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Members' Circular
11 April 2016

Dear Members:

Through this Circular, our Association would like to take this opportunity to provide all members the latest updates on Association affairs and information relevant to licensed MSOs:

Anti-Money Laundering Course (Cantonese)

“Ongoing Monitoring and Case Studies” course (Cantonese) co-organized by our Association and Institute of Professional Education and Knowledge (PEAK) will be held on 28 April 2016 (Thursday night).
Since sufficient staff training is significantly effective in combating money laundering and terrorist financing, and HKC&ED requires some MSOs to submit continuous training records, our Association encourages MSOs to proactively arrange and encourage their staff to attend our courses. This is also a good opportunity to raise staff’s legal awareness and enhance their knowledge on the required level of compliance.
The course only costs HK$350 for all licensed money service practitioners. Seats are limited so please apply as soon as possible. For more details, please refer to our website or call our hotline at 3176 2004.

Our Association has recently met with the Money Service Supervision Bureau of the HKC&ED to understand and discuss recent issues related to licensed MSOs. Discussion addressed the followings:

FATF will conduct the on-site visit of the 4th round of Mutual Evaluation of Hong Kong in 2018. All licensed MSOs should fully cooperate in the evaluation on the effectiveness of risk assessment in relation to anti-money laundering and counter-terrorist financing performed by the international organization against Hong Kong. The relevant evaluation will affect the status of Hong Kong being an International Financial Centre.
The HKC&ED reminds all MSOs must submit an application form and the required documentation for licence renewal within 90 days but not later than 45 days before the licence is due to expire, otherwise the licensees may need to apply for fresh new MSO licences. There were MSOs being convicted for operation after expiry of licence in the past. For further details, please refer to the relevant licence renewal application Guidance Notes, Online Demonstration and Form
HKC&ED reminds licensed MSOs the statutory requirements of notifying the Commissioner on changes in particulars under the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance, Chapter 615, Laws of Hong Kong. Prior Approval from the Commissioner is required on the following changes: Proposing persons to become licensee’s directors/ultimate owners/partners; Adding new business premises; and Applying to operate at particular premises. If there is any change in the particulars that are provided to the Commissioner in connection with a licensee’s application for the grant of licence or renewal of licence, the licensee must notify the Commissioner in writing of the change within one month beginning on the date on which the change takes place.
Regarding the submission of suspicious transactions reports (STRs), licensed MSOs should pay attention to red flags and the required specific format by the Joint Financial Intelligence Unit (JFIU), and follow the designated forms when providing relevant information. This will help JFIU in executing the relevant investigations.
Regarding Continuous Professional Training, licensed MSOs and their staff should constantly enhance and study the relevant knowledge in management and Money Laundering in a proactive manner.

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