Hong Kong’s Updated Anti-Money Laundering Guidelines for Professional Accountants: A New Regulatory Landscape

Effective Date: 1 June 2023

Background

March 2023: The Hong Kong Institute of Certified Public Accountants (The Institute) has published updated guidelines on Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) for professional accountants.
2018 and 2022 Amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615): The latest updates extend AML/CFT requirements to cover designated non-financial businesses and professions (DNFBPs), such as accounting professionals.

Overview and Application

Goal: The guidelines provide comprehensive guidance on AML/CFT requirements under AMLO and other relevant legislation. Scope: Primarily for practices and their members in Hong Kong; valuable for members in the financial services sector.

Key Changes in the Guidelines

Enhanced Policies, Procedures, and Controls:
- Robust policies, procedures, and controls to address AML/CFT concerns (STRs, targeted financial sanctions, and terrorist financing).
- Regular reviews and updates to policies.
Risk Assessment and Management:
- New business services and products.
- Technologies.
Ongoing Monitoring:
- Regular firm-wide risk assessments.
- Risk-based approach to manage potential ML/TF risks.

The Role of Hong Kong Institute of Certified Public Accountants

Regulatory Body: The Hong Kong Institute of Certified Public Accountants publishes and amends the guidelines.
Support: Training, publications, and initiatives to enhance practices’ AML/CFT knowledge and skills.

Sections of the Updated Guidelines

Policies, procedures, and controls
Customer due diligence (ID verification, risk assessment, ongoing monitoring, etc.)
Making Suspicious Transaction Reports (STRs)
Targeted financial sanctions and terrorist financing
Record keeping
Staff hiring and training

For more detailed information, refer to the official updated guidelines document.