HKMA amending address verification requirements in AML/CTF guidelines

On October 11th, the Hong Kong Monetary Authority issued a notice of changes to its AML/CTF Guidelines in the area of address verification:

The Hong Kong Monetary Authority (HKMA) and the other relevant authorities

(RAs) 1 have been reviewing various aspects of the anti-money laundering and 

counter-financing of terrorism (AML/CFT) regulatory requirements for financial 

institutions (FIs)2, which include the address verification requirements stipulated in 

the Guideline on Anti-Money Laundering and Counter-Terrorist Financing (AML 

Guideline).

 

Taking into account feedback from various stakeholders about AML/CFT 

processes and industry developments, the HKMA and the other RAs have agreed to 

remove the address verification requirements currently set out in the AML 

Guideline. As a result, FIs are only required to collect address information of 

customers and/or beneficial owners without the need to collect documentary 

evidence for AML/CFT purpose. Relevant paragraphs of the AML Guideline that 

will be amended to reflect the removal of the address verification requirements are 

listed in the Annex. Such amendments to the AML Guideline are expected to be 

gazetted tentatively in the first half of 2018 in conjunction with other revisions3 to 

the AML Guideline resulting from the passage of Anti-Money Laundering and 

Counter-Terrorist Financing (Financial Institutions) (Amendment) Bill 2017 (the 

Bill)4.

 

In the meantime, any absence of verification of address (as otherwise envisaged by 

paragraphs in the Annex) will be regarded by the HKMA and the other RAs as 

justified under paragraph 1.7 of the AML Guideline. Authorized Institutions (AIs) 

may start reviewing and adopt the changes as soon as it is practicable to do so. 

It should be noted that some AIs may, under certain circumstances, still require 

address verification from a customer for other purposes (e.g. group requirements, 

other local or overseas legal and regulatory requirements5). In such circumstances, 

AIs should communicate clearly the reasons of requiring verification of address to 

the customer.

 

If you have any questions relating to this letter, please contact Ms Sophia Lam at 

2878 1356 or Mr Gavin Cheung at 2878 8305.

There is also a 3-page table enumerating the specific changes being made.

The Hong Kong Securities and Futures Commission (HK SFC) issued an almost identical AML/CTF Circular on the same subject on October 11th. They also provide the table in a separate Appendix document.

Link:

HKMA Notice

HK SFC Notice

HK SFC AML/CTF Circular

HK SFC Appendix

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