• AML/CFT Health Check - Hong Kong Template

    The AML/CFT Health Check Tool has been customised to meet the requirements specified in the AML/CTF Ordinance (AMLO) for Hong Kong reporting entities.

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AML/CFT Health Check – Hong Kong Template

The AML/CFT Health Check Tool has been customised to meet the requirements specified in the AML/CTF Ordinance (AMLO) for Hong Kong reporting entities.

Our subject matter experts have leveraged and expanded upon the guidance provided in the AMLO, the Drug Trafficking (Recovery of Proceeds) Ordinance (DTROP),a the Organised and Serious Crimes Ordinance (OSCO), the United Nations (Anti-Terrorism Measures) Ordinance (UNATMO), Hong Kong Monetary Authority, Joint Financial Intelligence Unit and the Securities and Futures Commission, to bring to you the world’s first software-as-a-service AML/CFT Health Check (which can also be deployed behind your organisations firewall).

The AML/CFT Health Check for Hong Kong reporting entities contains over 600 out-of-the-box questions, comprising requirement traceability questions, as well as, best practice questions (which can be disabled) across the following categories:

AML/CFT systems and business conducted outside Hong Kong

  • Risk Factors
  • Product/service risk
  • Delivery/distribution channel risk
  • Customer risk
  • Country risk
  • Effective controls to ensure proper implementation of AML/CFT policies and procedures
  • Senior Management Oversight
  • Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO)
  • Compliance and audit function
  • Staff screening
  • Business conducted outside Hong Kong

Risk Based Approach

  • Introduction
  • General Requirements
  • Customer acceptance/risk assessment
  • Ongoing Review
  • Documenting the ML/TF risk assessment

Customer Due Diligence

  • Introduction to Customer Due Diligence
  • Identification and verification of the customer’s identity
  • Identification and verification of a beneficial owner
  • Identification and verification of a person purporting to act on behalf of the customer
  • Characteristics and evidence of identity
  • Purpose and intended nature of business relationship
  • Timing of identification and verification of identity
  • Natural Persons
  • Legal Persons and Trusts
  • Simplified customer due diligence
  • High-Risk Situations
  • Customer not physically present for identification purposes
  • Politically Exposed Persons
  • Bearer Shares
  • Jurisdictions that do not or insufficiently apply the FATF recommendations or otherwise posing higher risk
  • Reliance on CDD performed by intermediaries
  • Pre-existing customers
  • Prohibition on anonymous accounts
  • Jurisdictional Equivalence

Ongoing Monitoring

  • General
  • Risk Based Approach to Monitoring
  • Methods and Procedures

Financial sanctions and terrorism financing

  • Financial sanctions & proliferation financing
  • Terrorist Financing
  • Database maintenance and screening (customers and payments

Suspicious transactions report

  • General
  • Knowledge vs. Suspicion
  • Timing and Manner of Reports
  • Internal Reporting
  • Recording of Internal Reports
  • Records of reports to JFIU
  • Post Reporting Matters
  • ML through the securities sector – transactions involving securities, futures contracts or leveraged foreign exchange contracts
  • ML involving employees of licensed corporations

Record Keeping

  • General Legal and Regulatory Requirements
  • Retention of records relating to customer identity and transactions
  • Records kept by intermediaries

Staff Training

Wire Transfers

  • General Requirements
  • Ordering Institutions
  • Domestic Wire Transfers
  • Beneficiary Institutions
  • Batch File Transfers
  • Intermediary Institutions
  • Missing, incomplete or meaningless originator information
  • Cover payment messages related to cross-border wire transfers

Based on guidance developed by

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