Anti-Money Laundering (AML) Policy｜P&L

1. Purpose and applicable law

We are committed to complying with Hong Kong SAR laws and regulations on anti-money laundering and counter-financing of terrorism (“AML/CFT”), including without limitation the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (“AMLO”) and subsidiary legislation, as well as guidelines issued by relevant regulators from time to time.

This Policy explains our general approach to customer due diligence, transaction monitoring, suspicious transaction reporting and record keeping. Detailed procedures are set out in internal policies, risk assessments and regulatory updates.

2. Risk-based approach

We apply a risk-based approach to identify, assess and mitigate ML/TF risks, and calibrate controls by reference to customer types, products, delivery channels, geography and other relevant factors.

3. Customer due diligence (CDD)

Before and during the business relationship, we may collect and verify identity information on customers and beneficial owners, and understand the nature of the business, source of funds and purpose of transactions, as required by law and internal policy. For legal persons or trusts, we may request constitutional documents, ownership structure, authorised signatories and ultimate beneficial owner information.

Enhanced due diligence (EDD) may be required for higher-risk customers or scenarios, including additional information, senior management approval or shortened review cycles.

4. Ongoing monitoring

We conduct ongoing monitoring of customer relationships and transactions to detect activity that is inconsistent with the customer profile or historical patterns. Monitoring may include automated screening, list matching and manual review.

5. Suspicious transaction reports

Where we know or suspect that any property is proceeds of crime or relates to ML/TF, or where there is an intention to assist another to do so, we will file a suspicious transaction report (STR) with the Joint Financial Intelligence Unit (JFIU) or other competent authorities of Hong Kong as soon as practicable, where required by the AMLO and related guidance, unless a specific legal exception applies.

We may be prohibited from “tipping off” customers about STR filings where the law so requires.

6. Record keeping

We maintain CDD documentation and transaction records for at least the statutory or prescribed periods under the AMLO and internal policy, for inspection by competent authorities.

7. Sanctions and high-risk jurisdictions

We comply with United Nations Security Council sanctions and sanctions implemented under Hong Kong law, as well as internal list policies. We may refuse to onboard, refuse transactions or terminate services relating to sanctioned, embargoed or high-risk jurisdictions or persons.

8. Training and governance

We provide periodic AML/CFT training to relevant staff and maintain internal escalation and review mechanisms to support effective implementation.

9. Cooperation with authorities

Within the bounds of law, we cooperate with lawful enquiries, inspections and enforcement actions by Customs and Excise Department, Hong Kong Monetary Authority, Hong Kong Police Force and other competent authorities.

10. Policy updates

We may revise this Policy to reflect changes in laws, regulatory guidance or business operations. Updated versions will be posted on this website. Continued use of services may constitute acknowledgement of updates where permitted by law; where separate consent is required, we will obtain it.