SFC inspections update

AML: Hong Kong's Anti-Money Laundering and Terrorist Financing (Financial Institutions) Ordinance and related guidelines from the Securities and Futures Commission (SFC) came into force on 1 April 2012. How a licensee puts the AML requirements into practice will become one of the key areas of focus in SFC routine inspections from now on. We suggest clients take a close look at their AML systems, controls and procedures as well as their compliance and procedures manuals, to ensure they are in compliance with all the new requirements.

FRRs: The SFC takes breaches of the Financial Resources Rules seriously. During routine inspections, the SFC will be specifically looking to see that the licensee has implemented adequate systems and controls to monitor its liquid capital position (and not just its liquid asset position) on a daily basis.