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The Letter of No Consent: what the regime is, how long it runs, and why this one needs counsel

Current to 26 August 2026 · updates land in the changelog.

A Letter of No Consent is not a bank decision. Under Hong Kong's no-consent regime, police (via the JFIU) indicate to the bank that they do not consent to dealings with funds in an account — typically one that received money reported as fraud proceeds. The bank, facing money-laundering exposure if it moves the funds, freezes. The customer is dealing with a police posture wearing a banking face.

The regime survived its constitutional test

In Tam Sze Leung v Commissioner of Police [2024] HKCFA 8 (10 April 2024), the Court of Final Appeal unanimously upheld the LNC regime as lawful. The challenge era is over: recourse now runs through the specific case, not the regime's validity.

The clock

An LNC generally lasts no more than 6 months, with monthly police reviews — a freeze with a rhythm. Those reviews are where representations land: evidence of legitimate source and entitlement, made by counsel, at the points the system is designed to reconsider.

The recourse routes — all of them counsel work

• Representations / negotiation with police and the JFIU at the review points.
• Judicial review of the specific decision — the post-Tam route.
• Civil proceedings around the funds and competing claims.

This page deliberately contains no templates: any LNC, police or JFIU contact, restraint order, fraud-victim claim on the funds, personal suspicion, or sanctions nexus is a hard hand-off to a lawyer. What a document pack legitimately does here is preparatory: organising the genuine records counsel will need on day one — account history, source evidence, the paper trail of the funds in question.

What to do while counsel works

Keep every bank letter and date; do not move adjacent funds in ways that look responsive to the freeze; keep operating through unaffected accounts; and if the underlying event was a scam that touched your account, report your own position promptly — the record of when you learned matters.

Quick answers

How long does a Letter of No Consent freeze last in Hong Kong?

Generally no more than 6 months, with monthly police reviews — the review points are where evidence-backed representations are made, through counsel.

Can the LNC regime itself be challenged?

The Court of Final Appeal unanimously upheld the regime in Tam Sze Leung v Commissioner of Police [2024] HKCFA 8. Recourse now targets the specific decision — judicial review, representations, civil routes — not the regime's lawfulness.

Can I handle an LNC with template letters?

No. An LNC involves police decision-making and potential court applications — counsel work. The legitimate self-help portion is organising genuine records so counsel starts fast.

General information and document templates only — not legal advice. Organise genuine records only: never alter, backdate or fabricate a document — regulators apply zero tolerance and an honest gap explained is survivable where a fabricated paper is not. Anything involving police, the JFIU, a Letter of No Consent, restraint orders, personal suspicion or a sanctions nexus belongs with counsel, not templates. Sources are the HKMA, the Code of Banking Practice, SFC circulars, FDRC terms and case law as cited, plus our audited kit research. © 2026 Kilde.

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