The requirements relating to customer due diligence (CDD) and record-keeping for financial institutions are set out in Schedule 2 to the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (AMLO). 

As an interim provision, the AMLO permits financial institutions to outsource the performance of the CDD measures to specified intermediaries, on the condition that these intermediaries have adequate procedures in place to prevent money laundering and terrorist financing. The government has published a Gazette Notice to extend this provision, which was due to expire on 31 March 2015, for three more years until 31 March 2018.

As a reminder to licensed companies, although the CDD procedures may be outsourced to an eligible intermediary, ultimate responsibility resides with the licenced entity.  The licensee needs to be comfortable that all the AML work conducted on its behalf complies with Hong Kong’s AML regulatory framework and that records are maintained.