an urgent injunction is proportionate, or if you have traced where the money went and it is still sitting there.
The cases that end well are almost always the ones where someone moved early.
Been scammed, or had an account frozen? TITUS acts for individuals dealing with frozen accounts and crypto fraud losses, and for platforms and fintechs that want their compliance position reviewed before a regulator or a police officer asks. Contact us for a confidential consultation.
Disclaimer
If you suspect you have been the victim of fraud or a crypto-related scam, contact the Hong Kong Police Force’s Anti-Deception Coordination Centre on 18222 without delay. This article is for general information only and does not constitute legal advice on any specific case. If your assets or accounts are at risk, seek qualified Hong Kong legal advice as soon as possible, because time is often critical in asset-recovery matters.
This article reflects our understanding of the position under Hong Kong law and applicable regulatory guidance as at 21 August 2026. The regulatory framework for virtual assets continues to develop and is subject to change.