Hong Kong Money Service Operator (MSO) License Application

The MSO license is mainly applicable to the following business activities:

1. 货币兑换: Including but not limited to foreign currency exchange, precious metal trading, foreign currency deposits and other services, suitable for scenarios such as physical exchange stores and tourism-related businesses.
2. Remittance Services: Including personal cross-border remittances, cross-border fund transfers between enterprises, international trade settlements, etc.

3. Electronic payment services(Some cases): Such as mobile payment, e-wallet, online payment, etc., depending on whether the specific business involves currency exchange or remittance.

4. Other currency services: Such as bill cashing, prepaid card issuance, etc., must comply with the "money service" defined by AMLO.

Not applicable :

• Currency exchange incidental to the primary business (e.g., a retail store accepting foreign currency, a hotel providing exchange for guests).
• Monetary services provided by a system operator or clearing house of a designated retail payment system.
• Transactions in virtual assets (such as cryptocurrencies) are beyond the regulatory scope of MSOs as they are not considered legal tender in Hong Kong.

1. Applicant

• Company Requirements: The applicant can be an individual or a company, but the company must be:
  • Local enterprises registered in Hong Kong;

  • Or a branch of an overseas company registered with the Hong Kong Companies Registry.

• Investing funds: It is recommended to pay a registered capital of HK$50 to prove financial capabilities (the specific amount depends on the scale of the business).

• Hong Kong Company Account：Applicants need to open a Hong Kong bank account for money service transactions and provide bank certification that the account is used in compliance with regulations.

2. Fit and Proper Test

• Suitable：Shareholders, directors, ultimate owners and compliance officers must pass the customs’ “proper person test”.
• Claim :
  • Provide a criminal record certificate (issued by Hong Kong or other jurisdictions).
  • Provide bank statements to show that the source of funds is legal.
  • He has not been found guilty of money laundering, terrorist financing or other related crimes.

  • not being an undischarged bankrupt.

• expression: You need to fill in the "Applicant Application Form" (Form 4) and sign it in the presence of a witness such as an authorized officer of the Customs, a practicing lawyer, an accountant, a notary public or a justice of the peace.

3. Compliance Officer

• Compliance Officer: A qualified Hong Kong permanent resident must be employed as a compliance officer to ensure that the business complies with AMLO requirements.
• Money Laundering Reporting Officer (MLRO): Responsible for monitoring and reporting suspicious transactions, usually concurrently held by the Compliance Officer.

• Capacity Assessment: At least one company director must pass a written examination organized by Customs to test their knowledge of AMLO and anti-money laundering compliance. A maximum of three directors may be scheduled to take the examination, provided at least one passes.

4. Business premises

• Fixed location (optional) :
  • If the business involves a physical business location (such as a currency exchange shop), you will need to provide a lease agreement for the commercial office (with a stamp), a land search report and the owner's consent.

  • The business premises must allow customs officers to enter for inspection and must display the original MSO license in a conspicuous place.

• No fixed location :

  • If the business is provided through door-to-door service, telephone or the Internet (such as a cross-border payment platform), only the correspondence address of the Local Management Office (LMO) may be provided for storing transaction records and maintaining the physical presence in Hong Kong.

• Record storage : A location for storing transaction books and records (Local Place of Storage, LPS) must be set up to ensure that customs can access them at any time.

5. Compliance system

• Blacklist screening : It is necessary to sign a service agreement with a customs-approved blacklist screening service provider (such as World-Check) for customer due diligence.

• Risk control and compliance system : It is necessary to demonstrate the business’s risk control and compliance systems to the customs during the application interview stage, including customer identity verification, transaction monitoring and other functions.

• Policy Documents : The following documents are required:
  • Business plan;
  • Anti-money laundering and counter-terrorist financing policies;
  • Compliance guidelines;
  • Disciplinary Action Guidelines;

  • Floor plan of business premises (if applicable).

6. Other requirements

• Banking Relationships: It is necessary to communicate with Hong Kong banks to ensure that the bank’s specific account opening requirements for MSO business are met.

• The author of The New York Times: License holders are required to receive at least 5 hours of continuing professional training (CPT) each year to keep their compliance knowledge updated.

1. Company registration certificate :
   • Hong Kong local companies:
     • Certificate of Incorporation (CI).
     • Business Registration Certificate (BR).
     • Articles of Association.
   • Hong Kong branches of overseas companies:
     • Proof of overseas company registration.
     • Certificate of Registration of a Non-Hong Kong Company (Form NN1) issued by the Hong Kong Companies Registry.
     • Overseas company’s articles of association and related registration documents (need to be notarized and translated into English or Chinese).
2. Proof of company structure :
   • The company's organizational chart shows the shareholders, directors, ultimate owners and their shareholding ratios.
   • Register of shareholders and register of directors.
   • If a complex equity structure is involved, documents such as a trust agreement, equity holding agreement, etc. (notarization required) must be provided.
3. Company bank account proof :
   • Proof of opening a Hong Kong bank account.
   • Bank statements from the last 3-6 months, proving the legal source of funds.
   • A certificate of account use issued by the bank confirming that the account is used for money service business.
4. Tax registration documents(if applicable):
   • Tax registration certificate from the Hong Kong Inland Revenue Department (if already doing business).
   • If it is a newly established company, it can be paid after application.

