How does your firm fare on AML/CFT compliance?
The SFC posted an updated AML/CFT Self-Assessment Checklist on 27 January 2022. This reflects the latest Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Corporations) which became effective on 30 September 2021 (except for the cross-border correspondent relationships requirements which will take effect on 30 March 2022).
Licensed corporations should use the self-assessment checklist to assess and monitor their AML/CFT compliance as part of the regular review.
Senior management of licensed companies (e.g. MIC for Anti-Money Laundering and Counter-Terrorist Financing) should ensure that any compliance deficiencies identified during the regular reviews are rectified in a timely manner.
The SFC may require licensed corporations to provide evidence to show that such review has taken place and appropriate actions were taken as part of the routine inspections.
Time to plan ahead of CPT hours for 2022
We have mentioned the new CPT requirements in our newsletter articles of 24 November 2021, 24 June 2021 and 25 January 2021. It would be best to plan ahead and communicate with the licensed representatives and the responsible officers concerning their new CPT obligations. Licensed representatives are required to undertake a minimum of 10 CPT hours per calendar year while the responsible officers are required to undertake at least 12 CPT hours. Out of the required hours, all licensed individuals are required to attend at least five CPT hours on topics directly relevant to the regulated activities for which he/she is licensed, and two CPT hours on topics relating to ethics or compliance. In addition, responsible officers will also need to attend two CPT hours on topics relating to regulatory compliance.
