Responsibilities of Compliance Officer

According to AMLO, MSO licencees must appoint a "Compliance Officer" and a "Money Laundering Reporting Officer".


Responsibilities of Compliance Officer and Money Laundering Reporting Officer:

- Assist senior management to set up anti-money laundering policies

- Assist senior management to approve and audit customer and transaction information

- Assist senior management to monitor customers and analyze transactions on an ongoing basis

- Report and alert senior management on money laundering activities

- Liaise with JFIU and HK Customs

- Assist senior management on staff training

- Ensure exercise of reasonable case on a risk management basis

- Details pls refer to AMLO


Responsibilities of Compliance Officer:

(a) developing and/or continuously reviewing the FI’s AML/CFT systems to ensure they remain up-to-date and meet current statutory and regulatory requirements;

(b) the oversight of all aspects of the FI’s AML/CFT systems which include monitoring effectiveness and enhancing the controls and procedures where necessary.


In order to effectively discharge these responsibilities, a number of areas should be considered. These include: 

(a) the means by which the AML/CFT systems are managed and tested;

(b) the identification and rectification of deficiencies in the AML/CFT systems;

(c) reporting numbers within the systems, both internally and disclosures to the Joint Financial Intelligence Unit (JFIU);

(d) the mitigation of ML/TF risks arising from business relationships and transactions with persons from countries which do not or insufficiently apply the FATF Recommendations;

(e) the communication of key AML/CFT issues with senior management, including, where appropriate, significant compliance deficiencies;

(f) changes made or proposed in respect of new legislation, regulatory requirements or guidance;

(g) compliance with any requirement under Part 2 or 3 of Schedule 2 in overseas branches and subsidiary undertakings and any guidance issued by RAs in this respect; and

(h) AML/CFT staff training