Regulatory Disclosures

1. Corporate Information

1.1 Company Details

Admiralty Capital Limited is a private company limited by shares, incorporated and registered in the Hong Kong Special Administrative Region.

Company Name: Admiralty Capital Limited
Company Number: 2427888
Registered Office: Central, Hong Kong
Date of Incorporation: 15 September 2016
Jurisdiction of Incorporation: Hong Kong SAR

1.2 Nature of Business

Admiralty Capital Limited operates as a principal investor and lender, providing bespoke financing solutions to qualified corporate clients, institutional investors, and sophisticated parties globally. Our services include:

  • Asset-backed lending and financing
  • Structured finance and credit facilities
  • Trade and commodity finance
  • Working capital solutions
  • Bridge financing and mezzanine capital
  • Real estate and property financing
  • Special situations and restructuring finance

1.3 Corporate Structure

Admiralty Capital Limited operates both directly and through its affiliated entities and special purpose vehicles established in various jurisdictions to facilitate specific transactions and structures.

2. Regulatory Status and Licensing

2.1 Hong Kong Regulatory Framework

Admiralty Capital Limited conducts its business activities as a principal, deploying its own capital and that of its affiliated entities. Our activities are structured to fall outside the scope of "regulated activities" as defined under the Securities and Futures Ordinance (Cap. 571) of Hong Kong ("SFO").

Specifically, we do not:

  • Deal in securities (Type 1 regulated activity)
  • Deal in futures contracts (Type 2 regulated activity)
  • Provide automated trading services (Type 7 regulated activity)
  • Provide securities margin financing (Type 8 regulated activity)
  • Provide asset management services (Type 9 regulated activity)
  • Provide credit rating services (Type 10 regulated activity)

2.2 Money Lending

To the extent any of our financing activities constitute money lending under the Money Lenders Ordinance (Cap. 163) of Hong Kong, such activities are conducted in compliance with the requirements of that Ordinance or are exempt therefrom by virtue of the applicable exemptions.

2.3 Investment Advice

We do not provide investment advice or recommendations. Any information provided by us regarding potential transactions is for informational purposes only and should not be construed as a recommendation to enter into any transaction. You should seek independent professional advice before making any investment or financing decisions.

2.4 No Fund Management

We do not manage funds, investment portfolios, or assets on behalf of third parties. All capital deployed is proprietary capital or capital from affiliated entities that are not collective investment schemes.

2.5 Regulatory Oversight

While our principal investing and lending activities may not require specific licensing under Hong Kong's financial regulatory regime, we operate with full regard to:

  • The Companies Ordinance (Cap. 622)
  • The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
  • The Personal Data (Privacy) Ordinance (Cap. 486)
  • The Trade Descriptions Ordinance (Cap. 362)
  • Other applicable laws and regulations

3. Geographic Scope and Restrictions

3.1 Intended Audience

The information on this website and our services are intended for sophisticated corporate clients, institutional investors, qualified investors, and professional parties who meet the applicable eligibility requirements in their respective jurisdictions.

3.2 Geographic Restrictions

The information contained on this website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation or which would subject Admiralty Capital Limited to any registration or licensing requirement within such jurisdiction or country.

3.3 United States

This website and its contents are not directed at, and are not intended for distribution to or use by, any person who is a resident of, or is located in, the United States of America (including its territories and possessions), any state of the United States, or the District of Columbia (collectively, the "United States" or "U.S.").

Nothing on this website constitutes:

  • An offer to sell, or a solicitation of an offer to purchase, any securities in the United States
  • An offer or solicitation to any U.S. Person as defined under Regulation S of the U.S. Securities Act of 1933
  • An offer of services that requires registration under U.S. federal or state securities laws

3.4 European Union and European Economic Area

This website is not directed at retail clients in the European Union or European Economic Area. Where we conduct business with parties in EU/EEA member states, we do so in compliance with applicable local requirements and only with eligible counterparties or professional clients.

3.5 Other Restricted Jurisdictions

We do not provide services to persons or entities located in, organized under the laws of, or controlled by persons in, jurisdictions that are subject to comprehensive economic or financial sanctions programs, including but not limited to:

  • North Korea
  • Iran
  • Syria
  • Cuba
  • The Crimea, Donetsk, and Luhansk regions
  • Other jurisdictions subject to comprehensive OFAC, UN, EU, or UK sanctions

3.6 Local Law Compliance

Persons who access this website from jurisdictions other than Hong Kong do so on their own initiative and are responsible for compliance with local laws. If you are in doubt about your eligibility to access this website or use our services, you should seek independent legal advice.

4. Anti-Money Laundering and Counter-Terrorist Financing

4.1 Commitment to AML/CTF Compliance

Admiralty Capital Limited is fully committed to preventing money laundering, terrorist financing, and other financial crimes. We maintain comprehensive Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) policies and procedures that meet or exceed the requirements of Hong Kong law and international standards.

