The pair, a 61-year-old man and a 31-year-old woman, were the company’s director and secretary respectively.
Both have been released on bail pending an investigation.
Customs said they have so far received 1,686 complaints involving HK$7.2 million worth of prepaid packages.
Divisional commander Tsang Kin-wah said authorities are looking into the company’s operations and financial position immediately before its suspected closure on May 1.
“Just days before its suspected closure, this trader was still selling medical services and accepting prepaid payments from consumers,” he said.
“That allegedly violated the Trade Descriptions Ordinance by wrongfully accepting payments,” he said.
“At the time of accepting these payments, the trader had no reasonable grounds to believe they could provide the relevant services within the specified or reasonable time frame.”
Tsang urged affected customers to come forward, adding that Customs have already been in touch with more than 1,400 complainants.
The government has also set up an inter-departmental task force to follow up on the complaints.
