FAQ on MSO Licence Application

What is the definition of a Money Service Operator (“MSO”)?

A: A person who or an institution which operates a money changing service or a remittance service is a Money Service Operator.


Who is the relevant authority for the “MSOs” and the Postmaster General under the “AMLO”?

A: The Commissioner of Customs & Excise (“CCE”) is the relevant authority under the “AMLO”.


What should I do if I wish to operate a money changing and/or remittance service under the “AMLO”?

A: Under the “AMLO”, any person who wishes to operate a money service must apply for a licence from the “CCE”.


When should “MSOs” apply for a licence?

A: “MSOs” should submit application for a licence to the “CCE” commencing on 1 April 2012.


How to apply?

A: The application can be submitted in paper or through e-platform. (We can assist in making the application.)


What are the conditions for the “CCE” to grant an “MSO” licence?

A: The conditions that “CCE” will consider in granting a licence are set out in section 30(3) and (4) of the “AMLO”. In brief, the applicant (or any partner / director / ultimate owner) must not have been convicted of an offence specified at section 30(4), or is an undischarged bankrupt, and the premises for operation of the “MSO” business is considered by “CCE” to be suitable


How long is the validity of a licence?

A: The licence will be valid for 2 years and a licensee should apply for renewal not later than 45 days before the licence is due to expire.


Can I operate a money changing and/or remittance service without a licence?

A: It is illegal to  operate a money changing and/or remittance service without a MSO licence.


Possible penalty for illegal operations, failure on due diligence, or record keeping

A: If the person who is an employee of an FI or is employed to work for an FI or is concerned in the management of an FI knowingly contravenes a specified provision  he is liable to a maximum term of imprisonment of 7 years and a fine of $1 million upon conviction.


Basic requirements of a MSO applicant

A: A MSO applicant could be a Hong Kong limited company, Hong Kong unlimited company or overseas company.


General procedure of MSO application

A: After submitting all the required documents, the HK Customs will request for payment of application fee (basic fee: HK$3,310, audit fee for each "proper person": HK$860, audit fee for additional business premises: HK$2,200).

After payment, HK Customs will interview the applicant and issue an "additional information" form to the applicant.

HK Customs will perform an audit on the persons and company, together with an onsite visit to the business premises.  Finally, HK Customs will inform the applicant of the result of the applicant by mail.


Important matters after the issuance of MSO licence

A:  Upon collection of the MSO licence, HK Customs will request the licencee to nominate a "Compliance Officer" and a "Money Laundering Reporting Officer".

In addition, the licencee is required to submit a transaction report every quarter and suspicious customer / transaction report on a timely basis.


If there is any change during the operation of the MSO business (e.g., change in the Compliance Officer), the licencee must provide written notification to HK Customs within one month of the change.