Online Shopping Scam in Hong Kong: Immediate Reporting and Recovery Steps

• Further payments: a “tax”, “deposit” or “unlock fee” may continue the same fraud; stopping further payment may avoid a larger loss.
• Payment-provider case: open a case with the sending bank, wallet or card issuer and obtain a case reference; the reference connects later follow-up.
• Report reference: a Police report reference is a different thing from an 18222 enquiry record (this site's summary).
• Original transaction evidence: the listing, URL, seller identifiers, full chat export, payment record, bank details and timestamps preserve more context than cropped images alone.
• Platform record: buyer-protection, refund and account-reporting routes are contractual; on-platform messages and the outcome may become evidence.
• Account security: reused passwords, an OTP, screen sharing or device access may expose other accounts; bank and platform security procedures are separate from recovery.

As at 24 August 2026, no provision in Hong Kong legislation makes a card issuer liable to a cardholder for a supplier’s misrepresentation or breach of contract (this site's summary). The card schemes’ own “chargeback” rules are contractual arrangements between issuer, acquirer and scheme, not law (this site's summary). By comparison, section 75 of the UK's Consumer Credit Act 1974 makes the creditor jointly and severally liable with the supplier to the debtor for the supplier’s misrepresentation or breach of contract, but section 75(3) excludes a claim so far as it relates to any single item with a cash price not exceeding £100 or more than £30,000 — so a UK buyer of a £60 item has no section 75 claim either (this site's summary).

• 18222: Police describe it as an all-day enquiry hotline giving immediate consultation to the public:

• A Police report: giving the Police the facts and obtaining a report record.
• Stop-payment/interception: an attempt by banks and Police to stop processing or preserve funds during or after transfer; success depends on timing and where the money is.
• Reimbursement/recovery: money is ultimately returned to the victim; this does not follow automatically from an “intercepted” or “averted-loss” statistic.

Official programmes use different measures. The Government reply of 15 June 2022 used “intercepted” for funds that could include payments already made to local or overseas banks. The 2026 Upstream Scam Intervention reply reported “loss averted” through prevention: from the scheme's start to March 2026, the Police prevented 7,987 fraud cases and averted over HK$780 million in losses. That is loss avoided, not money recovered after a payment was made. The former does not mean every payment was stopped before leaving; the latter is not a recovery rate. Neither proves final reimbursement to victims.

The latest annual figures published by the Police record 12,505 e-shopping fraud cases in 2025 (+946 cases, +8.2% on 2024), being 28.9% of all deception cases that year, which puts 2024 at 11,559. Total deception cases were 43,212 in 2025, down 2.9% on 2024 and the first decline after consecutive annual rises since 2019. See the Police review of the law and order situation in 2025 . For earlier comparison, 8,735 cases were recorded in 2022 and 8,950 in 2023: see the Government/Police reply of 14 February 2023 and the Government/Police reply of 6 February 2024 .

These are Police-classified reported cases for those calendar years; the 2024 figure is derived from the year-on-year change published for 2025, not separately published. They are not a second-hand-platform series, unique-victim count, total actual loss or successful-recovery count. They cannot establish an individual's recovery prospect and should not be mixed with—or divided into—Consumer Council complaint or Customs prosecution figures.

Sections 25 and 25A of the Organized and Serious Crimes Ordinance (Cap. 455) create offences, disclosure, consent and immunity machinery concerning suspected proceeds. A letter of no consent (LNC) is one mechanism used by Police and banks in that setting. It may help preserve suspect funds during investigation, but it does not decide ownership or mean a victim has been reimbursed (this site's summary).

Who brought this litigation. The three decisions below are stages of one case. At §2 of the Court of Final Appeal judgment, the Court records that the appellants had, since 2019, come under suspicion of the Securities and Futures Commission for having committed (with others) offences involving:

So the applicants in this line of litigation were account holders under investigation, not fraud victims. It decides what "the police froze the account" means in law; it decides nothing about whether a victim can get money back (this site's summary).

Court of Final Appeal, 2024. Tam Sze Leung v Commissioner of Police, FACV 7/2023, [2024] HKCFA 8 (Court of Final Appeal, 10 April 2024, on appeal from CACV 152/2022). At §§73–74 the Court distinguished the Police power to take lawful measures under section 10 of the Police Force Ordinance (Cap. 232) from the consent/immunity mechanism in OSCO s 25A(2)(a); at §§74, 81 and 99 it held that the bank freezes the account and Police action does not determine the customer's right to the funds; and that even if property rights had been engaged, the action would have been legally certain and proportionate (§§82–87) (this site's summary). The outcome is at §115:

Court of Appeal, 2023. The Court of Appeal stage of the same litigation is Tam Sze Leung and others v Commissioner of Police, CACV 152/2022, [2023] HKCA 537 (Court of Appeal, 14 April 2023, judgment delivered by G Lam JA, with a corrigendum of 31 May 2023). At §58:

The order is at §120:

At §121 there was an order nisi that the applicants pay the Commissioner's costs here and below, with a certificate for two counsel (this site's summary). What it does not decide: it does not decide whether a bank owes its own customer any duty — at §56 it sends that question to contract law (this site's summary).

