Calvin To

Calvin advises financial institutions, listed companies, cryptocurrency exchanges and their senior management on regulatory compliance, reporting, investigation and enforcement matters.

These include matters in relation to the Hong Kong Securities and Futures Ordinance and its subsidiary legislation, the Listing Rules and director undertakings, anti-money laundering and counter-terrorist financing (AML/CFT) and virtual asset-related regulations, insurance laws and internal investigations.

Calvin has helped clients in connection with multiple cross-border matters covering Hong Kong, Mainland China, Singapore, South Korea, Japan, Australia, India, Indonesia, Malaysia, the United States and the United Kingdom.

Calvin has also assisted financial industry bodies to respond to regulatory reform initiatives and publications, including ASIFMA and AIMA.

Prior to joining Herbert Smith Freehills, Calvin worked at the Hong Kong Securities and Futures Commission (SFC) as an investigator of the Enforcement Division, where he investigated suspected cases of market misconduct and breaches of the Securities and Futures Ordinance, subsidiary legislation, codes, guidelines and circulars.

He also worked at the Listing Enforcement Department within the Listing Division of the Hong Kong Stock Exchange (HKSE), where he investigated and prosecuted possible breaches of the Listing Rules.

Calvin's experience includes advising:

• one of the largest cryptocurrency exchanges in the world on the SFC's investigation in relation to alleged unlicensed regulated activities
• an American multinational investment bank on compliance with the conflicts of interest requirements under the SFC's Code of Conduct
• a Japanese global investment bank on compliance issues with the Securities and Futures (Short Position Reporting) Rules
• a Chinese apparel company dual listed in Hong Kong and Shanghai on the HKSE's investigation in relation to possible breaches of the Listing Rules regarding connected transactions
• a former director of a Chinese gaming company listed in Hong Kong on the HKSE's investigation in relation to possible breaches of the director's duties and undertaking
• a French international banking group on its compliance with AML/CFT laws and regulations in relation to its payment service providers
• a multinational banking and financial services company in connection with cross-border enquiries by the Hong Kong, Australian and United States regulators
• one of the largest mobile phone manufacturers on the compliance of its extended warranty and technical support plans with insurance laws