Money Changing and Remittance Services

Money Changing Service

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 if the service:

  1. is operated within the premises of the hotel primarily for the convenience of guests of the hotel;

  2. consists solely of transactions for the purchase by that person of non‐Hong Kong currencies in exchange for Hong Kong currency.

Remittance Service

Remittance Service means a service of one or more of the following that is operated in Hong Kong as a business:

  1. sending, or arranging for the sending of, money to a place outside Hong Kong;

  2. receiving, or arranging for the receipt of, money from a place outside Hong Kong;

  3. arranging for the receipt of money in a place outside Hong Kong.

Scope of Business

Money Service Operator (MSO)

Anti-Money Laundering and Counter-Terrorist Financing Ordinance (the “AMLO”), Chapter 615 of the Laws of Hong Kong, mandates the Hong Kong Customs and Excise Department as the regulatory authority over money service operators with effect from 1 April 2012.

Any person or institution operating a money service should be licensed with the Commissioner of Customs and Excise.

Having trouble applying to be a money services operator?

We provide one-stop consultancy services to assist you in applying for a money service operator license, including preparation of business plan and compliance policy, advising on the suitability of potential store from lease and design perspectives, etc. We can also help on the ongoing compliance with the statutory requirements and the renewal of the money service operator license.

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Scope of Business

  1. Provide consultation (face-to-face and telephone)
  2. Review and evaluate the background of the applicant(s) for “Fit and Proper” Person(s)
  3. Provide compliance advisory recommendations regarding customer due diligence, record-keeping obligations and other licensing requirements
  4. Prepare and submit MSO licence application documents including forms, supplementary documents and business plan to Hong Kong Customs and Excise Department (the “Customs”)
  5. Handle preliminary enquiries from the Customs upon MSO licence application
  6. Arrange meetings with C&ED officers:
    (a) Arrange and accompany the “Authorized Person(s)” to attend face-to-face meeting with the Customs;
    (b) Arrange on-site visit at the Particular Premises with the Customs and the “Authorized Person(s)”;
  7. Liaise and follow-up with the Customs on the MSO licence until the application is approved by the Customs;

Application Procedure

1

Application

Applicant submits the MSO Licence Application to the Customs and Excise Department, and receives a "Notice of Receipt of Application".
2

Notice of Meeting

Customs and Excise Department issues "Notice of Meeting" and "Payment Form for Licence and Proper Person Determination Fee"
3

Meeting

Customs and Excise Department inspects original application documents and payment proof, and conducts interview with applicant.
4

On-Site Inspections

Customs and Excise Department conducts an on-site inspections against the proposed place of business.
5

Fit and Proper

Customs and Excise Department obtains records of suitability from other agencies
6

Grant of License

Applicant collects the MSO Licence from Customs and Excise Department

Application process

  1. Appoint MSO Compliance as your Consultant.

  2. Register a Hong Kong Company, rent a premises and finish decoration.

  3. We will arrange a site visit at the premise and provide operational advice and discuss the Business Plan and AML policy.

  4. Prepare the application forms) and provide with relevant documents.

  5. Submit application documents(s) to Hong Kong Customs and Excise Department.

  6. The Customs issues an acknowledgement receipt to the Applicant.

  7. The Customs issues letter through email to gather additional information and documents.

  8. The applicant will receive a notice for an interview together with a demand note for the payment of fees regarding the application.

  9. Provide CPT training to the Applicant by MSO Compliance.

  10. Face-to-face meeting with the Customs and Excise Department.

  11. The Customs and Excise Department will issue letter by email to request additional information and documents from the Applicant.

  12. The Customs and Excise Department passes the identification information to other government departments (including Hong Kong Police Force and Official Receiver s Office) for background check.

  13. The Customs and Excise Department will conduct a site visit at the premises of the Applicant.

  14. The Customs and Excise Department will issue letter through email to request additional information and documents from the Applicant.

  15. MSO licence is granted by the Customs and Excise Department.

Eligibility for a Licence

  1. “Fit and Proper Person” includes Partner/ Ultimate Owner and Corporate Director (see section of ‘Meaning of “Fit and Proper Person”‘ below)

  2. Appointment of a Compliance Officer (CO) and a Money Laundering Reporting Officer (MLRO) (implemented since November 2018)
    ✔ Requirement: CO and MLRO should always be stationed in Hong Kong

  3. Particular Premises used for the operation of a Money Service – retail shop/ commercial office/ residence
    ✔ A copy of stamped tenancy agreement or record of ownership of the premises should be provided
    ✔ A floor plan of the premises should be provided
    ✔ Landlord consent letter

  4. Bank Account(s) used for operating the Applicant’s Money Service:
    ✔ Details should include Name of Account Holder, Name of Bank and Account Number

Fit and Proper Person

  1. Except for traffic contraventions, whether the person has been convicted for an offence in Hong Kong or in a place outside Hong Kong

  2. 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

  3. Whether the person, being an individual, is an undischarged bankrupt

  4. Whether the person is the subject of any bankruptcy proceedings under the Bankruptcy Ordinance, Chapter 6.

SaaS exchange & remittance system

  1. Assist in managing and following various tedious compliance procedures, and prepare complete money service transaction reports to pass customs compliance review.

  2. Assist money service providers to process transaction processes, automatically collect transaction data and information required by customs, provide professional and reliable services, and calmly face ever-changing laws and regulations.

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