Hong Kong Money Service Operator (MSO) Currency Exchange and Remittance License Sale Information Introduction

Hong Kong Money Service Operator (MSO) License for Money Exchange & Remittance – Sale Information

Basic Information

Issued Area

Hong Kong MSO License

Issued Area

Hong Kong

s

customs

Validity period

Continuously valid (annual review required)

price range

Negotiable

License information last updated

November 2025, 8

Licence Details

Transfer price Negotiable
License MSO license plate (cash and exchange)
License Date September, 2020
Office Location Tsim Sha Tsui
Office Type specified premises
Lease expiration date Flexible arrangements
Number of shareholders 2
Current monthly expenses Average monthly salary: HKD 6
Bank account DBS Hong Kong
Trading System FIS Payments One
business Yes, but not much
Disciplinary Records 无
year established 2019
Deposit/Transaction Process
Other Remarks: -

Hong Kong Money Service Operator (MSO) License Acquisition Process and Timetable

stage A detailed description Specific tasks estimated time Attention points Our (consulting company) role
1. Demand analysis and target screening Confirm business needs with customers and screen suitable MSO license holders as acquisition targets. – Understand the client’s business model (currency exchange, remittance, digital finance, etc.).

– Confirm licensing requirements (e.g. single site or multiple sites).

– Search the market for MSO licensed companies that are available for acquisition (through M&A brokers, industry networks or law firms).

– Preliminary assessment of the target company: validity period of license, business location, financial status, and compliance record.

 2 to 4 weeks – Ensure that the target company’s license scope meets the client’s needs.

– Check whether the target company has any undisclosed liabilities or regulatory penalties.

 – Assist customers to clarify their needs.

– Provide market intelligence and recommend potential acquisition targets.

– Contact an M&A broker or seller representative.
2. Due Diligence Conduct a comprehensive investigation of the target company to ensure there are no potential risks in terms of license and company status. -
Financial Investigation
: Audit the target company’s financial statements to confirm there are no significant liabilities or outstanding taxes.

-
Legal Investigation
: Check the company's establishment documents, shareholding structure, and background of directors and ultimate owners.

-
Compliance Investigation
: Confirm the validity of the MSO license (through the public list of the Customs Department), compliance record, and no violation or investigation record.

-
Operational Survey
: Review business premises lease agreements, anti-money laundering and counter-terrorism financing (AML/CFT) policies, and transaction record keeping.

– Hire lawyers and accountants to conduct professional audits.

 1 to 3 months – Discovery of undisclosed regulatory issues could cause a deal to fail.

– Overseas shareholders or complex shareholding structures may prolong the investigation time.

– Ensure that the target company has no ongoing litigation or bankruptcy proceedings.

 – Coordinate with lawyers, accountants and compliance experts to conduct due diligence.

– Provide investigation reports, highlight risk points and propose mitigation measures.

– Negotiate with the seller and obtain necessary disclosure documents.
3. Valuation and negotiation Based on the due diligence results, we evaluate the target company's value and negotiate acquisition terms with the seller. – Assess the value of the licence: Consider the remaining validity period of the licence, the number of business locations, and market demand (the market price of an MSO licence is usually between HK$100 million and HK$500 million, depending on the company’s situation).

– Draft a Letter of Intent (LOI) to specify the purchase price, payment method, and transaction structure (share transfer or asset acquisition).

– Sign a non-disclosure agreement (NDA) to protect negotiation information.

– Negotiate deal terms: e.g. transition support, employee retention, seller responsibilities.

 2 to 6 weeks – The seller’s high price expectations may lead to a negotiation deadlock.

– The transaction structure (e.g. installment payment) needs to be in the interests of both parties.

– Tax implications need to be considered (e.g. stamp duty in Hong Kong).

 – Provide valuation advice, taking into account market conditions.

– Assist in drafting LOI and NDA to ensure clear terms.

– Negotiate with sellers on behalf of clients to obtain favorable terms.
4. Regulatory Notifications and Approvals Notify the Customs Department of changes in shareholding or transfer of control to ensure compliance with AMLO requirements. – Submit Form 3 (Notification of Changes): Report changes in shareholding, directors or ultimate owners.

– Provide proof of identity of new shareholders/directors and a Fit and Proper Person Declaration.

– The Customs Department conducts a background check to confirm that the new controller has no criminal or bankruptcy record.

– If the business location or AML policy changes, you need to submit updated documents and undergo inspection.

 1 to 3 months – Time-consuming background check of new controllers (if overseas persons are involved).

– The Customs Department may require an interview or supplementary AML/CFT policy.

– If the changes are complex (e.g. multiple sites), re-approval may be required.

 - Assist in preparing Form 3 and related documents.

– Communicate with the Customs Department to ensure smooth application of changes.

– Guide clients through fit and proper candidate testing and interviews.
5. Signing and delivery of transaction documents Complete the legal documentation and execute the transaction to formally transfer control of the company. – Drafting and signing of share transfer agreements or asset acquisition agreements.

– Complete payment: one-time payment or by installment plan.

– Update company registration information: Submit shareholding/director changes (Form NSC1 or other forms) to the Hong Kong Companies Registry.

– Transfer of operational control: including business premises, transaction systems, record files, etc.

 2 to 4 weeks – Disputes over the terms of transaction documents may delay signing.

– It takes time to update the Companies Registry (usually a few days to a week).

– The seller fails to transfer the operating assets in a timely manner.

 – Coordinate with lawyers to draft transaction documents to ensure compliance with Hong Kong laws.

– Oversee the closing process and confirm payment and asset transfer.

