Which companies are eligible for ongoing compliance support?
Continuous compliance support is applicable to the following scenarios (especially Hong Kong MSO/exchange remittances、Cross-border payment、payment gateway、Fintech platforms and related service providers):
- Licensing compliance pressure continues:Supervision on the RBA、traceable records、Requirements for training and audit evidence are increasingly “verifiable”。
- Banks and partners are tightening due diligence:Open an account、Common supplements for account maintenance and channel cooperation、Questionnaire、Sample transaction explanation and system verification。
- Fast business iteration:Add new country/region、Currency、product、customer group or channel,Without “change management + compliance assessment”,It is easy for the system to be inconsistent with reality。
- Insufficient internal resources:Compliance team has limited staff or uneven experience,External consultants are needed to provide implementable “second-line capability enhancement”。
Hong Kong Xintong's continuous compliance support is based on "Regulatory and auditable、The bank can explain、Operational executable” as delivery standard,Help enterprises advance compliance from the document level to daily operations and management。
For example, sorting out the compliance boundaries and regulated activities involving cross-border business,Synchronizable reference:Cross-border business compliance。
Our scope of continuous compliance services (designed according to regulatory audit standards)
Board/Management Oversight Framework、MLRO/CO Responsibilities、three lines of defense、Meeting mechanism and resolution trace template,Form "accountability and traceability"。
by product、customer group、region、Assess inherent and residual risks in channels and delivery methods,Export risk register、Control mapping and improvement roadmap。
Sampling review of customer file integrity、Beneficiary identification、Reasonable source of funds/source of wealth、Continuous due diligence on trigger conditions and re-certification mechanism。
List Screening Strategy (List Source、fuzzy matching、threshold)、Hit handling SOP、Secondary verification and evidence retention,Reduce the risk of misjudgment and missed diagnosis。
Rules/scenario library、Threshold tuning、Alarm classification、Investigation records and conclusions、Suspicious transaction upgrade and STR governance,Ensure the chain of evidence is auditable。
Design courses according to positions (frontline/operations/compliance/management)、annual training plan、Exam and check-in records,Meet audit and regulatory spot inspection standards。
Taking regulatory concerns and bank due diligence questionnaire as baseline,Conduct special audits (KYC、TM、sanctions、record keeping),Formation of rectification ledger and review。
Assist in preparing regulatory/bank supplementary materials、Policy explanation、Process walkthrough and sampling transaction instructions,Improve communication consistency and pass rate。
If you need to cover system capacity building at the same time,Can be connected to the following modules:
- KYC identity verification system:Identity verification、Document identification、Liveness detection、Enterprise information verification, etc.。
- eDon TM Transaction Monitoring System:scene rules、Alert workflow、Investigation traces and reports。
- Hong Kong Xintong AML/CRM system:Customer lifecycle management、KYC supplement、Work orders and audit trails。
- risk assessment system:Annual/Quarterly RBA Modeling、Control mapping and rectification tracking。
delivery mechanism:Monthly control + Quarterly review + Change management
to the existing system、Customer profile、Transaction monitoring、Training and record keeping gap analysis,Clarify the priority of “regulatory/banking standards”。
Develop an annual compliance calendar (training、audit、RBA、review),Set measurable indicators (alarm handling timeliness、KYC completeness rate、Review coverage, etc.)。
Review of new high-risk customers、Major warnings and STR、Channel abnormality、Reject/Exit Customer,Form a closed loop of meeting minutes and action items。
Around KYC/EDD、Sanctions Screening、TM alarm、Record keeping and sampling review,output discovery、Rectification suggestions and review conclusions。
Conduct compliance impact assessment before launching new products/new countries/new channels、Update system and system parameters、Train and leave a mark。
Form annual compliance report、Board of Directors Reporting Materials、Audit cooperation package;Assist with bank questionnaires and due diligence interviews。
