Core service content of continuous compliance support
Under Hong Kong’s strict financial regulatory environment，obtain a license orEstablish a companyonly the first step。Regulators require companies to maintain high standards of compliance during operations。Hong Kong Xintong's continuous compliance support services are designed to build dynamic、Strict compliance defense system，Comprehensive legal and compliance support covering daily consultation to annual audits。
Regular compliance advisor for various licenses and funds
Hong Kong Xintong provides permanent compliance advisory services for daily operations of licenses and ongoing management of funds.，Covers Hong Kong MSOs (Money Service Operators)、US and Canada MSB (Money Services Business)、Hong Kong money lenders、Hong Kong insurance broker、Hong Kong SFC License Business，and OFCs (open-ended fund companies) and LPFs (limited partnership funds)。According to the jurisdiction of the client’s jurisdiction, we、Business activities and scope of entrustment，Ongoing assistance with regulatory communications、business operations、Tax and other specific compliance items。
- Regulator communication：Assist in organizing regulatory inquiries and response materials、Prepare meeting and inspection materials、Follow up on supplementary documents and rectification matters，And assist in communication and recording follow-up actions within the scope of customer authorization。
- Licensing and business operations：around business changes、new products or services、Customer due diligence、Anti-money laundering、internal policy、Employee training and reporting arrangements，Provide daily consultation and special processing support。
- Taxation and Finance Specialties：Assist in sorting out tax matters、Prepare information required for declaration and inquiry response，and coordinate accounting、Audit and tax professionals follow up on specific projects。
- OFC and LPF ongoing support：Assist funds and managers in processing governance documents、Investor due diligence、annual return、Compliance matters in service provider coordination and operations，Clarify the scope of work at the fund level and manager level respectively。
- Permanent consultant and special project connection：Establish daily contact、To-do items and follow-up records；regulatory inspection、Historical rectification、Specific projects such as business adjustments and tax inquiries，Clearly deliver content、Division of responsibilities、Time schedule and fees。
Permanent consultants are an ongoing advisory and assistance service，Does not mean automatically assuming responsibility、Statutory compliance officer or other positions subject to qualification and appointment requirements。involves legal signature、Audit assurance or matters requiring specific professional qualifications，Handled by suitably qualified personnel in accordance with applicable requirements；Specific services and special fees are subject to the entrustment scope and final quotation confirmed by both parties.。
Operational mechanism of continuous compliance support
Continuous compliance is not about sending templates on a regular basis，Instead, we need to update the supervision、customer risk、Transaction monitoring、training、Reporting and remediation are integrated into daily responsibilities and calendars。
- establish jurisdiction、product、Compliance calendar for customer and regulatory reporting。
- Review high-risk customers on a monthly or quarterly basis、trading rules、sanctions list、Complaints and unusual events。
- Document policy changes、training、Management approval、Supervisory communication and rectification status。
- to registered agent、technology、pay、Banks and other outsourcing parties conduct ongoing due diligence。
Official verification：FATF recommendations。Specific obligations must be combined with the subject、business、Customer location and latest regulatory confirmation。
Service fees and handover materials
Ongoing compliance support is a professional service priced on a scope basis，The service fee shall be equal to the regulatory annual fee、audit、Breakdown of third-party fees such as legal advice and system subscriptions。Quotes must clearly cover entities、Business area、reporting frequency、Training and rectification workload。It is recommended to provide license or registration information when starting、Organization and beneficial ownership structure、Current policy、risk assessment、training records、Historical inspection and rectification ledger，and process customer information according to authority。Take Canada’s application of MSB as an example，FINTRAC Compliance Program Requirements Coverage Responsible Person、policy、risk assessment、Training and effectiveness review；Other regions should determine the handover list according to local systems.。
Source basis (verified on September 6, 2026)：FINTRAC：Compliance Program Requirements。The specific obligations shall be subject to the applicable system and the facts of the individual case.。
