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Members' Circular
17 November 2014

Dear Members:

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

Anti-Money Laundering Course for Money Service Operators

"Customer Due Diligence and Case Studies" course co-organized by our Association and Institute of Professional Education and Knowledge (PEAK) will be held on 27 November 2014 (Thursday night).

We welcome all money service practitioners and related persons to enrol. The course only costs HK$100 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......Read more

HKMA scraps 20,000 yuan daily conversion cap in landmark reform

Hong Kong will allow the city's residents to convert yuan freely from Monday - a landmark reform that marks the latest step in the internationalisation of the tightly controlled currency. The move will see the daily conversion limit of 20,000 yuan, in place since 2004 in a bid to stymie currency speculation, scrapped......Controls will remain on yuan remittances to the mainland by holders of Hong Kong bank accounts. The daily limit of 80,000 yuan will not change and cross-border travellers will still have to declare physical holdings of 20,000 yuan or more......Read more

New rules to pit forex dealers with banks

Hong Kong's banks welcomed the lifting of the daily yuan conversion cap, saying they will consider rolling out products and services targeting the currency, but money changers see it as a threat......Good news for banks may prove otherwise for money changers. "We'll be fighting with banks for business after the relaxation [of the conversion]," Mr Ng, head of a local exchange, said......Read more

Big sums laundered for 'tiny profits'

While sentencing a 70-year-old man yesterday for laundering HK$2.2 billion over three months, a High Court judge said the man had engaged in a serious crime dealing with huge amounts of money in exchange for "tiny profits" of HK$3,500 a month......Read more

What is Risk Assessment (1)

Over the past few months, the importance of risk assessment as one of the measures to combat money laundering has been emphasized in seminars held by HKC&ED and HKMA seminars as well as report issued by the Financial Action Task Force.

As a matter of fact, licensed MSOs can make use of risk assessment to determine the money laundering/terrorist-financing risk level of customers. Based on the risk level, resources can be allocated accordingly for performing customer due diligence and ongoing monitoring. It is crucial for licensed MSOs to take relevant effective measures in order to prevent from violation of law.

Licensed MSOs should conduct risk assessment once they start to establish business relationship with customers. After the assessment, customers should be categorized as different risk levels such as high, medium or low. While factors used for risk assessment varies depending on the industry and the nature of organization, factors that may be considered include:

- Country risk (subject to high levels of organized crime, increased vulnerabilities to corruption, for example Iran, North Korea, Afghanistan)
- Customer risk (For example Politically Exposed Persons (PEPs), non face-to-face transactions, source of wealth cannot be easily verified)
- Product/service risk (that inherently have provided more anonymity, for example Bitcoin)
- Delivery/distribution channel risk (For example sales through online, postal or telephone channels, business sold through intermediaries)

To be continued......