4.2 Regulatory Framework

Our AML/CTF program is designed to comply with:

  • The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) ("AMLO")
  • The Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405)
  • The Organized and Serious Crimes Ordinance (Cap. 455)
  • The United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575)
  • Guidelines issued by relevant Hong Kong authorities
  • Financial Action Task Force (FATF) Recommendations
  • Relevant international standards and best practices

4.3 Know Your Customer (KYC) Procedures

All prospective clients, counterparties, and business relationships are subject to our comprehensive KYC due diligence procedures, which include:

  • Identity Verification: Verification of the identity of individuals and legal entities using reliable, independent source documents, data, or information.
  • Beneficial Ownership: Identification and verification of beneficial owners and controllers of legal entities and arrangements.
  • Purpose and Nature of Business: Understanding the intended purpose and nature of the business relationship.
  • Source of Funds: Verification of the source of funds and wealth to be used in the business relationship.
  • Ongoing Monitoring: Continuous monitoring of business relationships and transactions to ensure they remain consistent with our knowledge of the client.

4.4 Enhanced Due Diligence

We apply enhanced due diligence measures for:

  • Politically Exposed Persons (PEPs) and their family members and close associates
  • High-risk jurisdictions identified by FATF or other relevant bodies
  • Complex ownership structures or unusual transaction patterns
  • Correspondent relationships
  • Other situations presenting elevated money laundering or terrorist financing risks

4.5 Sanctions Compliance

We maintain robust sanctions screening procedures to ensure compliance with:

  • United Nations Security Council sanctions
  • United States (OFAC) sanctions
  • European Union sanctions
  • United Kingdom sanctions
  • Hong Kong's implementation of UN sanctions
  • Other applicable sanctions regimes

All clients, counterparties, and transactions are screened against relevant sanctions lists before onboarding and on an ongoing basis.

4.6 Reporting Obligations

We comply with all applicable reporting obligations, including the filing of Suspicious Transaction Reports (STRs) with the Joint Financial Intelligence Unit (JFIU) of Hong Kong where required.

4.7 Record Keeping

We maintain records of all customer identification information, account files, and business correspondence for at least seven years after the termination of the business relationship, or for such longer period as required by law.

4.8 Training and Awareness

All staff receive regular training on AML/CTF requirements, including recognizing and reporting suspicious activities. We maintain an up-to-date training program that reflects changes in regulations, typologies, and best practices.

4.9 Independent Testing

Our AML/CTF program is subject to periodic independent review to ensure its effectiveness and compliance with applicable requirements.

5. Data Protection and Privacy

5.1 Commitment to Data Protection

Admiralty Capital Limited is committed to protecting the privacy and security of personal data in accordance with applicable data protection laws and regulations.

5.2 Applicable Regulations

We comply with:

  • The Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO")
  • The Data Protection Principles contained in Schedule 1 of the PDPO
  • Applicable data protection laws in other jurisdictions where we operate
  • Industry standards and best practices for data protection

5.3 Data Protection Principles

In processing personal data, we adhere to the following principles:

  • Lawfulness, Fairness, and Transparency: We process personal data lawfully, fairly, and in a transparent manner.
  • Purpose Limitation: We collect personal data for specified, explicit, and legitimate purposes and do not further process it in a manner incompatible with those purposes.
  • Data Minimization: We collect only personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.
  • Accuracy: We take reasonable steps to ensure that personal data is accurate and, where necessary, kept up to date.
  • Storage Limitation: We retain personal data only for as long as necessary to fulfill the purposes for which it was collected.
  • Integrity and Confidentiality: We implement appropriate technical and organizational measures to ensure the security of personal data.

5.4 Privacy Policy

Full details of our data protection practices are set out in our Privacy Policy, which is available on this website.

5.5 Cross-Border Data Transfers

Where we transfer personal data to jurisdictions outside Hong Kong, we ensure that appropriate safeguards are in place to protect the personal data in accordance with the requirements of the PDPO and other applicable laws.

5.6 Data Subject Rights

Individuals have certain rights regarding their personal data under the PDPO, including rights of access and correction. Requests to exercise these rights should be directed to our Data Protection Officer at privacy@admcl.com.

6. Conduct Standards and Professional Ethics

6.1 Commitment to Professional Conduct

Admiralty Capital Limited and its personnel are committed to the highest standards of professional conduct, integrity, and ethics in all business dealings.

6.2 Core Principles

Our conduct standards are founded on the following core principles:

  • Integrity: We act with honesty and integrity in all our dealings. We do not engage in any conduct that is deceptive, misleading, or fraudulent.
  • Fair Dealing: We deal fairly with all clients, counterparties, and other stakeholders. We do not engage in manipulative, unfair, or abusive practices.
  • Professionalism: We conduct ourselves with professionalism and competence. Our staff maintain the skills, knowledge, and expertise necessary to perform their duties.
  • Confidentiality: We protect confidential information and do not misuse it for personal gain or to the detriment of any party.
  • Conflicts of Interest: We identify, manage, and disclose conflicts of interest. Where conflicts cannot be managed, we decline to act.
  • Compliance: We comply with all applicable laws, regulations, and professional standards.

