SFC publishes AML/CFT inspection findings and urges intermediaries to ensure compliance

The Securities and Futures Commission (SFC) issued a circular on 31 August 2018 highlighting both deficiencies and good practices observed in relation to anti-money laundering and counter financing of terrorism (AML/CFT) compliance by licensed corporations (LCs) and associated entities (AEs). The observations were made over the past year from the SFC’s review of AML/CFT measures, policies, procedures and controls (AML/CFT systems) belonging to 13 LCs during thematic inspections and around 270 LCs during routine inspections. This follows on from the SFC’s circular issued on 26 January 2017, setting out its observations relating to AML/CFT compliance from inspections conducted in 2016 (see our earlier bulletin here). Continue reading

SFC proposes to implement revisions to AML/CFT guidelines on 1 November 2018 ahead of FATF Hong Kong evaluation

On 5 July 2018, the Securities and Futures Commission (SFC) issued a consultation paper on proposals to amend the Guideline on Anti-Money Laundering and Counter-Terrorist Financing (Main Guideline) and the Prevention of Money Laundering and Terrorist Financing Guideline issued by the Securities and Futures Commission for Associated Entities (Guideline for AEs). Comments on the proposals are required to be submitted by 9 August 2018. Continue reading


The Hong Kong government has published a report detailing the money laundering (ML) and terrorist financing (TF) risk assessment of Hong Kong. This follows the recommendations of the Financial Action Task Force (FATF) that jurisdictions identify and assess their ML/TF risks and apply mitigating measures, and is a pre-cursor to the FATF’s onsite evaluation of Hong Kong’s ML/TF safeguards, scheduled to take place this autumn.

The report examines the ML/TF threats and vulnerabilities facing Hong Kong as a whole as well as specific sectors. The key aspects of the report are highlighted in our e-bulletin of 4 May 2018. In a follow-up e-bulletin (please click here to access), we provide an overview of the report’s findings in relation to financial institutions and payment systems.

Among others, the Securities and Futures Commission, the Hong Kong Monetary Authority and the Insurance Authority have issued circulars to alert the entities under their purview of the report and provide guidance.


William Hallatt
William Hallatt
Head of Financial Services Regulatory, Hong Kong
+852 2101 4036
Vicky Man
Vicky Man
Senior Associate, Hong Kong
+852 2101 4243
Jackie Lam
Jackie Lam
Associate, Hong Kong
+852 2101 4194


In late February, Transparency International (“TI“) published the 2017 Corruption Perceptions Index (“CPI“). This is the 23rd annual edition of the CPI, which ranks countries according to the levels of public sector corruption, as perceived by business people and country experts. The CPI ranking aggregates data from a number of different sources, including various polls by institutions such as the World Bank and World Economic Forum. Countries and territories are given a score between 0 and 100, with 0 being highly corrupt and 100 being very clean and ranked from cleanest to most corrupt. Continue reading