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Fluctuating overseas crude oil futures market attracts claims

On 24th April 2020, the SFC issued a circular to the managers of SFC-authorised exchange traded funds (ETFs) and intermediaries reminding them of staying "vigilant" in response to the extremely fluctuating overseas crude oil futures market situation in order that ETFs can be managed in the best interests of investors. The SFC also suggests tightening up certain internal control measures for the managers and intermediaries' reference (please see

While it is never too late to mend, some investors start recalling that they might not have received derivatives product training before they started to invest in derivatives. Some start arguing that their account executives might have misled them, solicited them to buy derivative products without performing proper risk-matching and/or suitability assessment. Regardless of whether these claims are true, tenable, well-substantiated or not, it should be worthwhile for every SFC licensed person to take urgent steps to conduct internal compliance review for verifying due compliance with the relevant requirements set out in the SFC Code of Conduct, in order to prevent this nightmare from happening.

If you wish to learn more about how to formulate and implement the relevant internal control and compliance policies, please visit or feel free to email your inquiry to We will get in touch with you shortly.

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