To serve as the licensee's designated Compliance Officer and Money Laundering Reporting Officer under the AMLO, with overall responsibility for the establishment, implementation and
maintenance of the MSO's AML/CFT systems, and to act as the central reference point for suspicious transaction reporting.
Key responsibilities — Compliance Officer (CO) function
- Hold overall responsibility for the establishment and maintenance of the MSO's AML/CFT systems, acting as the focal point for oversight of the firm's compliance
measures.
- Develop, implement and maintain the firm's AML/CFT policy and procedures, covering customer due diligence, transaction monitoring, and reporting procedures.
- Serve as the primary point of contact for AML/CFT and regulatory matters with the Customs and Excise Department (C&ED), including handling requests for information (RFIs) from regulatory authorities on a timely basis and leading regulatory inquiries and inspections.
- Ensure ongoing compliance obligations are met, including carrying out customer due diligence for transactions above HKD 8,000, keeping transaction and client records for at least six years, and submitting periodic returns to the Customs and Excise Department.
- Lodge licence renewal applications and ad-hoc returns to the C&ED on a timely basis, including quarterly returns to the C&ED within two weeks of quarter-end using the
prescribed form.
- Arrange independent AML/CFT audits commensurate with the nature, size and complexity of the business.
Key responsibilities — Money Laundering Reporting Officer (MLRO) function
- Act as the central reference point for suspicious transaction reporting and as the main point of contact with the Joint Financial Intelligence Unit (JFIU) and other law enforcement agencies.
- Play an active role in the identification and reporting of suspicious transactions.
- Review internal disclosures and exception reports and, in light of all available relevant information, determine whether or not it is necessary to make a report to the JFIU.
- Ensure that any suspicious transaction is reported promptly to the JFIU as soon as it is reasonable to do so.
- Maintain proper records on all investigations and reviews, and provide additional information where required by the JFIU and law enforcement agencies.