6.3 Treating Clients Fairly

We are committed to treating all clients fairly and transparently. This includes:

  • Providing clear, accurate, and timely information about our services, terms, and fees
  • Ensuring that our products and services meet the needs of our target market
  • Communicating in a manner that is clear, fair, and not misleading
  • Handling complaints promptly and fairly
  • Avoiding conflicts of interest or managing them appropriately

6.4 Market Conduct

In our financing and investment activities, we:

  • Do not engage in market manipulation or insider dealing
  • Respect the integrity and orderly functioning of financial markets
  • Maintain appropriate information barriers where necessary
  • Comply with applicable market abuse regulations

6.5 Anti-Bribery and Corruption

We maintain a zero-tolerance approach to bribery and corruption. We do not offer, give, request, or accept any bribe or other improper payment, whether in dealings with public officials or private parties.

6.6 Political Contributions and Activities

Admiralty Capital Limited does not make political contributions or engage in political activities on behalf of the company.

6.7 Environmental, Social, and Governance (ESG)

We are committed to responsible business practices that consider environmental, social, and governance factors. We seek to conduct our business in a manner that is sustainable and contributes positively to society.

6.8 Training and Compliance Monitoring

All personnel receive training on our conduct standards and ethical obligations. We maintain systems and controls to monitor compliance with these standards.

7. Disclaimers and Limitations

7.1 No Offer or Solicitation

Nothing on this website constitutes an offer to sell, or a solicitation of an offer to purchase, any securities, financial instruments, or other products or services.

7.2 No Investment Advice

The information on this website does not constitute investment advice or a recommendation to enter into any transaction. You should seek independent professional advice before making any investment or financing decisions.

7.3 No Warranty

The information on this website is provided "as is" without warranty of any kind, express or implied. We make no representations or warranties regarding the accuracy, completeness, or timeliness of any information on this website.

7.4 Forward-Looking Statements

This website may contain forward-looking statements that reflect our current expectations and projections about future events. These statements are subject to risks, uncertainties, and assumptions that could cause actual results to differ materially.

7.5 Third-Party Information

This website may contain information obtained from third-party sources. We have not independently verified such information and make no representation or warranty as to its accuracy or completeness.

7.6 Hyperlinks

Hyperlinks to third-party websites are provided for convenience only and do not constitute endorsement of, or responsibility for, the content, products, or services offered on such websites.

7.7 Limitation of Liability

To the maximum extent permitted by law, Admiralty Capital Limited and its affiliates, directors, officers, employees, and agents shall not be liable for any loss or damage arising from the use of this website or reliance on any information contained herein.

7.8 Indemnification

By using this website, you agree to indemnify and hold harmless Admiralty Capital Limited and its affiliates from any claims, losses, or damages arising from your use of this website or violation of these terms.

8. Complaints Handling

8.1 Our Commitment

Admiralty Capital Limited is committed to handling all complaints promptly, fairly, and effectively. We treat complaints seriously and view them as an opportunity to improve our services.

8.2 What Constitutes a Complaint

A complaint is any expression of dissatisfaction, whether oral or written, about the provision of, or failure to provide, a financial service or a redress determination, which alleges that the complainant has suffered (or may suffer) financial loss, material distress, or material inconvenience.

8.3 How to Make a Complaint

Complaints may be submitted by:

Email: compliance@admcl.com

Mail:
Compliance Department
Admiralty Capital Limited
Central, Hong Kong

8.4 Information to Include

When submitting a complaint, please include:

  • Your full name and contact information
  • A clear description of your complaint
  • Relevant dates and transaction details
  • Copies of any relevant documents
  • The outcome you are seeking

8.5 Complaint Handling Process

  • Acknowledgment: We will acknowledge receipt of your complaint within five (5) business days.
  • Investigation: Your complaint will be investigated by an appropriate person who was not directly involved in the matter complained about.
  • Resolution: We will endeavor to resolve your complaint within thirty (30) business days. If we are unable to resolve your complaint within this timeframe, we will inform you of the reasons for the delay and provide a revised timeline.
  • Final Response: We will provide you with a final written response setting out the outcome of our investigation and any remedial action we propose to take.

8.6 If You Remain Dissatisfied

If you are not satisfied with our final response, you may have the right to refer your complaint to relevant regulatory authorities or seek other remedies available under applicable law.

8.7 Record Keeping

We maintain records of all complaints received and the actions taken to resolve them. These records are reviewed periodically to identify any systemic issues or areas for improvement.

8.8 Contact Information

For any questions about our complaints handling process, please contact:

Compliance Department
Admiralty Capital Limited
Central, Hong Kong
Email: compliance@admcl.com

9. Legal and Regulatory Updates

9.1 Changes to Disclosures

We may update these Regulatory Disclosures from time to time to reflect changes in applicable laws, regulations, or our business practices. Material changes will be posted on this website.

9.2 Effective Date

These Regulatory Disclosures are effective as of January 2026.

9.3 Contact for Regulatory Matters

For questions regarding these Regulatory Disclosures or our regulatory compliance, please contact:

Compliance Department
Admiralty Capital Limited
Central, Hong Kong
Email: compliance@admcl.com