According to the Guidelines provided by the HK Customs in July 2012:

- fully conversant in the FI’s statutory and regulatory requirements and the ML/TF risks arising from the FI’s business;

- ensure that the company is able to satisfy itself that the statutory obligations are being met and that the business is taking sufficiently robust measures to protect itself against the risks of ML/TF

- ensure that the company staff received sufficient staff training to comply with the relevant law

- ensure that the MLRO is of sufficient status within the organization, and has adequate resources, to

- enable the staff to perform their functions monitor to ensure the company and its staff are complying with the company policy and law

- access, on a timely basis, all available information

- ensure all staff are made aware of the identity of the MLRO and of the procedures to follow when making an internal disclosure report; and all disclosure reports must reach the MLRO without undue delay

- 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.