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Money Service Operator (MSO)

Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong

Tel：+852 3955 0277

Email：info@complianceone.hk

繁｜簡｜EN

According to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (the “AMLO”), Chapter 615 of the Laws of Hong Kong, the Hong Kong Customs and Excise Department (the "Customs") is the authority for regulating the money service operators (MSO) with effect from 1 April 2012. If a person who operates or wishes to operate a money service, he or she is required to apply for a licence.

WHAT ARE MONEY SERVICES?

Money service means a money changing service or a remittance service

A. Money Changing service means a service for exchanging of currencies that is operating in Hong Kong as a business, but does not include such a service that is incidental to the main business e.g. retail business accepting foreign currencies in transactions or that is operated by a person who manages a hotel

 

B. Remittance service means a service of one or more of the following that is operated in Hong Kong as a business -

(a) ​sending, or arranging for the sending of, money to a place outside Hong Kong; 

(b) receiving, or arranging for the receipt of, money from a place outside Hong Kong; 

(c) arranging for the receipt of money in a place outside Hong Kong.

WHAT ARE THE EXEMPTIONS?

Yes, according to the AMLO, the MSO licensing requirement does not apply to the following situation:

(a) Government;

(b) Authorized Institution (i.e. Bank);

(c) Licensed Corporation, regulated by the SFC;

(d) Authorized insurer;

(e) Authorized insurance broker;

(f) Appointed insurance agent;

(g) SVF licensee; or

(h) System operator or settlement institution of a designated retail payment system.

The Key Requirements to apply for a MSO Licence

WHAT ARE THE ELIGIBILITIES TO APPLY FOR A LICENCE?
(a) The Applicant, including the Ultimate Owner and Director, meets the Fit and Proper requirements.
(b) The management team fully understands the business of a money service.
(c) The Premises used for the operation of a Money Service is suitable.
(d) Local Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO) is appointed.

WHAT ARE THE FIT AND PROPER PERSON CRITERIA?
(a) Except for traffic contraventions, whether the person has been convicted for an offence in Hong Kong or in a place outside Hong Kong;
(b) Whether the person has been convicted for an offence relating to money laundering or terrorist financing, or has failed to comply with any requirement imposed under the AMLO or any regulation made by the CCE under section 51;
(c) Whether the person, being an individual, is an undischarged bankrupt;
(d) Whether the person is the subject of any bankruptcy proceedings under the Bankruptcy Ordinance, Chapter 6 of the Laws of Hong Kong.

Before You Start

 ➤ Incorporate a Hong Kong limited company.
 ➤ Appoint a board of directors who can likely pass the Competence Assessment (the Exam).
 ➤ Recruit a local Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO).
 ➤ Confirm arrangements with your professional service providers.
 ➤ Inform your existing clients about your new business plan.
 ➤ Consult your bank about opening an account for money service operations.
 ➤ Develop a detailed business plan with operational workflows.

What ComplianceOne can do for you

ComplianceOne Consulting Limited ("ComplianceOne") is a leading specialist in Money Service Operator (MSO) licensing and a well-established regulatory compliance consultancy in Hong Kong.

 

We have successfully processed hundreds of license renewals and new applications. Our expertise extends beyond licensing to a full suite of MSO-related services, including external AML audits, institutional risk assessments, and mergers & acquisitions support. Our highly popular mock examination papers have helped hundreds of directors prepare for and pass the Competence Assessment exam each year.

 

In the past few years alone, we have secured MSO licenses for nearly twenty clients. Our diverse clientele ranges from traditional brick-and-mortar money changers to innovative, technology-driven online remittance companies, serving businesses both locally and from key global markets including Southeast Asia, the Middle East, Africa, Europe, South America, and the USA.

MAIN SERVICES:

   ✔  Preliminary Assessment and Feasibility Analysis

         ▇  Review of the "Fit and Proper" status of shareholders, directors, and ultimate owners

         ▇  Planning of human resource arrangements

         ▇  Suitability assessment of the business premises

         ▇  Compliance review of the operational model and business workflows

   ✔  Drafting a detailed "Business Plan" and "Anti-Money Laundering and Counter-Terrorist Financing Policy" in accordance with Customs guidelines

   ✔  Preparing all required forms, declarations, and supporting documents

   ✔  Submission of the license application to the Customs on your behalf

   ✔  Providing training and support for the Competence Assessment examination

   ✔  Supplying preparatory materials for the interview with Customs

   ✔  Following up on all inquiries from the Customs throughout the process

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SUPPORTING SERVICES:

   ✔  Incorporation of a Hong Kong limited company

   ✔  Recruitment of directors and/or compliance officers

   ✔  Provision of a trading system

   ✔  Provision of an AML screening system

Anticipated Timeline

The Money Service Operator (MSO) license is highly sought after due to its wide range of applications and international recognition, leading to a significant increase in applications from both local and overseas applicants in recent years. To maintain the high standard of Hong Kong's money service industry, the Hong Kong Customs and Excise Department adopts a prudent and stringent approach in processing each application, resulting in a relatively lengthy overall processing cycle.

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Furthermore, Customs requires applicants to be fully prepared and operation-ready at the time of submission. Therefore, the entire process—from preliminary preparation, scheduling and taking the Competence Assessment, arranging interviews, and undergoing premises inspections, to the internal review by Customs—typically takes 6 to 12 months or longer.

Application process

Contact Us

For more information or to request a quotation, please feel free to contact us:
WhatsApp:   +852 39550277
WeChat:        ComplianceOneHK
Email:            info@complianceone.hk

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