Hong Kong AML Compliance

Hong Kong’s low tax rates and sophisticated banking system, company formation agents and the absence of currency and exchange controls present vulnerabilities for money laundering within the country; including Trade-Based Money Laundering (TBML) and illicit financing.

Government of Hong Kong officials specify the primary sources of laundered funds, derived from both local and overseas criminal activity, are fraud, financial crimes and illegal gaming.

Hong Kong has AML legislation allowing the locating and sequestering of proceeds derived from drug-trafficking and organised crime (in the Organised & Serious Crimes Ordinance). These ordinances have made it increasingly difficult for criminals to launder, retain or generally profit from illicit sources. Hong Kong also has enacted the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions Ordinance (AMLO) for supervising authorised institutions’ compliance with the legal requirements.

Under AMLO legislation, where payment-related information is exchanged, authorised organisations are required to carry out Customer Due Diligence procedures. Additionally, the AMLO Guideline and the Hong Kong Monetary Authority’s (HKMA) Transactions Guidance Paper provide substantial practical guidance on filing Suspecious Transaction Reports.

In 2016, the Hong Kong Association of Banks, in collaboration with the HKMA, published the Guidance Paper on Combating Trade-based Money Laundering in order to implement effective measures to further mitigate authorised institutions’ money laundering risks. Hong Kong is also a member of the FATF and the Asia Pacific Group, a FATF-style local organisation.

We can assist with the following services for fulfilling Hong Kong corporate compliance requirements:

Compliance checks at HKMA & SFC level

Eltoma Corporate Services can carry out an assessment of your Hong Kong Company’s current compliance provisions to identify any areas your company may be required to address to ensure compliance. A comprehensive report on the findings will be supplied, with an action plan.

Pre-acquisition Due Diligence & new licence applications

Opening a subsidiary company is a big step for any business and the status of which may be the focus of HKMA regulations that may affect your holding company’s good standing. Eltoma can assist by conducting a pre-acquisition compliance assessment and assist in obtaining the necessary permits in Hong Kong accordingly.

Drafting of risk mapping & risk management services

We can help to produce compliance and procedures manuals for data protection which are customised to your precise needs. We also provide training and competence schemes, compliance monitoring programmes, client letter templates, disclosure documents, business agreements and many other types of documentation you will need, in the form of risk mapping and risk management services.

New applications for HKMA authorisation

We can assist with the lengthy practice of applying for authorisation by project managing your application. Our service ensures that the application is complete and accurate, in turn minimising delays to the commencement of trading after being granted HKMA authorisation.

Continued compliance assistance

Eltoma provide ongoing assistance with compliance matters through any convenient method of communication, skype, email and telephone.

CDD, Politically Exposed Persons & Conflict of Interest resolution

We can help you to identify and satisfy any issues that may need to be addressed by creating an action plan and employing monitoring programmes.

Due Diligence for individuals will include checking the following information/documents:

  • Passport (or other legal document) to verify the full name, Date of birth
    Citizenship and photo.
  • Proof of address (any document that could prove identify place of living). 
  • Professional background.

Due Diligence for legal entities will include checking next information/documents:

  • Certificate of incorporation (Full name, Location, Date and number).
  • General information about the business activity.
  • Data that enables end-beneficial owners (controllers) to be identified.

Furthermore, our Compliance Department can provide:

  • Guidance on the proper application and interpretation of regulatory standards.
  • Implementation and support of effective policies, procedures and practices for regulated types of activities regarding AML/CFT policies.
  • Training the staff on key compliance issues.
  • Provide analysis and control of compliance with regulatory norms, detection of offenses / inconsistencies with the regulatory framework (Due Diligence, internal investigations, consideration of client complaints).
  • Regular reports to management on compliance issues.
  • Identification, assessment and management of compliance risks.


Please contact us for more information on anything mentioned on this page, we'd be happy to assist or provide a detailed quotation for services.


Take the next step, we are here to help.

Register a Hong Kong company.
Open a Hong Kong bank account.