Court of First Instance, 2015. Interush Limited and Interush (Singapore) Pte Limited v The Commissioner of Police and others, HCAL 167/2014 (Court of First Instance, Hon P. Li J, 5 August 2015). The judgment carries no neutral citation, so it is cited by action number and date. It records the Police internal guidelines:

So the six months is Police internal guidance, not a statutory deadline (this site's reading). The outcome:

All three applicants lost, and in all three the applicants were account holders under investigation, not victims (this site's summary). An LNC is not itself a restraint order issued by a court under Cap. 455 (this site's summary).

Even if money is preserved, return may still require a bank process, a restitution/compensation order in criminal proceedings, a civil judgment or enforcement. Neither Police involvement nor an LNC guarantees return.

Platform and Consumer Council

Platform buyer-protection, refund and account-reporting routes are contractual; in-platform records and outcomes may be evidence. Where the seller is a trader rather than a purely private seller, the Consumer Council may accept a complaint and attempt conciliation . Conciliation is not a judgment and cannot guarantee payment.

False trade descriptions and certain unfair trade practices by a trader are offences under sections 4, 5, 7, 7A, 13E, 13F, 13G, 13H and 13I of the Trade Descriptions Ordinance (Cap. 362) , which the Customs and Excise Department enforces (this site's summary). Section 36 is not one of those offence provisions: it is the section headed Actions for damages, and it lets a claimant who suffers loss or damage because of another person's conduct directed at the claimant recover that loss by action — but only where the conduct constitutes an offence under one of those nine sections and the other person is not an exempt person. Section 36(2) allows the action to be commenced within 6 years after the cause of action accrued, and section 36(3) makes a contract term purporting to exclude or restrict that right of no effect (this site's summary). Pleading and forum can turn on the statutory character of the claim. An amount below HK$75,000 does not by itself establish Small Claims Tribunal jurisdiction over a section 36 claim; a Hong Kong solicitor can advise on that issue.

Civil claims

If the correct defendant can be identified, contract, misrepresentation, deceit or another civil claim may apply. General public routing is: an eligible monetary claim within the Small Claims Tribunal Ordinance (Cap. 338) and up to HK$75,000 may go to that Tribunal; section 32 of the District Court Ordinance (Cap. 336) gives the District Court jurisdiction over an action founded on contract, quasi-contract or tort where the amount claimed does not exceed HK$3 million; that section sets no lower limit, so HK$75,000 is the Small Claims Tribunal ceiling in the Cap. 338 Schedule, not a District Court threshold (this site's summary). Larger claims generally proceed in the Court of First Instance. These are current amounts: Cap. 338 s 6 and Cap. 336 s 73A respectively permit the Legislative Council to amend the relevant Schedule/amounts by resolution. Claim type, remedy, identity and an address for service may change the forum. See the Judiciary's Small Claims Tribunal guide and District Court jurisdiction guide .

Two email-fraud judgments: what the courts actually ordered

[2020] HKCFI 1293. 800 Columbia Project Company LLC v Chengfang Trade Ltd and others, [2020] HKCFI 1293 (Court of First Instance, Mr Recorder Eugene Fung SC in Chambers (Open to Public), 24 June 2020; HCA 149/2020, 153/2020 and 156/2020). At §2(2) the court recites the plaintiff's pleaded case:

That US$5,697,724.42 is the plaintiff's pleaded case as recited by the court, not a finding after trial (this site's summary). The court gave default judgments for monetary and declaratory relief but refused the vesting orders. At §17:

At §18:

The same paragraph records that it remained open to the plaintiff to commence garnishee proceedings under RHC Order 49 to enforce the default judgments; costs were to the plaintiff (this site's summary).

[2023] HKDC 394. Flora Education Limited v Yuet Company Limited and another, [2023] HKDC 394 (District Court, Deputy District Judge Connie Lee, 23 March 2023; DCMP 3449/2022). The plaintiff was a Hong Kong company induced by emails impersonating its supplier to remit HK$329,449.46 and HK$7,537.55 — HK$336,987.01 in all — to the first defendant's bank account, which the Police later froze (this site's summary). At §20:

At §29:

The court granted the declaratory relief and the vesting order, and ordered the first defendant to pay the plaintiff's costs, with no order as to costs between the plaintiff and the bank (this site's summary).

This site's reading (the two read together): both judges faced the same practical problem — a defendant who will not comply — and they divided on whether section 52(1)(e) of the Trustee Ordinance (Cap. 29) is engaged. One held it was not, and noted that garnishee proceedings remained open; the other held it was, and made the order. The pair does not mean the money can be got out either way: the decision that refused decided nothing about whether garnishee proceedings would succeed. Neither is an online marketplace case; both are business email compromise, and in both the plaintiff was a company, not an individual consumer (this site's summary). Section 52 of Cap. 29 is stated here as those two judgments state it.

Winning does not guarantee collection. An unidentified defendant, no assets, overseas transfers or dissipation can frustrate enforcement. Freezing injunctions, garnishee proceedings and other enforcement measures are technical; their availability, cost and risk are fact-sensitive and ordinarily require individual legal assessment.

