HK SFC AML Monitoring Exams

On Aug. 31, HK SFC issued circular on AML inspections findings.

  • Found AML deficiencies in inspections of licensed corporations (LCs) in last year.
  • In meeting the expected regulatory standards, for AML/CFT measures, controls.

Scope of Reviews

  • This followed thematic inspection focusing on 13 LCs’ measures and controls for
  • identifying and mitigating money laundering and terrorist financing (ML/TF) risk.
  • Also reviewed the AML/CFT policies, procedures and controls of around 270 LCs.


  • SFC reminded LCs and associated entities (AEs) to take all reasonable measures
    to mitigate ML/TF risks and put in place proper safeguards to ensure compliance.
  • Firms should critically review internal AML/CFT policies, procedures and controls.
  • Where needed, take immediate action to rectify any deficiencies or inadequacies.
  • Particularly deficiency of institutional risk assessment, customer risk assessment,
    Initial and ongoing CDD, Sanctions screening, suspicious transaction monitoring.
  • Will continue to monitor LCs’ and AEs’ compliance with their AML/CFT obligations.