When Mr Zhou worked as a senior official in the civil service of the Hong Kong Special Administrative Region he routinely provided information sought by his friends who went to university with him. Most of these information related to work done by Mr Zhou but sometimes he would ask his colleagues from other departments for clarification.

Last year Mr Zhou bought a flat and secured loans totaling about $9.3 million from banks which were guaranteed by some of these friends. For about 6 months while his flat was being renovated he stayed rent-free in an apartment with two of these friends. Another three friends from.this group helped with the renovations and charged Mr Zhou about 20 percent of the market rate for their work. When these were discovered during in a routine internal audit the employment of Mr Zhou was terminated on grounds of his failure to disclose.

Mr Zhou is worried about further legal action and he seeks your advice as regards criminal charges that may be brought against him by the government. Advise him.