Hong Kong AML Policies, Procedures and Controls (APPC) Template
Proprietary customizable APPC template with 90% complete for Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) compliance.
✔ APPC document template
✔ Risk assessment template
✔ CDD forms
✔ 1.5-hour Training*
Designated Non-Financial Businesses and Professions (DNFBP), including Trust and Company Service Provider (TCSP), Accountants, Company Secretaries and Dealers in Precious Metals and Stones (DPMS), are required under Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) to have AML Policies, Procedures and Controls (APPC) implemented firm-wide and documented in an APPC document (also known as the “AML/CTF Systems” or “Manual”).
If you are running one of the above regulated businesses, during an inspection by the regulator (e.g. CR/ HKICPA/ C&ED), there is a heavy weightage placed on the implementation of Risk-based approach and risk assessment, APPC document, and Customer Due Diligence (CDD) and beneficial ownership information. Such was the importance of APPC, and professional firms are required to have the APPC document ready when applying for or renewing their licence.
For busy professionals like yourself, or you are not sure how to develop an APPC document, you can now purchase a customizable AML policy template.
The templates are delivered in Microsoft Word/ Excel format, and are almost 90% complete for your firm to use. With these templates and training*, you can adjust and customize to your firm’s requirements, and be ready for inspector review!
Contents of APPC Template:
1. INTRODUCTION
2. POLICY STATEMENT
3. MANAGEMENT OVERSIGHT
4. RISK ASSESSMENT
5. CUSTOMER DUE DILIGENCE (“CDD”)
6. ENHANCED CUSTOMER DUE DILIGENCE
7. RECORD KEEPING
8. ON-GOING MONITORING
9. REPORTING A SUSPICIOUS TRANSACTION
10. AUDIT AND COMPLIANCE
11. HIRING OF NEW STAFF AND TRAINING
APPENDIX A. AML/CFT ROLES & RESPONSIBILITIES
APPENDIX B. RISK ASSESSMENT
APPENDIX C. INDICATORS OF SUSPICIOUS TRANSACTIONS
Customer Due Diligence Forms:
Form 1 Customer Information
Form 2 Client’s Particulars (Individual or Entity)
Form 3 Politically Exposed Person Information
Form 4 Risk Assessment
* Training is only available for regular-priced APPC and will not be provided to the orders with discounted rate.
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