Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance, Cap. 615 has been effective from 1 April 2012.  Under the “AMLO”, any person who wishes to operate a money service must apply for a licence from the Commissioner of HK Customs.

Please find below the linkage to the three relevant laws:

Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405)

Organized and Serious Crime Ordinance (Cap. 455)

United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575)


Under the AMLO, all MSO licencee must keep all documents and records throughout the business relationship with the customer and for a period of six years after the end of the business relationship. 


Licencees under AMLO are required to comply with the following requirements.  Offenders may be de-licensed, penalized, or even prosecuted.

- Due diligence 

- Record keeping

- Ongoing monitoring

- Submit quarterly transaction report

- Report suspicious transaction