Hong Kong MSO Licence Application
Your Gateway to Asia’s Financial Hub
Navigating complex regulations and obtaining licences can be time-consuming. Hong Kong offers a simplified process for securing a Money Service Operator (MSO) Licence, allowing you to provide services like currency exchange and remittance in one of Asia’s leading financial centres.
Your External Compliance Team: We’ll guide you through the application process with the Hong Kong Customs and Excise Department (C&ED), prepare all necessary documentation, and ensure compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).
Comprehensive Support: From legal consultation to document preparation, office registration, and AML policy development, we provide a one-stop service to simplify the MSO licensing process and save you time.
Fast Application Expertise: We’ll assist you with a streamlined process to obtain the MSO licence in 7-9 months.
Ready to offer financial services in Hong Kong? Let’s partner up! Contact us today.
- Currency Exchange Service
Once licensed, you can provide currency exchange services in Hong Kong. This service does not include incidental exchanges, such as those conducted by retail businesses accepting foreign currencies or hotel operators offering currency exchange solely for the convenience of their guests.
- Remittance Service
You can provide money transfer services to or from Hong Kong, including arranging international remittances. For example:
(a) sending or arranging the sending of money to locations outside Hong Kong;
(b) receiving or arranging for the receipt of funds from abroad; and
(c) organising the receipt of money in locations outside Hong Kong.
- Digital Financial Services
Extend your business to online or mobile platforms, adapting to the increasing demand for digital financial services.
- Prime Financial Hub: Operate in one of Asia’s most dynamic financial centres, enhancing your business credibility and market reach.
- Simplified Process: The MSO application process in Hong Kong is straightforward and without excessive regulatory burdens.
- Cost-effective and Efficient: Take advantage of a clear, predictable process with no capital requirements and competitive licensing fees.
- Enhance Business Value: An MSO licence increases your business legitimacy, attracting more clients and investors.
The Customs and Excise Department (C&ED) regulates Money Service Operators under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO). This framework ensures that licensed operators meet strict standards of business conduct, while remaining agile to adapt to changing market needs.
- Company Eligibility: A Hong Kong registered company is preferred (with limited or unlimited liability). Both Hong Kong residents and non-residents can operate under an MSO licence.
- Fit and Proper Person Test: One of the company directors must pass a “Fit and Proper Person” test conducted by C&ED. This test ensures that individuals with criminal records, bankruptcies, or corrupt practices are excluded from managing or owning a licensed entity.
- Premises Registration: A registered office address is required where the company’s business activities and meetings will be conducted. This must be authorised by the landlord through a formal agreement and approved by a representative of the C&ED. If no dedicated premises are available for the money service operation, a local management office (LMO) must be designated for storing the business’s books and records.
- Document Requirements: This includes corporate documents such as a business registration certificate; personal details for all directors, partners, and Ultimate Beneficiary Owner; a business plan; AML and IT policies; and an authorization letter signed by all partners or board members authorising the submission of the application.
- Interview and Competency Assessment: As part of the application process, the company must undergo a face-to-face interview conducted by the C&ED. This interview will assess the company’s preparedness and competency in operating a money service business in compliance with regulatory standards.
- Restrictions: Companies that have declared bankruptcy, have not been reinstated in their rights, or have managers with criminal records are not eligible for an MSO licence.
| 1st month | 2nd month | 3rd month | 4th month | 5th month | 6th month | 7th month | 8th month | 9th month |
|
|---|---|---|---|---|---|---|---|---|---|
| Rent an Office | Agreement signing | Structure Changes | |||||||
| Business plan and AML policy application | Document Preparation | Document Drafting and Finalization | Application Form | Interview with Regulator and Submission of Application | |||||
| Corporate Account | Negotiate with Bank | Submit account opening application & KYC | Inject Capital Funds | ||||||
| Escrow Account | Compliance Review Q&A | Obtain Letter of Commitment | |||||||
| IT System | Create virtual account and build a website | Revise project plan & prepare a user manual | Refine system & manual | Demonstrate to regulator the IT system & user manual | |||||
| Assessment | Extract key study materials | Register, prepare for Assessment | Passed Assessment | ||||||
Generally, a granted licence is valid for two years. If the licensee wishes to continue operating a money service, they must apply for renewal within 90 days but not later than 45 days before it expires.
- Costs: Expect application fees, company registration, AML/KYC solutions, and professional support like translations. Contact us for a clear breakdown.
- Timeline: The entire process, from company incorporation to final licence approval, generally takes 7-9 months, depending on the completeness of the documentation, the results of the Fit and Proper Person test, and the time taken for on-site inspections.
1. Who is required to apply for an MSO licence?
Anyone intending to conduct money service operations, such as currency exchange or remittance services, must apply for an MSO licence.
2. Are there any legal consequences if I carry out money service operations without a licence?
Yes, according to Section 29(1) of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), operating money services without the required licence can result in a fine of HKD 100,000 and imprisonment for up to six months.
3. Why is obtaining an MSO licence crucial for a financial services provider?
An MSO licence allows you to legally offer services like currency exchange, remittance, and expand your business into digital financial services in one of Asia’s largest business hubs.
4. What is the primary distinction between a currency exchange service and a remittance service?
A currency exchange service handles the conversion of currencies within Hong Kong, except for occasional exchanges in places like tourist hotels. On the other hand, remittance services involve the transfer of funds to or from Hong Kong and the organisation of those transactions.
5. Who is exempt from obtaining an MSO licence in Hong Kong?
Financial institutions that are already regulated by the Securities and Futures Commission or the Hong Kong Monetary Authority are exempt. These include authorised banks, licensed corporations, and authorised insurance companies, which generally do not need to apply for an MSO licence.
6. What are the essential steps and documents needed to obtain an MSO licence in Hong Kong?
You are required to complete a background check, register your business premise, and provide a comprehensive set of documents. These documents include company and member details, office address verification, a business plan, and anti-money laundering (AML) policy. Additionally, a non-refundable application fee must be paid as part of the process.
7. What are the guidelines for determining if a premise is suitable for money service operations?
1. The premises must be accessible to Customs and Excise Department (C&ED) officers for conducting their duties under the MSO regulatory regime.
2. If the premises are located in a mixed-use commercial and residential building, the applicant must obtain written consent from all occupants, allowing authorised C&ED personnel to enter and carry out inspections.
8. How long does the MSO application process take?
The process typically takes around 7-9 months from submission to approval.
9. What are the ongoing compliance requirements?
Regular AML/KYC reporting, office inspections, and periodic audits are required to maintain your licence.
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