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.