Marketplace billing reference for ongoing compliance services
CompliancePlus：Monthly ongoing compliance servicesAdopt a monthly support plan，Specify telephone number and email for consultation、quarterly meeting、policy review、Services such as training and annual mock regulatory inspections；Tianhui Compliance：Continuous Compliance Services for Licensed CorporationsProvide customized support based on the institution’s business and risks。Both public programs determine fees based on institutional needs.，Uniform consultant monthly fee not specified。Ongoing consulting services can be arranged on a monthly or annual basis；When comparing plans，You should first confirm the service coverage and billing methods for additional items.。
- recurring consulting fees：Compare same license types、Number of subjects、Monthly or annual quotations based on staff size and transaction risk，Confirm whether it contains regulatory inquiries、On-site inspection、Policy updates、Training and application review。
- Additional item fee：New business、Historical rectification、Extensive file rewriting and special inspections，You should confirm whether there is any additional charge，Avoid mistaking the basic monthly fee for the all-inclusive fee。
- Separable software budget sample：Yidong Financial Technology：Dongchacha CRM monthly fee planThe public price of Gatekeeper plan is HK$690/month，Contract period 12 months，Annual usage of 100 CRM customers and 200 single screening quotas，Includes client risk assessment and ongoing monitoring。The monthly fee calculated based on 12 months is HK$8,280；This is just a sample third-party software subscription，Does not include consultants、Audit or legal services，It is not a tool that must be purchased。
Market data verification date：2026September 6。The above are samples of services or prices disclosed by designated institutions.，Not a unified industry standard，It’s not a Hong Kong Xintong quotation either.；The actual cost is subject to the final quotation；The quotation should specify the scope of services、Currency、Billing cycle and whether tax is included。taxes、Additional services、Discount qualifications and renewal conditions should be checked separately。
According to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance(Chapter 615)statutory requirements，Regular review of the institution’s AML/CTF policy、Independent review of procedures and internal controls。Hong Kong Xintong's expert team will conduct random checks on customer due diligence(CDD)File and transaction monitoring records，Identify potential compliance gaps and issue independent audit reports。
Regulatory regulations (such as the SFC’s Code of Conduct or Customs’ AML Guidelines) are subject to frequent revisions。Hong Kong Information Communications is responsible for tracking regulatory developments in real time，Regularly review and revise the company's "Compliance Manual"、"Anti-Money Laundering Policy" and "Business Continuity Plan"(BCP)》，Ensure internal systems are absolutely consistent with the latest statutory requirements。
Assist licensed institutions to complete various statutory declarations on time，Including but not limited to SFC’s Financial Resources Rules(FRR)declare、Annual license return、Business and Risk Management Questionnaire(BRMQ)Fill in。at the same time，Serve as the company’s compliance representative，Assist in responding to daily inquiries and on-site inspections from regulatory agencies(On-site Inspection)。
Provide professional external legal support and consultation to internal compliance officers and money laundering prevention directors。In the account opening approval of complex transactions or high-risk customers (such as PEP politically exposed persons)，Provide independent compliance advice，Ensure decisions comply with regulatory red lines。
According to regulatory requirements，as a licensed representative(LR)、Responsible person(RO)Provide customized annual continuing professional training to all employees(CPT)Or anti-money laundering special training，Covers the latest regulatory case analysis、suspicious transaction report(STR)Process and internal compliance culture construction，and issue training certificates for regulatory verification。
Supervisory red lines for continuous compliance support
Annual review process for ongoing compliance support
Hong Kong Information Communications Compliance Team intervenes，Check the latest regulatory circulars and guidance，The company’s existing business model、Conduct a comprehensive baseline assessment of organizational structure and compliance systems，Identify compliance gaps(Gap Analysis)。
Based on health check results，Draft or revise the Compliance Manual、"Anti-Money Laundering and Counter-Terrorism Financing Policy"、"Risk Assessment Framework" and other core internal control documents，and submitted to the board of directors or senior management for approval。
