INSTRUCTIONS ON COMPLETING THE AML / CFT SELF-ASSESSMENT CHECKLIST
INSTRUCTIONS ON COMPLETING THE AML / CFT SELF-ASSESSMENT CHECKLIST
INSTRUCTIONS ON COMPLETING THE AML / CFT SELF-ASSESSMENT CHECKLIST
Background "The AML / CFT Self-Assessment Checklist has been designed to provide a structured and comprehensive framework for licensed corporations (""LCs"") and associated entities (""AEs"") to assess compliance with key AML / CFT requirements. LCs and AEs are advised to use this as part of their regular review to monitor their AML/CFT compliance. The frequency and extent of such review should be commensurate with the risks of ML/TF and the size of the firm's business.
The AML / CFT Self-Assessment Checklist is neither intended to, nor should be construed as, an exhaustive list of all AML/CFT requirements."
Instructions LCs / AEs will be able to save and print the checklist as required to enable internal review and follow-up.
"Completion of the self-assessment checklist should be organised and directed by the compliance officer having overall responsibility for the establishment and maintenance of the firm's AML/CFT systems who should also approve and sign the completed checklist.
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Please read each question carefully before answering and use the text box to provide comments where the response to the question requires further elaboration. Wherever appropriate, cross-references to related provisions of the SFC's Guideline on Anti-Money Laundering and Counter-Terrorist Financing have been provided for the reader's assistance.
"Each question in the self-assessment checklist provides a number of response options including ‘Yes’, ‘No’, 'Not applicable (""N/A"")'.
1): When the LC / AE confirms the response to be ‘Yes’ to any of the questions in the tick box, it represents a compliance with the requirement. For some of the questions, further specified information should be given in the text box for a 'Yes' response.
2): When the LC / AE confirms the response to be ‘No’ to any of the questions in the tick box, it represents a potential non-compliance with the requirement. If the response to a question is 'No', the LC / AE should use the text box to additionally document:
a) How does the LC / AE plan to remediate the potential gap identified
b) When does the LC / AE plan to complete the remediation for any potential gaps identified
3): When the LC / AE confirms the response to be ‘N/A’ to any of the questions in the tick box, it represents the requirement is not applicable to the LC / AE."
"All terms used in the checklist are, unless otherwise specified, as defined in the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (Cap.615) and the SFC's Guideline on Anti-Money Laundering and Counter-Terrorist Financing.
Some key terms and abbreviations are provided in the Glossary for easy reference."
