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Members' Circular
23 December 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

The "Customer Due Diligence and Case Studies" course, co-organized by our Association and Institute of Professional Education and Knowledge (PEAK) was held. Both of our course instructors explained in detail the importance of CDD to licensed MSOs. Our Association will continue organizing anti-money laundering-related courses for practitioners in order to promote compliant operation within the industry and to provide training to practitioners. For those who are interested in related courses, please take note of our Association's further notice. We would like thank all licensed MSOs, our compliance advisor and PEAK for their support to our course.

HKC&ED Questionnaire to MSOs

HKC&ED recently released a questionnaire for conducting a preliminary survey on problems MSOs may encounter. Answers provided by MSOs to the HKC&ED will help the Commissioner of Customs and Excise (CCE) plan a programme which aims at promoting the compliance level of MSOs under the requirements of AMLO. Licensed MSOs are strongly encouraged to fill in and submit it as soon as practicable......Read More

New "Telephone Deception" and "Email Scam" webpages

In view of the increasing number of deception cases announced by the Hong Kong Police Force, our Association has set up "Telephone Deception" and "Email Scam" webpages in our website. We hope to enhance licensed MSOs' precaution awareness against these deceptions and enable MSOs to understand the common modus operandi in order to detect relevant fraud cases. By doing so, financial loss of victims can be avoided and related crimes can be combatted.

Robbers used curry powder to steal HK$800,000 from couple

Two teenagers who pleaded guilty to taking part in robbing a couple by throwing curry powder and attacking them with glass bottles were jailed for five years in the Court of First Instance......Read More

Standard Chartered faces three more years of US scrutiny for sanctions breaches

Standard Chartered will face another three years of scrutiny by US prosecutors for compliance with government sanctions against certain countries......Read More

What is Risk Assessment (2)

After risk assessment, companies should formulate different policies, procedures and supervisory controls based on different risk levels in order to monitor customer transactions and perform on-going reviews (e.g. high risk customers should be reviewed annually). Assessments will change over time, depending on how circumstances develop, and how threats evolve. Therefore, licensed money service operators have to adjust its risk assessment of a particular customer from time to time and keep its policies and procedures under regular review and assess that its risk mitigation procedures and controls are working effectively.

Licensed MSOs should maintain relevant records and documents and should update them regularly based on different risk levels in order to show HKC&ED and regulatory departments:

-  How customers' anti-money laundering/counter terrorist financing risk have been assessed; and
-  Adequate due diligence and on-going monitoring have been performed based on respective customers' anti-money laundering/counter terrorist financing risk level.

During an anti-money laundering seminar held in mid-October, officers of the Hong Kong Monetary Authority emphasized the importance of risk assessment. Risk assessment helps banks better understand their risks associated with money laundering and formulate relevant measures to manage risk. As banks are investing more resources into measures such as risk assessment, licensed MSOs should cooperate and conduct comprehensive assessment on their own operations as well as customers based on the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance. A certain risk level should be allocated and according to the degree of risk, customer due diligence and on-going monitoring should be conducted and relevant records and documents should be kept. Review of the effectiveness of the risk assessment system should be performed from time to time.

(Please note that above information is for reference only.)