Perform substantive testing。Randomly select a certain proportion of customer files(KYC/CDD)and transaction records，Review risk rating(Risk Profiling)accuracy、Source of funds(SOF)Adequacy of verification and effectiveness of suspicious transaction monitoring mechanisms。
Issue a detailed "Annual Compliance Independent Audit Report"，List the deficiencies found(Findings)、Risk level and specific rectification suggestions(Remediation Plan)。The report will serve as an important defensive document in the event of inspections by regulatory agencies。
Address weaknesses identified during audits，Conduct targeted training for relevant business and compliance personnel。Hong Kong Information Communications will continue to follow up on the implementation of the rectification plan，Ensure all compliance loopholes are managed in a closed loop。
The benefits of ongoing compliance support
Through proactive compliance reviews and regular internal audits，Nip potential violations in the bud，Avoid SFC violations、Huge fines imposed by customs or the Hong Kong Monetary Authority、Business restrictions or license revocation。
Standardized compliance processes go beyond meeting regulatory requirements，Can better optimize the internal governance structure of the enterprise，Improve cross-department collaboration efficiency，Provide management with a clear understanding of the company's risk exposure。
Hong Kong Xintong is staffed by former regulators、An expert team composed of senior lawyers and certified public accountants。Our professional endorsement can significantly enhance the company’s reputation with regulatory agencies、Credibility in the eyes of partner banks and investors。
Hong Kong’s financial regulatory policies are changing rapidly。Hong Kong Xintong serves as your external compliance brain，Will interpret regulatory circulars as soon as possible(Circulars)and guidance updates，and quickly transformed into executable internal policies for the enterprise，Ensure compliance without blind spots。
Frequently Asked Questions about Ongoing Compliance Support(FAQ)
All institutions holding financial or chartered business licenses in Hong Kong are subject to strict ongoing compliance。This includes SFC licensed corporations (Type 1-10 licenses)、Money service operators under customs supervision(MSO)、Trust or company service providers regulated by the Companies House(TCPS)、moneylender(Money Lender)and by the Monetary Authority(HKMA)regulatory agency。also，Ordinary Hong Kong companies are also required to comply with the annual declaration and significant controller register under the Companies Ordinance.(SCR)and other basic compliance requirements。
The frequency and scope of independent reviews should be determined based on applicable regulatory rules and risks，Not all SFC licensed corporations or MSOs follow the "biennial" policy。SFC Anti-Money Laundering Guidelines paragraphs 3.10 to 3.11 require periodic review，and align the frequency and scope with the nature of the business、scale、Commensurate with the level of sophistication and money laundering and terrorist financing risks；Seek external review when appropriate。Other licenses must check their respective requirements separately.。source：SFC Anti-Money Laundering Guidelines Paragraphs 3.10 to 3.11：independent audit function(Verified on September 7, 2026)。
The Compliance Manual is not a one-and-done document。It must be updated immediately when the following three situations occur:：1. Regulators issue new laws, regulations or guidance circulars；2. Company launches new product、New services or entry into new markets；3. Major changes to the company's internal organizational structure or core management。Even if there is no such situation，HKIT also recommends conducting a regular review every year，to ensure its suitability。
Local private companies that submit late annual returns must pay higher registration fees，HK$870 depending on delay period、HK$1,740、HK$2,610 or HK$3,480；These are the registration fees，Not a criminal fine cap。Companies Registry states otherwise，Failure to comply with Section 662 of the Companies Ordinance may result in prosecution，Maximum fine upon conviction is HK$50,000 per violation，Continued violations may result in an additional daily fine of HK$1,000。FRR and other declarations from SFC licensed corporations should be processed in a timely manner in accordance with their respective applicable rules.，Late submission cannot be written as automatic and immediate suspension.。source：Companies Registry：Private company annual return fees and late consequences(Verified on September 7, 2026)。
