Global Currency Exchange Limited ("GCE") is committed to strict compliance with Hong Kong's anti-money laundering and counter-terrorist financing legal framework as a core business value. This disclosure outlines GCE's compliance commitments, policy framework and operational measures in respect of financial crime prevention.
1. Regulatory Framework
Global Currency Exchange Limited operates under a Money Service Operator (MSO) licence issued by the Hong Kong Customs & Excise Department under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) ("AMLO"). We are committed to full compliance with AMLO and applicable guidance issued by the Financial Action Task Force (FATF).
As a licensed MSO, GCE is subject to the customer due diligence (CDD) and record-keeping requirements set out in Schedule 2 of AMLO, the obligation to report suspicious transactions to the Joint Financial Intelligence Unit (JFIU), and all supervisory circulars and guidance issued by the Customs & Excise Department in respect of MSO operations.
2. AML/CFT Programme
GCE maintains a comprehensive AML/CFT programme comprising the following key elements:
- A Board-approved AML/CFT Policy and Procedures Manual, reviewed annually;
- Appointment of a designated Compliance Officer with overall responsibility for AML/CFT compliance and internal reporting;
- Risk-based client due diligence (CDD) procedures, with the level of diligence calibrated to client risk profile;
- Ongoing monitoring of all transactions to identify unusual patterns and suspicious behaviour;
- Suspicious Transaction Reporting (STR) to the Joint Financial Intelligence Unit (JFIU);
- Annual AML/CFT risk assessments to identify, assess and mitigate the money laundering and terrorist financing risks to which GCE is exposed;
- Periodic independent compliance reviews and audits; and
- Mandatory AML/CFT training programmes covering all relevant staff.
3. Know Your Business (KYB)
All clients undergo rigorous KYB verification prior to account activation. GCE's KYB process encompasses the following verifications:
- Corporate registration verification, including company status, jurisdiction of incorporation and regulatory status (where applicable);
- Beneficial ownership identification: Identification and verification of all ultimate beneficial owners (UBOs) holding 10% or more of the entity's equity, directly or indirectly (UBO threshold: 10%);
- Director and officer identity verification for all directors and senior officers;
- Source of funds and source of wealth documentation, to assess the legitimacy of client funds;
- Assessment of business nature, target customer base and expected transaction volumes and patterns; and
- Screening against sanctions lists, politically exposed persons (PEP) databases and adverse media records.
For higher-risk clients, account applications require approval by GCE's Compliance Officer or senior management. GCE also conducts ongoing due diligence on all client relationships, including periodic and event-triggered reviews.
4. Enhanced Due Diligence (EDD)
GCE applies Enhanced Due Diligence (EDD) to clients presenting higher-risk characteristics, including but not limited to:
- Politically Exposed Persons (PEPs) and their family members or close associates;
- Clients from high-risk or enhanced-monitoring jurisdictions per FATF guidance;
- Clients involving complex corporate structures or nominee shareholding arrangements;
- Clients with transaction volumes or patterns inconsistent with their declared business nature;
- Clients with adverse media records or involvement in regulatory investigations; and
- Any other client where GCE's compliance team determines that a higher level of scrutiny is warranted.
EDD measures may include obtaining additional documentation, conducting direct client interviews, obtaining senior management approval for high-risk transactions, and applying enhanced ongoing monitoring.
5. Transaction Monitoring
GCE applies automated and manual monitoring of all transactions processed through its platform. The monitoring system uses rule-based detection and behavioural analytics to identify suspicious patterns including:
- Unusually large transactions without apparent business purpose;
- Transactions inconsistent with the client's declared business nature or historical behaviour;
- Structuring transactions to avoid reporting thresholds;
- Frequent transfers to or from high-risk jurisdictions; and
- Transactions involving sanctioned entities or individuals as counterparties.
Transactions flagged by the system are subject to manual review by the compliance team. Confirmed suspicious transactions are reported to the JFIU via a Suspicious Transaction Report (STR) under the Organized and Serious Crimes Ordinance (Cap. 455) and the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575), without tipping off the client ("tipping-off prohibition").
6. Prohibited Activities
GCE will not provide services to any of the following:
- Entities or individuals listed on international sanctions lists, including OFAC (US Treasury), EU, UN and Hong Kong sanctions lists;
- Entities from jurisdictions on the FATF blacklist;
- Entities engaged in virtual asset, cryptocurrency or stablecoin activities (GCE does not support any virtual asset transactions);
- Shell banks or entities maintaining correspondent relationships with shell banks;
- Entities unable to demonstrate a legitimate business purpose or source of funds; and
- Any other entity declined by GCE's compliance team based on a reasonable assessment of money laundering or terrorist financing risk.
GCE conducts sanctions screening on all clients and counterparties at onboarding and on an ongoing basis, and subscribes to real-time sanctions list update services to ensure screening is performed against the most current lists.
7. Record Keeping
In compliance with section 20 of AMLO, all client records and transaction data are retained for a minimum of six (6) years. Records retained include:
- Client due diligence documents and KYB verification materials;
- Complete transaction records, including amounts, currencies, dates and counterparty information;
- Internal suspicious transaction reports and records of related compliance decisions;
- STRs submitted to JFIU; and
- Client correspondence and due diligence enquiry records.
All records are stored in a secure, encrypted format and are accessible for regulatory inspection upon request.
8. Staff Training
All GCE staff involved in client-facing and compliance roles complete mandatory AML/CFT training annually. Training covers:
- The Hong Kong AML/CFT legal framework and regulatory requirements, including AMLO and applicable FATF Recommendations;
- Common money laundering and terrorist financing typologies and red flags;
- GCE's internal reporting procedures and suspicious transaction identification standards;
- Sanctions compliance and screening procedures; and
- Individual legal obligations, including criminal penalties for failure to report or committing tipping-off offences.
Training records are maintained and available for regulatory inspection. New staff complete AML/CFT training within 30 days of joining GCE.
9. Reporting & Contact
For AML/CFT enquiries or to report concerns about suspicious activity, please contact GCE's compliance team:
- Email: compliance@gce.hk
- Post: Compliance Officer, Global Currency Exchange Limited, Hong Kong SAR
Suspected criminal activity may also be reported directly to the Joint Financial Intelligence Unit (JFIU):
- Telephone: +852 2866 3366
- Website: www.jfiu.gov.hk