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Ethical Scenarios

Anti-Money Laundering (AML) and
Counter-Terrorist Financing (CTF)

The amended Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), effective from 1 March 2018, extends the scope to cover "designated non-financial businesses and professions", including accountants. Accountants in practice should comply with the existing legal requirements on AML/CTF, observe the relevant guidelines under the COE and adopt appropriate measures when preparing or carrying out for a client a transaction concerning services of higher risks, e.g. buying and selling of real estate/business entities, managing of client money, securities or other assets. Practices and members working in practices must have in place internal policies, procedures and other controls which cover primarily the following areas:

Risk assessment and management

Adopt a risk-based approach which can identify and categorise money laundering/terrorist financing overall risks at the client level and establish reasonable measures based on the risks identified, and have adequate management oversight in relation to AML/CTF.

Customer due diligence

Identify the client or beneficial owner in relation to the client, and verify the identity using documents, data or information provided by a government body or other reliable, independent source.

Ongoing monitoring

Update from time to time documents, data and information relating to the client; pay attention to transactions carried out for the client to ensure that they are consistent with the client's nature of business, risk profile and source of funds.

Suspicious transactions reporting

Make a report to the appropriate law enforcement agency (e.g. the Joint Financial Intelligence Unit) as soon as possible after the suspicion or knowledge is first established.

Record keeping

Prepare, maintain and retain documentation and records on practices' business relations with, and transactions for, clients, as are necessary and sufficient to fulfil legal or regulatory requirements, and which are appropriate to the scale, nature and complexity of their businesses.

Compliance management

Designate a Money Laundering Reporting Officer at the management level.

Staff hiring and training

Ensure adequate standards when hiring employees, and provide appropriate AML/CTF training to the staff.

For more details, please refer to Chapter F of the COE.

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