Money Service Operator (“MSO”)
The Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (“AMLO”), Cap 615, Laws of Hong Kong came into operation on 1 April 2012.
Under AMLO, any person who wishes to operate a remittance and / or money changing service is required to apply for a license from the Commissioner of Customs & Excise, who is the authority to administer the licensing regime for Money Service Operators (“MSOs”) (i.e. Remittance Agents and Money Changers / “RAMC”) and supervise licensed MSO’s compliance with the customer due diligence and record-keeping obligations and other licensing requirements.
With effect from 1 April 2012, the appointment of the Chief Superintendent of Narcotics Bureau as the responsible officer for the purposes of section 24B of the Organized and Serious Crimes Ordinance is nullified; the Joint Financial Intelligence Unit of Narcotics Bureau stopped processing the registration of RAMC.
For enquiries about the licensing matters under the new AMLO, please contact the Customs and Excise Department directly at the below contact or visit their website. You may also find the list of the licensed MSOs at here.
Customs and Excise Department
Money Service Supervision Bureau
13/F, Customs Headquarters Building, 222 Java Road, North Point, Hong
Tel. (852) 3759 3722
Fax (852) 3108 3425
Email : firstname.lastname@example.org
Although JFIU has stopped processing the registration of RAMC, you are obliged to report to us any suspicious transactions that you encountered during your business. You can find more information on the reporting of suspicious transactions at here.
Here are some of the common red-flag indicators for your reference:
- Unusual large cash transactions made by an individual or company whose ostensible business activities would normally be conducted through cheques and other financial instruments.
- Substantial increases in transactions of an individual or business without apparent cause, especially if such transactions involve transfers within a short period out of the account and/or to a destination not normally associated with the customer.
- Customers who exchange or remit cash by means of numerous smaller transactions so that each transaction is unremarkable, but the total of all the transactions will exceed the threshold.
- Customers who seek to exchange large quantities of low denomination notes for those of higher denominations.
- Reluctant to provide normal information when conducting transactions, or just provides minimal or apparently fictitious information.
- number of customers transferring funds to the same beneficiary without an adequate explanation.
- Structured transfers – transfers broken up into a series of smaller transfers to avoid record keeping and customer identification requirements.
- Transactions in the name of an offshore company with structured movement of funds.
- Transactions inconsistent with the customer's usual business or apparent means without good explanation.
- Customers who make regular and/or large payments that cannot be clearly identified as bona fide transactions to, or receive regular and/or large payments from, countries which are commonly associated with the production, processing or marketing of drugs; or where the risk of terrorist financing activities is high.
- Frequent exchange of travellers’ cheques, foreign currency drafts by the same customer.
- Customers receipt of numerous transfers but each transfer is below the reporting /identification requirement in the remitting country.
- Customers sending and receiving transfers to/from tax havens, particularly if there are no apparent business reasons for such transfers or such transfers are not consistent with the customers' business or apparent background.