Hong Kong Law Society’s Practice Direction P
Guidelines on Anti-Money Laundering and Terrorist Financing


1.    On 26 June 2008, the Privacy Commissioner for Personal Data, at the request of the Law Society of Hong Kong, endorsed the practice of solicitors’ collection of copies of their clients’ identification documents pursuant to para. 86 of the Law Society’s Practice Direction P (Guidelines on Anti-Money Laundering and Terrorist Financing).  The endorsement was made by the Privacy Commissioner in accordance with Clause 3.2.2.2 in the Code of Practice on Identity Card Number & Other Personal Identifiers.

2.    Following the endorsement, there have been concerns among solicitors as to how and under what circumstances the Privacy Commissioner’s endorsement applies.  To address such concerns, the Privacy Commissioner wrote a letter to the Law Society on 14 August 2008 in which he stated the rationale behind his endorsement and the proper scope of its application.  The letter can be downloaded from here.




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