The Criminal Procedure Ordinance (Cap. 221) allows compensation and restitution orders in appropriate criminal cases. Section 73(3) may permit compensation to be paid from money taken from the convicted person or paid into court, while return of identified property can operate differently. It is therefore too broad to say every favourable order merely awaits separate enforcement.

A case in which compensation orders were actually made. [2024] HKDC 2003 (District Court, DCCC 962 and 1094/2021, 732/2022 and 93/2023 (consolidated), before District Judge 嚴舜儀, 1 November 2024). The judgment is in Chinese; the Reasons for Sentence record:

〈This site's rendering: between February 2019 and November 2019, D1, together with others of unknown identity, defrauded six victims of cash or cheque payments totalling $7,867,350.〉

D1 was convicted after trial on six counts of fraud and sentenced to 5 years 3 months in total; the court made a compensation order on each of the six counts, the six sums totalling $110,000 (this site's summary). Six victims lost $7,867,350 and the compensation orders came to $110,000. The scope of this case: it is a debt-restructuring and mortgage-loan fraud against six individuals, not an online marketplace case, and it is used here only for what a compensation order does and does not do (this site's summary).

But an order does not guarantee receipt. The offence, proven loss, applicable legislation, judicial discretion, money available under section 73(3) and later enforcement may all affect the result. Where a magistrate makes an order under section 98 of the Magistrates Ordinance (Cap. 227) , compensation is capped at HK$100,000 per aggrieved person; section 73 of Cap. 221 does not itself state that HK$100,000 ceiling. Those are the scopes of different statutory powers, not a prediction of recovery in any case.

Is calling 18222 the same as reporting to the Police?

No. Police describe 18222 as an all-day enquiry hotline giving immediate consultation to the public; an enquiry is not a report (this site's summary).

Can an FPS transfer always be recalled?

No. The sending bank can assess a stop/recall from the transaction details. Success depends on timing, availability of funds, the receiving institution and investigation. Interception is not final reimbursement.

Does Hong Kong law make a card issuer answerable for a seller's misrepresentation?

No. As at 24 August 2026, no provision in Hong Kong legislation makes a card issuer liable to a cardholder for a supplier's misrepresentation or breach of contract (this site's summary; see section 1 above). Contractual arrangements between an issuer and a card scheme are a separate matter; whether a refund is available depends on the issuer's terms and the scheme's rules.

Can Police simply return the money after my report?

Not necessarily. Investigation or an LNC may preserve funds but does not determine civil ownership and does not reimburse automatically; at §58 of [2023] HKCA 537 the Court of Appeal went further and held that the police have no power to require the bank to do anything. Return may require a bank process, criminal order, civil judgment or enforcement (this site's summary).

Should I pay a company that guarantees recovery?

The Police ADCC provides an official anti-scam consultation channel. A promise of guaranteed recovery does not establish authenticity.

HKGoodLawyer provides general legal-document explanation and lawyer referral. It is not a law firm, does not provide legal advice and does not guarantee recovery or an outcome. Formal Police reporting, payment-provider procedures and individual deadlines remain matters for the relevant agency or an independent Hong Kong solicitor.

Platform terms, bank responses and court papers may contain identity-card numbers, addresses, bank/card numbers, signatures, Police report references, login details and third-party personal information; passwords and one-time passcodes are especially unsuitable for disclosure to any document service. A referral is only a route to locating an independent Hong Kong solicitor; engagement and scope are agreed separately with that solicitor.

Legislation consolidation versions: the Hong Kong e-Legislation texts cited in this article are Cap. 338 (28 March 2025), Cap. 232 (24 August 2025), Cap. 455 (19 September 2025), Cap. 336 (18 August 2024), Caps. 221 and 227 (14 May 2026), and Cap. 362 (24 August 2026).

• Hong Kong Police ADCC and 18222
• [Tam Sze Leung v Commissioner of Police, FACV 7/2023, [2024] HKCFA 8 (Court of Final Appeal, 10 April 2024)](https://www.hklii.hk/en/cases/hkcfa/2024/8)
• [Tam Sze Leung and others v Commissioner of Police, CACV 152/2022, [2023] HKCA 537 (Court of Appeal, 14 April 2023)](https://www.hklii.hk/en/cases/hkca/2023/537)
• Interush Limited and Interush (Singapore) Pte Limited v The Commissioner of Police and others, HCAL 167/2014 (Court of First Instance, 5 August 2015; the document as served carries no neutral citation)
• [800 Columbia Project Company LLC v Chengfang Trade Ltd and others, [2020] HKCFI 1293 (Court of First Instance, 24 June 2020)](https://www.hklii.hk/en/cases/hkcfi/2020/1293)
• [Flora Education Limited v Yuet Company Limited and another, [2023] HKDC 394 (District Court, 23 March 2023)](https://www.hklii.hk/en/cases/hkdc/2023/394)
• [2024] HKDC 2003 (District Court, 1 November 2024; the judgment is in Chinese)
• Criminal Procedure Ordinance (Cap. 221)
• Consumer Council complaint and conciliation service