AML/CFT Regulated Entities in Hong Kong
Table of Contents
- March 17, 2026
- Pathik Shah
AML/CFT Regulated Entities in Hong Kong- Key Takeaways
- AML/CFT regulated entities in Hong Kong are organisations or individuals that are supervised and controlled by supervisory authorities under the AMLO scope.
- Financial institutions that must comply with AMLO in Hong Kong include banks, securities, authorised insurers and brokers, money service operators, money lenders, stored value facilities, and VASPs.
- The DNFBPs sectors regulated under AMLO include legal professionals, accounting professionals, trust or company services providers, estate agents, and dealers in precious metals and stones.
- AML Consultants HK helps AML/CFT regulated entities in Hong Kong by implementing CDD, drafting policies and procedures, and providing staff training.
What Does It Mean by AML/CFT Regulated Entities?
AML/CFT Regulated entities are organisations or individuals that are licensed, supervised, and controlled by regulatory authorities in Hong Kong to ensure they follow AML/CFT laws and regulations
In Hong Kong, the AML/CFT regulated entities, including FIs and DNFBPs, must comply with the obligation set by the Anti-Money Laundering and Counter Terrorist Financing Ordinance (AMLO), which clarifies AML obligations in Hong Kong, who they apply to, and requires regulated entities to implement customer due diligence, record-keeping, and suspicious transactions reporting.
Types of Financial Institutions Regulated Under AMLO
The following types of financial institutions are considered AML-regulated entities under AMLO:
Categories of financial institutions covered under AMLO
Banks
Banks are licensed and supervised by the Hong Kong Monetary Authority (HKMA), which includes licensed banks, restricted license banks, deposit-taking companies and local representative offices of foreign banks.
Securities
Securities firms in Hong Kong include securities trading, brokerage, asset management, and investment advisory. They are regulated by the Securities and Futures Commission (SFC), which imposes restrictions and takes action against the entities that fail to comply with AML/CFT regulations.
Authorised Insurers and Brokers
Authorised insurers and brokers include insurers carrying on long-term business and intermediaries carrying on regulated activities in respect of long-term business. They are regulated by the Insurance Authority (IA) of Hong Kong, ensuring that the companies do not help criminals in money laundering or finance terrorism.
Money Service Operators
Money service operators provide money remittance and currency exchange services, regulated by the Customs & Excise Department, enabling them to prevent financial crime.
Money Lenders
Money lenders who provide their own money to people or businesses, and earn from interest or loans, are supervised by the Companies’ Registry, which ensures that lending activities are not used for illegal activities.
Stored Value Facilities (SVF) Licensees
The stored value facilities allow users to store value for payments and are essential for prepaid cards and digital wallets. They are supervised by the Hong Kong Monetary Authority (HKMA).
Virtual Assets and Service Providers (VASPs)
The virtual assets and service providers include a VA trading platform operator or services involving digital assets, which are regulated by the Securities and Futures Commission (SFC).
AML Compliance Guidance for Regulated Entities in Hong Kong
Understand how AML/CFT regulated entities in Hong Kong must meet their obligations and who must comply with AMLO
Types of DNFBPs Regulated Under AMLO
DNFBPs that must comply with AML regulations in Hong Kong:
Categories of DNFBPs covered under AMLO
Legal Professionals
Legal professionals, including solicitors, barristers, registered foreign lawyers, Hong Kong law firms, and registered foreign law firms regulated by the Law Society of Hong Kong, provide key legislation, guidance, and support publications to help members detect ML/TF/PF risks.
Accounting Professionals
Accounting professionals include accountants, accounting firms, and audit practitioners, regulated by the Hong Kong Institute of Certified Public Accountants (HKICPA).
Trust or Company Services Providers (TCSPs)
TCSPs in Hong Kong offer essential services, including company formations. TCSP licensing AML Hong Kong is administered by the Companies Registry and requires a licence to operate and comply with AML obligations under AMLO.
Estate Agents
Estate agents include real estate agents and salespersons, regulated by the Estate Agent Authority, ensuring that AML/CTF rules are enforced so that estate agents do not help criminals launder money or finance terrorism.
Dealers in Precious Metals and Stones (DPMS)
Dealers in precious metals and stones include businesses dealing with high-value metals and gemstones, which are regulated by the customs and excise department to prevent financial crime.
How AML Consultants HK help AML/CFT Regulated Entities in Hong Kong
AML Consultants HK help AML/CFT Regulated Entities in Hong Kong by implementing effective customer due diligence to verify, identify, and assess the customer risks.
It helps in drafting clear policies and procedures for regulated entities to stay compliant and supports regulatory inspections.
AML Consultants HK provide AML staff training to ensure knowledge of regulatory requirements and effectively apply AML controls, aligning with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).
FAQs- AML/CFT Regulated Entities in Hong Kong
Who are the regulatory bodies for AML and CFT?
The regulatory body for AML/CFT includes the Hong Kong Monetary Authority (HKMA), Securities and Futures Commission (SFC), Insurance Authority, Money Service Supervision Bureau, C& ED, Law Society of Hong Kong, Hong Kong Institute of Certified Public Accountants, Estate Agents’ Authority, and Companies’ Registry.
Who is considered a regulated entity under Hong Kong’s AML/CFT framework, and who must comply with AMLO?
AML/CFT regulated entities in Hong Kong include financial institutions and designated non-financial businesses and professionals (DNFBPs) that must comply with AML obligations.
What AML obligations apply to regulated entities in Hong Kong?
The obligations apply to AML-regulated entities in Hong Kong, including CDD, transaction monitoring, record-keeping, and reporting suspicious transactions to JFIU.
What penalties can regulated entities face for AML/CFT non-compliance in Hong Kong?
Regulated entities for non-compliance in Hong Kong may face fines, penalties, imprisonment, and revocation or suspension of licences.
Build a Stronger AML/CFT Compliance Framework
AML Consultants HK helps FIs and DNFBPs to be regulatory ready with clear AML policies, procedures, documentation, and trained staff.
About the Author
Pathik Shah
Founder | FCA, CAMS, CISA, CS, DISA (ICIAI), FAFP (ICAI)
Pathik Shah is a Chartered Accountant with more than 28 years of experience working at the juncture of governance, compliance, and financial risk. His work has consistently focused on helping institutions in Hong Kong to operate confidently within regulated environments, particularly where AML/CFT obligations demand practical implementation.
As part of his role with AML Consultants HK, Pathik is involved in working with various financial institutions and DNFBPs so that not only are their AML frameworks compliant from a regulatory standpoint under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), but they are also effective from a supervisory review expectations standpoint. Aside from that, Pathik has served as a functional expert in the development and deployment of RegTech solutions to enhance monitoring discipline and documentation integrity. Additionally, he has assisted institutions in understanding the FATF requirements and how to implement them within the Hong Kong context in an operationally feasible manner.
Pathik is a recognised thought leader in AML/CFT and frequently shares insights on trends in financial crime risks and developing supervisory approaches on various platforms.
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