On 12 January 2026 Steve Vickers and Associates (“SVA”) issued a Risk Advisory Bulletin to clients and selected media outlets as to key risks associated with initial public offerings (“IPOs”) in Hong Kong.

That bulletin noted that Hong Kong’s IPO market had experienced a major resurgence in 2025, but that, while the benefits of the surge have been immense, dangers have grown, as not all listings are of the same quality.

In particular, SVA noted that due diligence standards had slipped in the rush to market, and some parties had simply relied on AI-assisted prospectuses, and the work of less experienced staff members.

Now, sadly events suggest that some market participants have been engaged in insider trading, raising further concerns.

Action by the authorities

On 30 January 2026 Hong Kong’s Securities and Futures Commission (“SFC”) issued a formal directive tackling “serious deficiencies in the preparation of some listing documents”. The SFC also suspended the vetting of 16 IPO applications, and required 13 as-yet-unnamed sponsors to conduct comprehensive internal reviews.

Then, in apparently unconnected action, on 12 March 2026, Hong Kong’s Independent Commission Against Corruption (“ICAC”), acting in concert with the SFC, arrested eight people reportedly linked to CITIC Securities (中信证券), Guotai Junan International
(國泰君安國際) and a hedge fund Infiniti Capital (無極資本). The arrests are reported to relate to alleged corruption and insider dealing.

This latest case is as yet unresolved, and no doubt further information will emerge in due course. In the interim, though, SVA would note that such developments underline, once again, the need for careful investigative due diligence in relation to IPOs, and also for measures aimed at protecting corporate interests and proactive fraud investigations into malfeasance.

SVA current market posture

As noted previously, in response to client demand, SVA has recently expanded its investigative due diligence offering for sponsors, underwriters, custodians, legal service providers, accountants, investors, and others in the IPO process. These services seek to protect businesses against just such risks as those outlined above.

SVA personnel have many years of expertise in conducting IPO investigative due diligence and in providing services, which can help key parties understand the real-life nature of listing companies, and which can mitigate the reputational, compliance, and integrity risks.

With regard to difficult insider trading issues, SVA also has a great deal of experience in handling corporate investigations, by assisting in responses to misconduct by staff, including by conducting: fraud investigations; staff defection and disclosure of confidential information inquiries; and data forensic assessments.

Please see attached details about relevant services in further detail:

• IPO & Reverse Takeover Investigative Due Diligence Services.
• Investigative Due Diligence Services.
• Corporate Investigations.

SVA (www.stevevickersassociates.com) is a specialist risk mitigation, corporate intelligence and risk consulting company. The firm serves financial institutions, private equity funds, corporations, high net-worth individuals and insurance companies and underwriters around the world.