One rule cannot cover all licenses。CO、MLRO Eligibility、management level、independence、Contactability and availability of group or external support arrangements，According to the regulatory system to which they belong、Institutional size and business risks are checked separately。Appointing a permanent consultant does not mean transferring the statutory responsibilities of the licensed institution and management，Nor does it mean that a consultant is automatically permitted to hold statutory office。Hong Kong Xintong can assist internal personnel to handle daily compliance、Documentation and risk assessment；Specific appointments must first verify the applicable rules and personnel qualifications。
According to paragraphs 5.2 to 5.5 of the SFC Guidelines on Continuing Professional Training，LR Minimum 10 hours per calendar year，RO at least 12 hours，Among them, the additional 2 hours of RO must be regulatory compliance topics.；Not simply stacked based on the number of regulated activities。At least 5 hours of the total annual hours must be directly related to the regulated activity for which the license is issued at the time。Must complete 2 hours of ethics training within 12 months after first joining the industry，At least 2 hours of ethics or compliance training per calendar year thereafter；The 2 hours of ethics training for new entrants cannot be used as an additional 2 hours for RO.。Special conditions and pro-rata calculations need to be checked separately。 MSO、Anti-money laundering training for TCSP and other industries must be arranged separately according to the requirements of the respective competent authorities and positions.，SFC’s 10/12 hour rule cannot be applied。source：SFC Guidelines on Continuing Professional Training Section 5(Verified on September 7, 2026)。
According to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance(Chapter 615)strict regulations，All customer due diligence(CDD)Record、Account documents and business correspondence，Must be kept for at least 5 years after the end of the business relationship。All transaction records (including single transactions) must be kept for at least 5 years after the transaction is completed。Failure to keep proper records will be a criminal offense。
On-site inspections by regulatory agencies are usually divided into routine inspections and unannounced inspections triggered by specific events。The key to coping lies in daily and continuous compliance preparations：Ensure all CDD files are complete、Clear transaction monitoring records、The Compliance Manual is the latest version，and employees are familiar with compliance processes。during the inspection，Hong Kong Xintong can serve as an external consultant to assist companies in communicating with regulators，Explain internal control logic，and assist in drafting rectification responses after the inspection(Response to Deficiency Letter)。
Absolutely needed，And there are strict time limit requirements。For licensed institutions，Any major changes (including changes in major shareholders、Director/RO resigns、Change of office address、bank account changes, etc.) usually require prior approval from the regulatory authority before the change occurs，Or provide statutory notification within 7 to 14 working days after the change occurs。Failure to notify on time is a serious violation，May result in license revocation。
SFC licensed corporations must maintain the Financial Resources Rules at all times(FRR)Required minimum paid-up share capital and liquid capital。Once liquid funds are found to fall below 120% of the legal minimum requirement (early warning level)，The SFC must be notified immediately。If it falls below the minimum requirement，Relevant regulated activities must cease immediately。Hong Kong Xintong assists enterprises in establishing a daily fund monitoring mechanism，and provide compliant capital injections or subordinated loans when funds are tight(Subordinated Loan)Architectural recommendations。
Institutional Risk Assessment(Institutional Risk Assessment, IRA)Is the core of AML compliance。It must comprehensively assess four risk dimensions：1. Customer risk (e.g. PEP、Proportion of non-resident customers)；2. Country/regional risk (such as whether it involves FATF high-risk jurisdictions)；3. Product/service risks (such as whether to provide anonymous trading or high-leverage products)；4. Delivery channel risk (such as non-face-to-face account opening ratio)。Hong Kong Xintong assists companies to quantify these risks every year，and develop appropriate risk mitigation measures。
Can't。Hong Kong regulators (such as the SFC、Customs) strictly prohibits licensed institutions from remaining in a ‘dormant’ or ‘empty shell’ state for a long period of time。Licensed institutions must have substantial business operations、Suitable office space and core management personnel based in Hong Kong。If the institution does not conduct business for a long period of time after being granted a license，or stop business midway，The supervisory authority has the power to impose 'inadequate and competent'(Not Fit and Proper)’ to revoke its license。Hong Kong Information Communications recommends that enterprises still need to maintain minimum compliance operations and reporting during the business suspension period。
