The origins of the AML/CFT framework date back to the 1980s, when the international community recognised that enormous proceeds from drug trafficking and organised crime were penetrating the legitimate financial system. The 1988 Vienna Convention was the first treaty to require signatories to criminalise money laundering linked to drug offences. In 1989, the G7 established the Financial Action Task Force, which issued the “40 Recommendations” in 1990—later becoming the global standard for combating money laundering and terrorist financing. The FATF monitors compliance through mutual evaluations and identifies high‑risk jurisdictions, exerting significant influence over the international financial system.
The scope of regulated sectors has expanded significantly over time, moving beyond traditional banking to include securities firms, insurers, payment institutions, virtual asset service providers, and designated nonfinancial businesses and professions—such as lawyers, accountants, estate agents, trust and company service providers, and dealers in precious metals and stones. Governments around the world require these sectors to carry out customer due diligence, ongoing monitoring, recordkeeping, and suspicious transaction reporting, applying a riskbased approach to manage money laundering and terrorist financing risks.
Financial institutions act as the first line of defence in the AML/CFT framework. They are required to establish written compliance policies, appoint a compliance officer and a money laundering reporting officer, conduct regular institutionlevel risk assessments, and apply enhanced due diligence for highrisk customers—such as politically exposed persons, individuals from sanctioned jurisdictions, or those with complex ownership structures. Staff must receive periodic training, and the effectiveness of the AML/CFT system must be subject to independent audit. Noncompliance can result in heavy fines, criminal prosecution, licence revocation, and serious reputational damage—demonstrating the binding force of this regime.
Bolivia - South America
Bulgaria - Eastern Europe
Haiti - Central America
Monaco - Europe
Venezuela - South America
Virgin Islands(UK) - Central America
Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
Sets out the statutory requirements for customer due diligence and record-keeping. It is the core legislation regulating financial institutions and designated non-financial businesses and professions.
Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405)
Deals with the recovery of proceeds derived from drug trafficking and the reporting of suspicious transactions.
Organized and Serious Crimes Ordinance (Cap. 455)
Deals with the recovery of proceeds from organised and serious crimes and the reporting of suspicious transactions.
United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575)
Implements the counter-terrorism resolutions of the United Nations Security Council and sets out the reporting obligations in respect of terrorist property.
United Nations Sanctions Ordinance (Cap. 537)
Imposes United Nations sanctions, including financial sanctions against designated persons and entities.
Weapons of Mass Destruction (Control of Provision of Services) Ordinance (Cap. 526)
Regulates the provision of services related to the proliferation of weapons of mass destruction.
The Truth About Money Laundering
Money laundering refers to the process of concealing the true origin of proceeds derived from illegal activities, making them appear to be legitimate assets. The primary objective of criminals engaging in money laundering is to disguise the illegal source and ultimate control of such funds, thereby reducing the risk of detection by law enforcement authorities and enabling the proceeds to be safely integrated into the legitimate economy or used to support further criminal activities.
The "predicate offences" that generate illicit proceeds are extensive and cover a wide range of criminal activities, including drug trafficking, smuggling, illegal gambling, loan sharking, extortion, tax evasion, controlling prostitution, bribery and corruption, robbery, theft, fraud, copyright and intellectual property infringement, insider dealing, market manipulation, and other organised or serious crimes. Any proceeds derived from these offences, when further processed to conceal their origin, constitute money laundering.
What are the methods of money laundering?
Money laundering is the criminal act of transforming illegally obtained funds into "clean" money. Generally, money laundering is divided into three stages: placement, layering, and integration.
Placing the illegal funds into the financial system, such as banks. This can be done by breaking down cash into small deposits, investments, or currency exchanges.
Through multiple transfers of funds and using complex transaction methods, the source becomes obscure and difficult to trace. For example, remitting funds to multiple accounts to disperse and confuse the flow of money.
Reinject the laundered funds back into normal economic activities, making them appear to be legitimate earnings. This can be done through investments in real estate, luxury goods, or startup companies.
AML Ordinance Applicable Industries
Financial Institutions (FIs)
Designated Non-Financial Business and Professions (DNFBP)
Others
Banks
Solicitors/Notary Public
Money Lenders / Credit Institutions / Pawn Shops
Exchange Service Providers
Accountants/Auditors/Tax Consultants
Trust Companies
Stored Value Facilities (SVFs) licensee
Estate Agents
Trustees
SFC Licensed Corporations
Trust or Company Service Provider (TCSPs)
Investment Funds / LPF / OFC
Financial Intermediaries
Dealers in Precious Metals and Stones (DPMS) - category B
Fund Administrators
Money Service Operators (MSOs) / Payment companies
Family Offices
Insurance Companies
Casino and Gaming Operators
Insurance Agency/Insurance Broker Companies
Art Market Participants
Virtual Assets Service Providers (VASPs) / Crypto-asset service providers
Regulatory authorities
Corporations/Individuals that are subject to comply with AMLO
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