Data privacy and cross-border data compliance (support bank and partner review)
Ongoing compliance support goes beyond AML/CFT。For MSOs and payment companies,Customer information、Transaction data and cross-border transmission are also high-frequency concerns for banks’ due diligence and partner review.。Hong Kong Information Communications can be promoted collaboratively:
- Data classification and minimization collection:Combing the data flow、Clarify the purpose of collection and retention period,Reduce the risk of over-collection and overdue storage。
- Privacy Policy and Internal Policies:External disclosure is consistent with internal execution,Override third-party sharing、cross-border transfer、Data Subject Rights Response。
- Data security assessment and rectification:access control、encryption、Log audit、Backup and restore、Vendor Management and Penetration Testing Evidence Packages。
For related supporting capabilities, please refer to:
Fee Reference (HK MSO Matrix) and Startup Checklist
Ongoing compliance support is typically billed as an annual retainer or on a quarterly/thematic delivery basis。If the enterprise is in the stage of “application/renewal/reinforcement of compliance system”,You can refer to the common cost structure of Hong Kong MSOs (for budget matrix only),Actual business complexity、Number of personnel、System scope and audit depth shall prevail):
| cost category | project | Reference amount (HKD) | illustrate |
|---|---|---|---|
| Government fees (Gov) | Application | 3,310 | Listed according to common fee standards for Hong Kong MSO applications |
| Government fees (Gov) | Fit & Proper | 860/people | Depends on the number of key personnel |
| Basic input (Base) | Company Registration | 8,000–15,000 | Common intervals related to company establishment/maintenance |
| Basic input (Base) | Office | 20,000–80,000/year | Office Space and Verifiable Operational Elements for Compliance |
| Agency | MSO service | 60,000–150,000 | Application/rectification/ongoing compliance advisory support (scope determines price) |
| Agency | AML Documents | 20,000–80,000 | Institutional system construction/iteration、Forms and processes、Training materials, etc. |
| Total | Standard Range | 150,000–400,000 | Standard budget range (excluding additional costs for system procurement and third-party due diligence/auditing) |
If your goals include both reducing account opening friction and improving account maintenance stability,Can be referenced:Hongkong(HSBC/Standard Chartered/Hang Seng)Open an account。
Startup Checklist (recommended preparation):Corporate structure and beneficiary information、Business process and capital flow/data flow、Customer categories and main regions、Current KYC/EDD form、TM rules and alarm examples、STR/SAR records (if applicable)、Training and audit records、Outsourcing/Third Party Checklist and Contract Essentials。
One-time documents are more "establishing system texts";Continuous compliance support emphasizes "system + execution + evidence chain":Includes monthly/quarterly reviews、Sampling audit、Rule tuning、Training and Records、Change management and rectification closed loop,To meet the requirements of continuous audit and bank due diligence。
External consultants provide a second perspective and methodology:Benchmarking supervision and bank standards、Make up for experience shortcomings、Improve document and evidence auditability,And in major events (high risk alarms、sanctions hit、Channel abnormality、Provide quick support and unified caliber when asked)。
uncertain,But traceable monitoring and disposal records must be achieved。If the trading volume、Product complexity or bank/partner requirements increase,Systematic (rules、work order、leave traces、reporting) often significantly reduces operating costs and improves consistency。Can be referenced:https://www.gxt-hk.com/edon-tm-transaction-monitoring/ 。
Can。We can press "factually accurate"、Full disclosure of risks、Clear rates and limits、reviewed based on the criteria of "no misleading statements",and establish a pre-launch compliance approval process。For details, please refer to:https://www.gxt-hk.com/marketing-material-review/ 。
Can conduct joint assessment and project delivery according to group needs,Commonly included CRS classification and processes、BEPS related compliance framework and cross-border tax impact assessment。Can be referenced:https://www.gxt-hk.com/crs-tax-advisory/ and https://www.gxt-hk.com/beps-compliance-consulting/ 。