HK watchdog takes disciplinary action against 33 Financial Services Limited

The Hong Kong Monetary Authority (HKMA) announces the completion of an investigation and disciplinary proceedings for 33 Financial Services Limited (33FS) under the Payment Systems and Stored Value Facilities Ordinance (PSSVFO).

The regulator has reprimanded and ordered 33FS to pay a pecuniary penalty of HK$875,000 for contravening section 8Q of the PSSVFO as it failed to fulfill the minimum criterion relating to anti-money laundering and counter-terrorist financing measures under section 6(2)(b) of Part 2 of Schedule 3 to the PSSVFO.

The disciplinary action follows an on-site examination and further investigation by the HKMA which found that, during the period from November 2016 to June 2019, 33FS failed to have in place adequate and appropriate systems of control to comply with the relevant paragraphs of the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) for Stored Value Facility (SVF) Licensees.

Specifically, the contravention relates to deficiencies in 33FS’ systems of control in two areas, namely:

  • (a) continuously monitoring business relationships in respect of transaction monitoring; and
  • (b) implementing an effective name screening mechanism.

In deciding the disciplinary action, the regulator took into account a variety of factors, including the seriousness of the investigation findings and the need to send a clear deterrent message to 33FS and the industry about the importance of effective controls and procedures to address money laundering (ML) and terrorist financing (TF) risks.

Ms Carmen Chu, Executive Director (Enforcement and AML) of the HKMA, said,

“While the majority of the SVF sector is characterised by lower ML/TF risks in view of the business nature, higher risk situations may emerge as business scale and scope develop, such as prepaid cards being misused for cash withdrawals funded by third-party’s (non-cardholders’) deposits.

All SVF licensees are expected to make reference to the lessons learnt from this case as well as the guidance provided by the HKMA in the Guideline and circulars in their ongoing efforts to have in place effective AML/CFT systems of control for identifying, assessing and managing ML/TF risks, especially when encountering higher ML/TF risk situations.”

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  1278. HKMA这次对33FS的罚款，金额不算特别大，但时间跨度从2016到2019年，说明监管盯着漏洞盯了挺久。像它提到的“持续监控业务关系”这一点，很多小平台其实都容易马虎，用户自己也得多个心眼。之前我因为类似的事查过一些监管记录，发现不同地区的处理方式差别不小，有篇分析写得挺清楚， fable5 fable5 里的对比表格直接列出了几个案例。这种细节不注意，真出了问题才麻烦。

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  1314. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  1315. May I simply say what a relief to discover an individual who genuinely knows what they are talking about on the net. You definitely know how to bring an issue to light and make it important. More and more people ought to check this out and understand this side of your story. I was surprised you are not more popular given that you most certainly have the gift.

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