1.1 Purpose

The purpose of AML regulations is to prevent and detect money laundering and the financing of terrorism. Money laundering refers to the process of concealing the origins of illicit funds to make them appear legitimate.

1.2 Compliance Responsibilities

We are committed to complying with all applicable AML regulations and guidelines issued by regulatory authorities in Hong Kong. We have designated a compliance officer who is responsible for overseeing our AML program, ensuring compliance, and reporting suspicious activities to the relevant authorities.

1.3 Customer Due Diligence (CDD)

We conduct thorough customer due diligence to verify the identity and assess the risk of potential customers. CDD procedures include:

1.4 Reporting Suspicious Activities

We have established internal procedures for employees to report any suspicious activities or transactions that may be related to money laundering or terrorist financing. All reports will be treated confidentially, and employees will be protected from any retaliation for making such reports in good faith.

2.1 Purpose

KYC requirements aim to verify and understand the identity, financial activities, and risk profile of customers. This helps prevent fraud, identity theft, and other illegal activities.

2.2 Customer Identification Program (CIP)

We have implemented a Customer Identification Program to verify the identity of our customers. The program includes:

2.3 Risk-Based Approach

We adopt a risk-based approach to KYC, which involves assessing the risk associated with each customer and applying appropriate due diligence measures based on the risk level. Factors considered may include the customer's nature of business, geographic location, and transaction patterns.

2.4 Record Keeping

We maintain records of customer identification information, transaction details, and supporting documents in accordance with applicable laws and regulations. These records are securely stored and made available to regulatory authorities upon request.

3.1 Compliance Monitoring

We have implemented internal controls and monitoring processes to ensure ongoing compliance with AML and KYC regulations. Regular internal reviews and audits are conducted to assess the effectiveness of our AML program and identify areas for improvement.

3.2 Training and Awareness

We provide regular training to our employees to raise awareness of AML and KYC obligations and ensure their understanding of relevant laws, regulations, and internal policies. Training programs cover identification of suspicious activities, reporting procedures, and the importance of compliance.

4.1 Reporting Obligations

We are committed to reporting any suspicious activities, as required by law, to the appropriate regulatory authorities, such as the Hong Kong Police Force and the Joint Financial Intelligence Unit (JFIU). We will promptly file suspicious transaction reports (STRs) and cooperate fully with authorities in their investigations.

4.2 Data Protection and Confidentiality

We handle customer information in accordance with applicable data protection laws and maintain strict confidentiality regarding any information related to suspicious activities, investigations, or reports.