– Assistance in filing documents with the Companies Registry.
6. Subsequent compliance and operational integration Ensure that the operation of the acquired MSO license complies with regulatory requirements and integrate customer business. – Nominate a new Compliance Officer and Money Laundering Reporting Officer and report to the Customs Department for record.

– Update AML/CFT policies and internal systems to align with client business models.

– Submit the initial transaction report (Periodic Return).

– Ensure that the business premises display the license and are subject to regular inspection by the Customs Department.

– Train employees and familiarize them with compliance procedures.

 2 to 4 weeks – Failure of the new compliance officer to complete training may delay filing.

– The AML policy update does not meet the requirements and needs to be rectified.

– Business disruption during the integration period affects compliance.

 – Provide compliance training and AML policy templates.

– Assist in setting up transaction recording system.

– Maintain contact with the Customs Department to ensure smooth follow-up inspections.
total Complete cycle from demand analysis to acquisition and operational integration 3 to 9 months -
Simple transactions
: 3 to 5 months (local company, single location).

-
Complex transactions
: 6 to 9 months (overseas shareholders, multiple locations, regulatory issues).

 – Due diligence reveals significant issues that could halt the transaction.

– Delay in approval from the Customs Department affects delivery.

– Disputes regarding transaction structure or payment.

 – Provide full-process consulting to reduce risks.

– Accelerate due diligence and regulatory communications.

– Ensure efficient execution of transaction documents.
More information about Hong Kong MSO license

Frequently Asked Questions about Hong Kong MSO License Trading

Yes, even if you purchase a ready-made license, Hong Kong Customs will still check:

  • Background of new shareholders/directors(No criminal record, legal source of funds)

  • Business Plan(Proof of compliance operation capability)

  • Anti-Money Laundering (AML) System(Must comply with the latest AMLO requirements)
    ⏳ Approval Time: Usually 4-8 weeks, complex cases may be extended to 3 months.

No. Hong Kong Customs requirements:

  • Licensed companies must be registered in Hong Kong

  • Directors/shareholders need to provide proof of address (non-Hong Kong residents are accepted, but the ultimate beneficiary must be disclosed)

There are two situations:

  • Original account: Most banks will require you to re-sign the Account Controller Agreement

  • New Account: You need to explain the license change to the bank, as some banks may refuse to provide service

💡 Suggest: Communicate with MSO-friendly banks such as HSBC and Standard Chartered in advance.

To be negotiated separately:

  • If included：The landlord needs to sign the "Lease Transfer Consent"

  • If not included：The buyer needs to rent a new address by himself (it must be a "specified place" approved by the customs)

Can be traded but please note:

  • Minor Violations(such as overdue report): 10-20% discount

  • Serious Violations(If related to money laundering): Customs may require suspension of business for rectification

Hong Kong Customs has no explicit requirements, but will assess:

  • Management Qualifications: At least 1 director/compliance officer with 3 years of relevant experience

  • employee training：An annual AML training plan is required

Typical agreement terms:

  • Due to buyer's reasons: Seller withholds deposit

  • Due to seller/regulatory reasons: Full refund

  • Shared responsibility：Lawyer custody until the transaction is completed

It is theoretically feasible, but difficult to implement in practice:

  • Customs will still review all "controlling persons" (shareholders holding more than 10%)

  • Banks may refuse to change account signing authority

Three-step verification:

  1. Search the Companies Registry (CR No.)

  2. Check the list of licensees on the customs official website

  3. Request the seller to produce the original license certificate

It can be changed, but an application for name change must be submitted to the Companies Registry and the Hong Kong Customs, which usually takes 1-2 weeks for approval.
⚠️ Business Scope :

  • If the original license is limited to "currency exchange", adding "remittance service" requires re-application to the customs to expand the business scope.

  • If it involves high-risk countries (such as sanctioned regions), it may be rejected.

  • Valid period: Usually 1-3 years (subject to customs approval).

  • Renewal conditions :

    • No major compliance violations

    • Submit annual audit report

    • Pay the renewal fee (approximately HKD 8,000-15,000)

  • Renewal Process: Application must be submitted 3 months before expiration, and customs may conduct on-site inspection.

can, but must:

  1. The new address must meet the “specified premises” requirements (not a virtual office).

  2. Notify Hong Kong Customs in writing 14 days in advance.

  3. Customs may send personnel to verify whether the new site is suitable for operations.

  • Equity Acquisition: The buyer usually does not assume historical debts/liabilities (this needs to be clearly agreed in the SPA).

  • Asset Acquisition：The buyer may need to assume some obligations and clarify responsibilities through legal documents.
    💡 Suggest: Review all outstanding transaction records before trading.

can, but must meet the following requirements:

  • The system complies with the AML/CFT requirements of the Hong Kong Customs (such as customer identity verification, transaction monitoring).

  • The website/APP needs to be registered with the customs.

  • Anonymous cryptocurrency transactions must not be involved (an additional VASP license application is required).

Mandatory requirement :

  • MLRO (Money Laundering Reporting Officer): Must be full-time or outsourced to a licensed compliance company.

  • Compliance Team: Depending on the scale of the business, at least 1-2 full-time personnel are responsible for AML monitoring.

can, but please note:

  • If the license is held for less than 1 year, Customs may question the "license reselling" behavior.

  • New buyers still need to go through customs approval.

Must submit :

  • Quarterly Report: Summarize transaction amounts and number of suspicious transactions.

  • Annual Audit Report: Signed by a certified public accountant.

  • Major incident reporting: Such as system failure, changes in senior management (report within 7 days).

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