New Handbook Shows How Financial Data Travels From UK and US Payment Systems to Hong Kong Authorities
ARTICLE 19 yesterday published Safeguarding Payments, Sustaining Movements: A Handbook for Hong Kongers to Navigate Digital Payment Platforms (opens in a new tab), a practical tool for civil society in Hong Kong and for the Hong Kong diaspora in the United Kingdom and the United States. The research was funded by a public policy activation grant from the Interledger Foundation.
The handbook maps the information flows behind the four main ways money crosses borders: bank wire transfers, money transfer operators, platform-based payment apps, and direct blockchain transfers. For each, it identifies what data is required, who along the chain can see it, and where the exposure sits. It then sets out seven strategies individuals and organizations can apply to assess and reduce their risk.
Since the passage of the National Security Law of 2020 and more recently Safeguarding National Security Ordinance of 2024, Hong Kong authorities have frozen bank accounts, tracked transactions, and cut off funding to journalists, activists, and those who send them money. Distance offers less protection than most people assume. Mutual legal assistance treaties between Hong Kong and both the US and the UK were suspended in 2020, yet financial intelligence can still move between jurisdictions through the Egmont Group, and multinational financial groups routinely share customer data internally across subsidiaries. This can have real world consequences for the targets of repression. For example, in February 2026, a Hong Kong court sentenced the father of a prominent pro-democracy activist living in the United States to eight months in prison for handling his child’s financial assets. The charge rested on an insurance policy he had taken out for her when she was a baby.
The handbook explains what type of data financial service providers are legally obliged to collect and what they voluntarily collect; how due diligence extends to family members, joint account holders, and regular counterparties; and what data protection rights exist in the UK, the US, and Hong Kong. An appendix profiles the major banks and payment platforms, including whether each requires formal legal process before disclosing customer records, whether it commits to challenging overbroad requests, and where it holds subsidiaries.
“Access to secure financial services is an essential condition for civic participation, democratic resilience, and the survival of human rights movements,” said Michael Caster, Head of Global China Program at ARTICLE 19. “When malign actors interfere with these services across borders it is a form of financial transnational repression. This guide seeks to safeguard these platforms from repressive overreach and to sustain the human rights movement in Hong Kong and the diaspora.”
“Financial inclusion is usually measured by who can open an account,” said Chris Lawrence, Chief Program Officer of the Interledger Foundation. “We care at least as much about what people can do once they have one, and that depends on trust, which is earned transaction by transaction. This handbook sets out the sharpest reason for withholding it. For the people it is written for, the payment system is both how they sustain their work and the apparatus used to map and punish them.”
“Anti-money laundering rules are legitimate. The volume of data collected on top of them, and the discretion firms retain to share it, is a design choice”
– Ayden Férdeline
“The finding that generalizes well beyond Hong Kong is that risk concentrates wherever one intermediary can see an entire transaction and one jurisdiction can compel that intermediary to hand it over,” said Ayden Férdeline, Lead for Public Policy and Government Affairs at the Interledger Foundation. “Anti-money laundering rules are legitimate. The volume of data collected on top of them, and the discretion firms retain to share it, is a design choice. We believe better design choices are possible, and this handbook is part of the evidence base for insisting on them.”
Safeguarding Payments, Sustaining Movements: A Handbook for Hong Kongers to Navigate Digital Payment Platforms is available in English and Cantonese at https://www.article19.org (opens in a new tab).
