Ship Helm

Combating trade-based money laundering – Hong Kong banks bolster their artillery

The Hong Kong Association of Banks has just issued its much anticipated Guidance Paper on Combating Trade-based Money Laundering (Guidance Paper). The Guidance Paper is a valuable resource for the Hong Kong banking industry in combating one of the oldest forms of money laundering.

See here for our alert that synthesises the key aspects of the Guidance Paper.

Importantly, this industry-led paper is endorsed by the Hong Kong Monetary Authority (HKMA) and there no “grace period” as such.  The HKMA expects banks and other authorised institutions to give full consideration to the adoption of the practices in the Guidance Paper and make improvements where needed in relation to trade-related activities.

The Guidance Paper also includes “red flags” and guidance that can assist financial institutions operating in other trade hubs around the world.

We expect to see the HKMA to continue its increasing focus on AMLO compliance and to take an increasing tougher stance. The AMLO is coming up to its 4-year anniversary in April 2016 and the honeymoon period is well and truly over.

This post was written by Urszula McCormack and Lauren Dray.

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