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AML Requirements by Industry
Welcome to our comprehensive AML Guide.
Different industries face unique Anti-Money Laundering (AML)
challenges and requirements,
Our guide provides comprehensive insights
to ensure your business remains compliant.




BANKING & FINANCIAL
Regulatory Framework: Governed by the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) and the Banking Ordinance (BO). Customer Due Diligence (CDD): Banks must perform CDD when establishing business relationships, conducting transactions above a certain threshold, or when there are suspicions of money laundering. Ongoing Monitoring: Continuous monitoring of transactions to detect and report suspicious activities. Record-Keeping: Maintain records of transactions and CDD for at least five years. Reporting: Mandatory reporting of suspicious transactions to the Joint Financial Intelligence Unit (JFIU). The HK Association of Banks – Industry Guidelines>Anti-money Laundering




SECURITIES & FUTURES COMMISSION
Regulatory Framework: Governed by the Securities and Futures Commission (SFC) under the AMLO. Risk-Based Approach: Implement a risk-based approach to identify and mitigate money laundering risks. Enhanced Due Diligence (EDD): Required for high-risk clients, including Politically Exposed Persons (PEPs). Training: Regular training for staff on AML policies and procedures. Reporting: Immediate reporting of suspicious transactions to the SFC. Links: SFC-AML & CTF





INSURANCE
Regulatory Framework: Governed by the Insurance Authority (IA) under the AMLO. CDD and EDD: Conduct CDD and EDD for new policies, especially for high-value or high-risk clients. Transaction Monitoring: Monitor insurance transactions for unusual patterns or activities. Record-Keeping: Maintain records of transactions and CDD for at least five years. Reporting: Report suspicious activities to the JFIU 1.





REAL ESTATE
Regulatory Framework: Governed by the Estate Agents Authority (EAA) under the AMLO. CDD: Perform CDD on clients involved in property transactions. Risk Assessment: Assess the risk of money laundering in property transactions. Record-Keeping: Keep records of transactions and CDD for at least five years. Reporting: Report suspicious transactions to the JFIU 1.





TRUST & COMPANY SERVICE PROVIDERS
Regulatory Framework: Governed by the Companies Registry under the AMLO. CDD and EDD: Conduct CDD and EDD on clients, especially for high-risk services. Ongoing Monitoring: Continuously monitor business relationships and transactions. Record-Keeping: Maintain records of transactions and CDD for at least five years. Reporting: Report suspicious activities to the JFIU 2. Links: Guideline on Compliance of AML/CTF Requirements for TCSPs








LICENSED MONEY LENDERS
Regulated by the Company Registry Links: Guideline on Compliance of Anti-Money Laundering and Counter-Terrorist Financing Requirements for Licensed Money Lenders.