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。
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。
According to the general guidance of Hong Kong regulatory authorities，Licensed organizations (such as SFC licensed corporations or MSOs) are generally required to conduct a comprehensive AML/CTF independent audit at least every two years。However，If the business scale of the institution is large,、Customer risks are higher (such as involving large amounts of cross-border remittances or virtual asset transactions)，or there have been major business changes recently，Regulators may require an annual independent audit。Hong Kong Information Communications recommends that high-risk institutions maintain annual audit frequency。
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。
The consequences are extremely serious。For ordinary companies，Late submission of annual returns will result in a fine of up to HK$3,480 and possible prosecution.。For SFC licensed corporations，Late submission of Financial Resources Rules(FRR)Report is a serious violation，The SFC has the power to suspend its license immediately，and to the responsible person(RO)and core management(MIC)take disciplinary action，even impose huge fines。
Can't。Hong Kong regulatory agencies (such as SFC and Customs) clearly require，Compliance officer(CO)and money laundering prevention director(MLRO)Must be a senior executive within the organization，and usually need to be resident in Hong Kong。Although positions cannot be outsourced，However, companies can hire professional organizations such as Hong Kong Information Technology Co., Ltd. to provide "compliance support services"，Assist internal CO/MLRO to handle daily compliance matters、Draft documents and conduct risk assessments。
SFC Licensed Representative(LR)and responsible personnel(RO)Must complete at least 10 to 12 hours of continuing professional training each year(CPT)，Must include a specific number of hours of compliance or ethics-related courses。For MSO and TCSP licensees，The Customs and Company Registry also requires all relevant employees to receive regular AML/CTF special training every year。Hong Kong Xintong can provide customized training courses and certifications that meet regulatory requirements。
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。
