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POLICY EXPRESS · PE-SB-192 · Security Bureau

Criminal Misuse of AI: Closing the Deepfake Gap

One deepfake fraud already cost Hong Kong HK$200 million, yet police do not count AI-enabled crime and new law remains at the study stage.

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2 pages · English and 繁體中文 · Built on the 1134211 Framework · Facts as at 25 October 2026

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The tension and our thesis

The tension

Hong Kong prosecutes AI-enabled crime under laws written for older tools, but it does not count AI’s part in crime, has no removal duty on platforms and has committed to no new law.

Our thesis

Count AI-enabled crime, publish the gaps in current law, set a platform removal duty and legislate new offences only where the evidence points.

Three policy problems this brief examines

  1. 01AI’s part in crime is not counted
  2. 02The law fits the act, not the tool
  3. 03Removal depends on requests

Each problem is developed in three layers: the fact, why it persists, and the consequence for the system.

Three options compared

A

A · Wait: apply existing law and platform requests.

B

B · Bespoke law now: new deepfake offences, labelling and personality rights.

C

C · Platform duty: a statutory takedown and reporting duty for tech and telecom.

The scored comparison, the justified recommendation with its phased measures, the implementation challenges, the stakeholder assessment and the success metrics are in the full brief.

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Facts and figures are checked against primary sources where we could retrieve them. † marks press-only figures. (J) marks IRB judgements. Facts as at 25 Oct 2026.

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