For example, this image.
I asked Gemini 2.5 Pro whether there were any factual issues with the legal content described in this image, but it told me there were almost no issues. As shown in the figure
However, in fact,
The Securities and Futures Ordinance (SFO, Cap. 571)
1) The “2023 Revised Edition” does not directly correspond to the virtual asset licensing system. The license for virtual asset trading platforms (VATP) under the revised Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Cap. 615) was implemented in June 2023, not the SFO revised edition.
2) Section 103 essentially prohibits “unauthorized investment advertising,” not “the unauthorized issuance of prospectuses to the public.” The maximum penalty is HK$500,000 and three years' imprisonment, with additional daily fines for continued violations, not “HK$10 million/10 years.”
3) The criminal liability for “conducting business without an SFC license” is stipulated in Section 114(8), with a maximum fine of HK$5 million and seven years' imprisonment; it is not covered by Section 116.
4) Including security tokens under the regulation of ‘collective investment schemes’ “ is an inaccurate statement. The SFO's definition of ”securities/collective investment schemes“ is technically precise and does not include a specific amendment in 2023 to ”include security tokens.“ Whether a scheme falls under regulation depends on its specific structure and offering method, not on the addition of a ”token clause." (Summarized from the SFO framework and SFC's public explanations)
4. Project Ensemble Sandbox Project Guidelines (HKMA)
1) The timeline is incorrect. The HKMA announced Project Ensemble in March 2024 and officially launched the Sandbox on August 28, 2024; there is no “guideline” document dated “November 2023.”
2) The so-called “Section 5.3/Section 7.2” terms in the table, such as “quarterly submission of risk control reports” and “24-month testing period,” have no official source for their section numbers or fixed deadlines. The HKMA's public documents are press releases and speeches, which are positioned as testing interoperability and four key themes, and do not contain the aforementioned terms.
5. Circular on the Sale and Distribution of Tokenized Products (HKMA, February 20, 2024)
1) The document and date are authentic.
2) The scope is misrepresented. This circular applies only to tokenized products and tokenized deposits that are not regulated by the Securities and Futures Ordinance (SFO), and explicitly does not apply to stablecoins or tokenized securities regulated by the SFO.
3) Due diligence and disclosure, risk management, customer suitability, and AML/KYC obligations are indeed regulatory requirements. However, the circular does not require a “blanket review of the issuer's solvency and liquidity for all token products,” but rather requires thorough due diligence and information disclosure on the structure and risks of the issuer and its key third parties.
Even the above content was told to me by GPT-5.
Gemini 2.5 Pro now requires the deep search function to be enabled in order to significantly reduce such errors.