← Back to Hong Kong licences
HONG KONG LICENCES
Money service operator (MSO)
Money changing and remittance · Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
Licensing authorityHong Kong Customs (Commissioner of Customs and Excise)
Governing legislationAnti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
Licence validityNormally two years; apply for renewal at least 45 days before expiry
Business scopeMoney changing and remittance
Purpose of the licence
An MSO licence covers money changing and/or remittance services. Unless a statutory exemption applies, a person operating a money service in Hong Kong must obtain a licence from the Commissioner of Customs and Excise. On conviction on indictment, unlicensed operation carries a maximum fine of HK$1 million and two years' imprisonment. Whether a specific activity falls within the licensing scope depends on the service model.
Main application requirements
- The applicant and relevant partners, directors and ultimate owners must meet the fit and proper criteria. An ultimate owner of a corporation includes an individual directly or indirectly owning or controlling more than 25% of its share capital or voting rights, or exercising ultimate control over its management;
- Appoint a Compliance Officer and a Money Laundering Reporting Officer;
- Nominate a qualifying senior manager, such as a sole proprietor, partner or director, to undertake and pass the competency assessment as required by Customs;
- Prepare a business plan, AML/CFT policies, premises floor plans and other required documents;
- Establish customer due diligence and record-keeping arrangements. Premises in a wholly residential building are unsuitable for an MSO business. A residential unit in a mixed-use building requires written consent from every occupant for routine inspection and must satisfy the other premises requirements.
Application process
- Confirm a sole proprietorship, partnership or corporate structure and appoint the Compliance Officer and Money Laundering Reporting Officer;
- Prepare the application documents, including the business plan and AML policies, and submit them to Customs;
- Respond to Customs enquiries and arrange for the nominated qualifying senior manager to complete the competency assessment;
- Customs arranges an interview, examines original documents and inspects the business premises;
- Customs grants the licence if satisfied.
Acquisition, sale and transfer
An acquisition of an existing MSO company or a new application may be assessed against business needs. Proposed directors, partners or ultimate owners require prior Customs approval. Buying a company with a licence does not by itself allow immediate operation. An adviser must verify the arrangements for the case.