2. Personal documents

1. Proper Person Application Form (Form 4) :
   • To be completed by all shareholders, directors, ultimate owners and persons responsible for compliance.
   • It needs to be signed in the presence of a witness such as an authorized customs officer, a practicing lawyer, an accountant, a notary public or a justice of the peace.
2. personal I.D :
   • Identity documents of shareholders, directors, ultimate owners and compliance officers:
     • Hong Kong Identity Card (if you are a Hong Kong resident).
     • A copy of your passport (notarized required if you are a non-Hong Kong resident).
   • Hong Kong Permanent Resident Identity Certificate of the Compliance Officer and Money Laundering Reporting Officer (MLRO).
3. Certificate of Good Conduct :
   • A criminal record certificate issued by a law enforcement agency in the applicant's jurisdiction (e.g. Hong Kong, Mainland China or other countries/regions).
   • Hong Kong residents can apply for a “Certificate of No Criminal Record” from the Hong Kong Police Force (must indicate that it is for MSO license application).
   • Non-Hong Kong residents are required to provide similar certificates from their home countries (need to be notarized and translated into English or Chinese).
4. Personal financial proof :
   • Personal bank statements from the last 3-6 months, proving the legal source of funds.
   • Proof of personal assets (such as property certificates, investment account statements, etc.) to support the "fit and proper person" assessment.
5. Resume and qualification certificate :
   • CVs of shareholders, directors and compliance officers, describing relevant industry experience (e.g. finance, payments, remittances, etc.).
   • Qualifications of the Compliance Officer and Money Laundering Reporting Officer (e.g. anti-money laundering training certificate, relevant academic qualifications or professional qualifications).

III. Compliance and Business Documents

1. Business Plan :
   • A detailed description of the company's business model, including:
     • The type of money service provided (currency exchange, remittance, etc.).
     • Target customer groups (such as individuals, cross-border e-commerce, enterprises, etc.).
     • Estimated transaction volume and revenue.
     • Business operations processes (e.g., customer identity verification, transaction processing, record keeping).
   • It is necessary to explain how the Anti-Money Laundering and Counter-Terrorist Financing Regulations (AMLO) are being complied with.
2. Anti-Money Laundering and Counter-Terrorist Financing Policy (AML/CTF Policy) :
   • Detailed policy document covering:
     • Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) processes.
     • Suspicious transaction identification and reporting procedures.
     • Anti-money laundering training program for employees.
     • Internal audit and compliance inspection mechanism.
3. Compliance Manual :
   • Describe how the company implements customs compliance requirements, including:
     • Transaction record keeping process (at least 5 years).
     • Blacklist screening and customer identity verification process.
     • Responsibilities of the Head of Compliance and the Officer of Money Laundering Reporting.
4. Disciplinary Action Guidelines :
   • Describe the penalties for employees violating compliance policies, such as failure to report suspicious transactions.
   • Includes internal investigation and disciplinary processes.
5. Blacklist Screening Service Agreement :
   • Service agreements signed with customs-approved blacklist screening service providers (such as World-Check, Dow Jones, LexisNexis).
   • Prove that the company has the ability to screen customer identity and transaction background.
6. Risk Control and Compliance System Description :
   • Describe the risk control and compliance systems used by the company, including:
     • Customer identity verification tool.
     • Transaction monitoring and anomaly detection capabilities.
     • Data encryption and privacy protection measures.
   • The system functions (such as demonstration interface or operation process) must be demonstrated during the customs interview.
7. Continuing Professional Training Program (CPT Plan) :
   • Explain how the company ensures that its employees receive at least 5 hours of anti-money laundering and compliance training each year.
   • Provide training course outlines or service agreements with training institutions.

4. Business premises documents

1. Fixed place of business (if applicable) :
   • Lease Contract :
     • Lease agreement for commercial office or money exchange shop (with stamp duty certificate, i.e. Hong Kong stamp duty certificate)
     • The recommended lease term is at least 1 year, covering the license application and validity period.
   • Owner's consent :
     • Proof of the owner's consent to use the property for a money services business.
   • Land Search Report :
     • Issued by the Hong Kong Land Registry to prove the legal use and ownership of the property.
   • Site plan :
     • Indicate the layout of the business premises, including transaction counters, customer reception areas, record storage areas, etc.
   • Fire and safety certification :
     • Proof that the site complies with fire and safety requirements (e.g. fire hydrant inspection reports, emergency exit signs).
2. Local Management Office (LMO) :
   • If there is no fixed place of business, the address proof of LMO is required:
     • Lease agreement or property use agreement.
     • Documentary proof of correspondence address (e.g. utility bill, property management fee receipt).
   • Explain how LMO is used for business management and communication with customs.
3. Local Place of Storage (LPS) :
   • Provide the address of the location where the transaction records are stored and supporting documents (such as a lease agreement).
   • Describe the security of the storage facility (e.g. fire prevention, anti-theft measures).
   • Ensure that customs can enter for inspection at any time.

V. Other supporting documents

1. expression :
   • Application Form for Money Service Operator Licence (Form 1) :
     • To be filled in by the authorized representative of the company, stating the application details.
   • Proper Person Application Form (Form 4) :
     • To be completed and signed by shareholders, directors, ultimate owners and compliance officers.
   • Renewal Application Form (Form 2)(If it is a renewal application).
2. Proof of payment of application fee :
   • Bank transfer record or payment receipt, proving that the application fee required by the customs has been paid (the specific amount should refer to the latest customs guidance, about several thousand Hong Kong dollars).
3. Proof of bank relationship :
   • A recommendation letter or account compliance certificate issued by a Hong Kong bank, confirming that the bank supports the MSO business.
   • If the bank requires additional compliance documents, you need to prepare them in advance (such as business model description, funds flow chart).
4. Other supplementary documents(depending on the situation):
   • If cross-border business is involved, qualification certificates or cooperation agreements of overseas partners must be provided.
   • If the business involves electronic payment or virtual accounts, you must provide proof of qualifications of the technical service provider or system security certification.
   • If the company is part of a group, a group structure chart and background information of the parent company are required.