MSO License in Hong Kong

Your application will be reviewed and inspected by the Customs and Excise Department (C&ED) and the Commissioner of Customs and Excise (CCE) under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).

Your initial permit is valid for two years from its last registration. As per the rules, you should renew your license at least 45 days before it expires, but we recommend doing so 90 days before its expiration.

The authority will check if the applicants have any convictions for financial crimes like money laundering, personal or professional bankruptcy history, poor compliance, and whether they are competent or not.

Hong Kong money service operator license requirements and documents include the company’s AOA, certificate of incorporation/business registration, AML, KYC, CDD, & CFT policies, procedure for transaction monitoring, business plan, fit & proper test of all key managerial personnel, financial projections, and passport copies of directors and shareholders.

While the usual timeline is around 8 to 16 weeks, the process may extend up to 16 to 36 weeks, depending on the complexity of your application, the average application processing time, and the accuracy/completeness of your documents/policies.

Yes, you need a company incorporation in Hong Kong with a business registration and a physical office before you apply for the MSO license. Book a free discussion call and find out what you need before the licensing.

• Verify the identity of all your clients and customer beneficial owners (CDD) before executing transactions. The high-risk category needs enhanced due diligence.
• Mandatory staff training and implementation of policies.
• Track and report suspicious transactions as soon as you have the information to the Joint Financial Intelligence Unit (JFIU) and C&ED.
• Maintain records for at least five to six years from the start of operations.
• Appoint an MLRO, compliance officer, company secretary, and individual director.

A compliance officer is responsible for overseeing the entire anti-money laundering and CFT system, whereas an MLRO officer is the one who reports all suspicious transactions to the authority.
A qualified professional can be both the compliance officer and MLRO in a money-changing company with no restrictions on their nationality- they don’t have to be a resident of Hong Kong.

You will have to pay a fine up to HKD 1 million and face criminal prosecution with a possibility of imprisonment of up to two years because of the high risk related to money laundering and CFT in the money changing business.

• Be ready to pay up to HKD 1 million as per the seriousness of the offence.
• An additional fine of around HKD 50,000 applies if you fail to inform the authority of changes within 30 days, provide false or fabricated information, or do not display your certificate of registration at your official premises.
• Up to two years of imprisonment with a fine if you are caught operating without a license.
• Criminal prosecution in case you miss out on or deliberately fail to report suspicious transaction reports or AML/CFT compliance.
• Regular and continuous non-compliance will lead to the revocation of your permit.
• Disqualified directors and promoters will be blacklisted from further employment in the regulatory and financial sector.

You simply avoid the above by following proper anti-money laundering and CFT regulations, regularly reporting the STRs, maintaining records, only appointing competent and qualified staff, and having a proper setup in Hong Kong.

Without a doubt, your license can absolutely cover both remittance and money changing in case you want both, or you can simply go for either of the two.
The only thing to keep in mind is that you can only provide services that are within the scope of your MSO license. Anything outside the scope will land you in legal trouble and hefty financial difficulties due to penalties.

We not only submit your form for application for approval but also take care of your complete paperwork, structuring, lease agreement signing, AML/CFT framework development, liaison support, and ongoing compliance after licensing, like filing STR reports and annual submissions.

Your license can only assist you in operating through fiat currency. You cannot have crypto-fiat conversion, trading of virtual assets, or remittance of cryptocurrency because they are covered under different licenses as issued by the Securities and Futures Commission (SFC).

Online money transfers, digital remittance apps, businesses engaged in selling, buying, & exchanging foreign currencies, companies involved in cheque-cashing services, and electronic money transfer facilitators.