The Anti-Money Laundering and Counter-Terrorist Financing Ordinance, Chapter 615 of the Laws of Hong Kong, came into force on 1 April 2012. It imposes customer due diligence and record-keeping requirements on financial institutions and on designated non-financial businesses and professions, and it provides the licensing regimes for money service operators, trust or company service providers and virtual asset service providers. The due diligence and record-keeping duties are in Schedule 2; the regulators that enforce them are the Hong Kong Monetary Authority, the Securities and Futures Commission, the Insurance Authority, the Customs and Excise Department, and the Companies Registry, the Law Society, the Hong Kong Institute of Certified Public Accountants and the Estate Agents Authority for their sectors.
Main amendments
The 2018 amendment extended the due diligence duties to solicitors, accountants, estate agents and TCSPs, and introduced TCSP licensing from 1 March 2018. The 2022 amendment, in force from 1 June 2023, introduced licensing of virtual asset service providers, brought dealers in precious metals and stones under the ordinance, and aligned the treatment of politically exposed persons with the FATF standards, with a risk-based approach to domestic and former PEPs.
What Schedule 2 requires
Identification and verification of the customer and its beneficial owners from reliable and independent sources, information on the purpose of the relationship, ongoing monitoring, enhanced measures in high-risk cases, reliance on intermediaries on conditions, and records kept for at least five years. Each regulator's guideline explains how its sector should meet these.
How Fill Easy relates to it
Schedule 2 allows verification from a government body or a recognised digital identification system, which is what GovVerify returns, and from independent registry records, which is what CorpVerify returns. Our Hong Kong KYC and AML page maps each duty to the evidence.