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Add-on: Internal AML Policies, Procedures and Controls (APPC) Template

Under the latest Hong Kong registration regime, Designated Non-Financial Businesses and Professions (DNFBP), including Trust and Company Service Provider (TCSP), Accountants and Company Secretaries, are required to implement internal AML Policies, Procedures and Controls (also known as the “AML/CTF Systems” or “Manual”, APPC), in accordance with Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).

To assist you in fast track the development of APPC documents, we provide a customizable APPC template. The templates are delivered in Microsoft Word/ Excel format, and are almost 90% complete for your company to use. You can adjust and customize to your company’s requirements, and comply with the AML/CFT regulatory requirements.

Contents of APPC Template:

1. INTRODUCTION
2. POLICY STATEMENT
3. MANAGEMENT OVERSIGHT
4. RISK ASSESSMENT
5. CUSTOMER DUE DILIGENCE (“CDD”)
6. ENHANCED CUSTOMER DUE DILIGENCE
7. RECORD KEEPING
8. ON-GOING MONITORING
9. REPORTING A SUSPICIOUS TRANSACTION
10. AUDIT AND COMPLIANCE
11. HIRING OF NEW STAFF AND TRAINING
APPENDIX A. AML/CFT ROLES & RESPONSIBILITIES
APPENDIX B. RISK ASSESSMENT
APPENDIX C. INDICATORS OF SUSPICIOUS TRANSACTIONS

Customer Due Diligence Forms:

Form 1 Customer Information
Form 2 Client’s Particulars (Individual or Entity)
Form 3 Politically Exposed Person Information
Form 4 Risk Assessment