Anti-money laundering describes a firm's whole programme against the laundering of criminal proceeds and the financing of terrorism. In Hong Kong the programme rests on three ordinances: the AMLO (Cap. 615), which sets customer due diligence and record-keeping duties; the Organized and Serious Crimes Ordinance (Cap. 455) and the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405), which create the laundering offences and the duty to report suspicious transactions to the Joint Financial Intelligence Unit; and the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575).
The programme has four working parts: customer due diligence at onboarding, ongoing monitoring of transactions and of the customer's profile, sanctions screening and PEP screening, and suspicious transaction reporting. Each regulator issues its own guideline on how its sector should meet them.
Why it matters
The Financial Action Task Force assesses Hong Kong against its 40 Recommendations, and the ordinance has been amended several times to match them: in 2018 to extend due diligence to solicitors, accountants, estate agents and trust or company service providers, and in 2023 to license virtual asset service providers and to align the treatment of politically exposed persons.
How Fill Easy relates to it
Fill Easy supplies the data an AML programme runs on: registry records and ownership tracing through CorpVerify, government-confirmed identity through GovVerify, and periodic re-checks of an existing book through monitoring and remediation. The judgement stays with the firm; the evidence comes from the source.