1. Our Commitment
HA HK Limited is committed to maintaining a strong culture of integrity and to preventing its business, systems and proposed services from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, bribery or other unlawful activity.
HHL is currently applying for a Hong Kong Money Service Operator licence. Before commencing regulated operations, the Company intends to establish and implement policies, procedures and controls proportionate to its business model and financial crime risks.
2. Legal and Regulatory Framework
Subject to licensing and commencement of operations, HHL's AML/CFT and sanctions framework will be designed with regard to applicable Hong Kong requirements, including:
- the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615);
- the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism for Money Service Operators issued by the Customs and Excise Department;
- the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405);
- the Organized and Serious Crimes Ordinance (Cap. 455);
- the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575);
- the United Nations Sanctions Ordinance (Cap. 537) and sanctions regulations made under it; and
- other applicable laws, regulatory guidance and binding directions.
HHL will also take account of relevant international standards, including recommendations issued by the Financial Action Task Force, where appropriate to its risk profile and legal obligations.
3. Customer Acceptance
Following licensing, access to HHL's services will be subject to customer eligibility, completion of satisfactory due diligence and acceptance under the Company's risk appetite. HHL will not establish or continue a business relationship where required information cannot be obtained or verified, where legal or sanctions restrictions apply, or where identified risks cannot be appropriately managed.
4. Sanctions Compliance
HHL intends to screen customers, beneficial owners, connected parties and transactions against applicable sanctions and designation lists. The Company will not knowingly process a transaction or maintain a relationship prohibited by applicable law.
Sanctions restrictions can be complex and may depend on the persons, ownership, control, jurisdiction, goods, services and payment route involved. HHL may therefore request additional information, delay processing while checks are completed, decline a relationship or transaction, or take other action required by law.
5. Transactions and Information Requests
Subject to applicable law and contractual terms, HHL may:
- request additional identification, ownership, business, source-of-funds, source-of-wealth or transaction information;
- decline an onboarding application;
- refuse, reject, delay or suspend a proposed transaction;
- restrict or terminate a business relationship;
- retain records and information as required by law;
- make a report or disclosure to the Joint Financial Intelligence Unit or another competent authority; and
- cooperate with lawful requests from regulators, courts and law-enforcement agencies.
HHL may be legally restricted from informing a person that a suspicious transaction report, investigation or related disclosure has been made.
6. Prohibited and Restricted Activity
HHL will not knowingly provide services:
- to a sanctioned or prohibited person where doing so would breach applicable law;
- for unlawful, fraudulent or deceptive purposes;
- for anonymous or fictitious customers;
- where required customer due diligence has not been completed;
- to conceal the source, ownership, destination or purpose of funds;
- to evade sanctions, reporting, monitoring or legal requirements; or
- in connection with activities outside the Company's approved risk appetite.
7. No Guarantee of Service
This statement describes HHL's intended compliance approach and does not create a contractual obligation to accept any customer or execute any transaction. HHL may apply additional controls based on the circumstances and its assessment of legal, regulatory, operational and reputational risk.
8. Review and Updates
This statement may be updated to reflect changes in law, regulatory expectations, the Company's licensing status, business model, risk assessment or compliance framework.
9. Contact
General compliance enquiries may be directed to compliance@hapayhk.com.