Our global sanctions screening includes most international sanctions lists to identify whether your customer or potential customers is not on the list.

The checks are essential to remain compliant with Guidelines on Anti-Money Laundering (“AML”) and Counter-Financing of Terrorism (“CTF”) for Licensed Corporations and Authorized Institutions that are required respectively to do take this risk-based approach.

Hong Kong does not implement sanctions above and beyond those imposed by the UNSC. However, it has implemented local legislation that is supplemental to the relevant sanctions measures. For example, the AMLO imposes on financial institutions authorized by the Hong Kong Monetary Authority (HKMA) additional requirements relating to customer due diligence, transaction monitoring and record-keeping and provides the HKMA with powers to supervise compliance with those requirements.

Institutions are required to perform CDD to ascertain at least whether their customers have involved in any offences under the AMLO, Drug Trafficking (Recovery of Proceeds) Ordinance (DTROP), the Organised and Serious Crimes Ordinance (OSCO), etc.

Contravention of the relevant provisions under the UNATMO shall be punishable on summary conviction by a fine of HKD100,000 and imprisonment for two years, or on conviction on indictment by an unlimited fine and imprisonment for 14 years. Section 12(1) of the UNATMO requires a person to report his knowledge or suspicion of terrorist property to an authorized officer (e.g. the JFIU). Failure to make a disclosure under this section constitutes an offence under section 14(5). The maximum penalty upon conviction of this offence is a fine of HK50,000 and imprisonment for three months.

Contravention of sanctions under the UNSO shall be punishable on conviction on indictment by an unlimited fine and imprisonment for a term not exceeding 7 years.

All persons are required to report any asset frozen or actions taken in compliance with the targeted financial sanctions requirements by filing a Suspicious Transaction Report to the Joint Financial Intelligence Unit (JFIU), which is jointly run by staff members of the Hong Kong Police Force and the Hong Kong Customs & Excise Department.

The Commerce and Economic Development Bureau (CEDB) has overall responsibility in implementing the United Nations Sanctions in Hong Kong. Individuals or entities affected by targeted financial sanctions because of mistaken identification or confusion with individuals or entities on the relevant sanctions lists may submit written requests for clarification to the Commerce, Industry and Tourism Branch of CEDB, after requesting an explanation from the institution that froze the assets.

The Hong Kong Monetary Authority (HKMA) and Securities and Futures Commission (SFC) are responsible for supervising compliance by authorized and licensed institutions with financial sanctions in Hong Kong.