February 1, 2016
Guidance Paper on combating Trade-based Money Laundering
This Guidance Paper on Combating Trade-based Money Laundering (Guidance Paper) has been developed by the Hong Kong Association of Banks (HKAB) with input from the Hong Kong Monetary Authority (HKMA). The practices recommended in this Guidance Paper do not form part of the Guideline on Anti-Money Laundering and Counter-Terrorist Financing (for Authorized Institutions) (AMLO Guideline).
However, the HKMA considers that the adoption of these practices will assist authorized institutions (AIs) in not only meeting the legal and regulatory obligations under the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (AMLO) and the AMLO Guideline, but also in implementing effective measures to further mitigate their money laundering and terrorist financing (ML/TF) risks. Als should also take appropriate measures to ensure compliance with Hong Kong’s sanctions regime, and obligations under Hong Kong law in respect of weapons of mass destruction (WMD) proliferation. In addition to meeting requirements under Hong Kong laws, these practices will also help Als operating internationally to meet relevant overseas sanctions regimes that are applicable to them.