MSO Licence Renewal
Normally, the validity period of a Money Service Operator (MSO) licence granted will be 2 years. The licensee is required to apply for renewal of the licence not later than 45 days before the licence is due to expire. You will receive a reminder from the Customs to renew the licence.
The Key Requirements for MSO Licence Renewal
WHAT ARE THE LICENSEE’S ONGOING OBLIGATIONS?
(a) A licensee must report on suspicious transactions;
(b) A licensee must develop and maintain an effective AML Policy to mitigate ML/TF risks;
(c) The individual in relation to a licensee must remain fit and proper at all times;
(d) A licensee must ensure at least one of the directors having passed the Assessment;
(e) A licensee must submit periodic return to the CCE in the form specified by the CCE in a timely manner; and
(f) Where bank account(s) is used for operation of the money service business, the bank account must be in the name of the licensee’s company, director or ultimate owner of the licensee.
WHAT ARE THE PARTICULARS THAT AN MSO LICENSEE NEEDS TO NOTIFY THE CUSTOMS FOLLOWING THE CHANGES?
For the changes in particulars, the licensee must notify the Customs in writing of the changes within one month beginning on the date on which such change takes place.
(a) Change in business / corporation name
(b) Change in principal (correspondence) address
(c) Change in contact information
(d) Change in business premises information
(e) Change in particulars of directors and/or ultimate owners
(f) Change in “Fit and Proper” status of director and/or ultimate owner
(g) Change in bank account used for operating money service business
(h) Change in CO or MLRO
WHY MAY THE CUSTOMS REFUSE TO GRANT A LICENCE RENEWAL?
(a) the licensee or anyone within the business fail to satisfy the fit and proper person test;
(b) the premises to be used are not suitable for the operation of a money service;
(c) the licensee fails to provide Business Plan and AML Policy in accordance with the relevant guidelines promulgated by the Customs;
(d) the licensee fails to appoint a competent Compliance Officer (CO) or Money Laundering Reporting Officer (MLRO);
(e) the licensee submits an incomplete or invalid application;
(f) none of the senior management of a licensee attends or passes the Assessment designated by the Customs;
(g) the licensee fails to submit a periodic return on time;
(h) the licensee fails to fulfill the purpose (i.e. provision of money service) for which the licence was issued; and
(i) the licensee fails to comply with any requirements provided under the AMLO including requirements stipulated in Part 5 of the AMLO.
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.
MAIN SERVICES:
➤ Reassessing the operational model and business workflows
➤ Updating the "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
➤ Supplying preparatory materials for the interview with Customs
➤ Following up on all inquiries from the Customs throughout the process
SUPPORTING SERVICES:
➤ Recruitment of directors and/or compliance officers
➤ Provision of a trading system
➤ Provision of an AML screening system
External Reference
Licensing Guide:
https://eservices.customs.gov.hk/MSOS/download/guideline/Licensing_Guide_en.pdf
Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Money Service Operators):
https://eservices.customs.gov.hk/MSOS/download/guideline/AMLO_Guideline_en.pdf
Disciplinary Action Guideline on Imposition of Pecuniary Penalty:
Disciplinary Fining Guideline:
https://eservices.customs.gov.hk/MSOS/download/guideline/Fining_Guideline_en.pdf
Guideline on Criteria for Determining Fitness and Propriety:
Competence Assessment:
Contact Us
For more information or to request a quotation, please feel free to contact us:
WhatsApp: +852 39550277
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Email: info@complianceone.hk