DNBC External AML Policy | DNBC Financial Hong Kong Limited
1. Our Commitment
DNBC Financial Hong Kong Limited (“DNBC Hong Kong”) is committed to conducting business with the highest standards of integrity, transparency, and accountability.
We recognize the serious global threats posed by money laundering (ML), terrorist financing (TF), and proliferation financing (PF). These crimes undermine the stability of the financial system, support organized crime and terrorism, and threaten the safety of communities worldwide.
As a licensed Money Service Operator (MSO) in Hong Kong, DNBC Hong Kong has put in place strong measures to ensure our services are not misused for illegal activities.
We comply with:
- The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615),
- The Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405),
- The Organized and Serious Crimes Ordinance (Cap. 455),
- The United Nations Sanctions Ordinance (Cap. 537), and
- International standards set by the Financial Action Task Force (FATF). (as reference)
2. Why AML/CTF/CPF is Important
- Money Laundering (ML): the process of hiding the origins of illegal money to make it look legitimate.
- Terrorist Financing (TF): providing funds that are intended to support terrorist organizations or activities.
- Proliferation Financing (PF): providing funds that support the spread of nuclear, chemical, or biological weapons.
By preventing these crimes, DNBC Hong Kong helps:
- Protect customers and their transactions.
- Safeguard the financial system of Hong Kong.
- Support international efforts to combat terrorism and serious crime.
3. Our Legal and Regulatory Obligations
Under Hong Kong law, DNBC Hong Kong must:
- Verify customer identity before providing services.
- Monitor transactions for unusual or suspicious activities.
- Report suspicious activities to the Joint Financial Intelligence Unit (JFIU).
- Retain records of customer information and transactions for at least five (5) years.
- Not disclose (tipping-off) when a suspicious transaction has been reported to authorities.
Failure to comply with these requirements may lead to severe penalties for both DNBC and individuals involved.
4. What Customers Need to Provide
To open an account or use our services, customers must provide accurate and valid information. This may includes:
Individuals
- Full name, date of birth, nationality, and proof of residential address.
- Government-issued identification.
Companies / Legal Entities
- Registration documents, business address, and nature of business.
- Names of directors and controlling persons.
- Identification of Ultimate Beneficial Owners (UBOs) (those who own or control 25% or more).
For All Customers
- Source of Funds (SOF): proof of where the money comes from (e.g. salary, sales, dividends).
- Source of Wealth (SOW): in some cases, we may require information about how the customer accumulated overall wealth.
- The intended purpose and nature of the relationship with DNBC.
Providing false or misleading information is a misuse of DNBC’s services and may lead to immediate refusal of service, account closure, and reporting to authorities.
5. When Enhanced Checks Apply
Some situations require Enhanced Due Diligence (EDD), where we collect additional information and apply stricter monitoring. These include:
- Customers who are Politically Exposed Persons (PEPs), their relatives, or close associates.
- Transactions involving high-risk jurisdictions identified by the FATF.
- Large cash transactions or complex transactions inconsistent with a customer’s profile.
In such cases, DNBC may require additional documentation, senior management approval, or may refuse the service.
6. Ongoing Monitoring and Record-Keeping
DNBC Hong Kong continuously monitors customer activity to ensure transactions are consistent with their profile and legitimate purpose.
- Customer monitoring: information is reviewed and updated regularly.
- Transaction monitoring: unusual, complex, or high-value transactions are flagged for review.
- Record retention: all customer and transaction records are kept securely for at least five years.
This ensures that DNBC can provide information to regulators whenever required.
7. Sanctions and Restricted Activities
DNBC Hong Kong complies with all international and domestic sanctions, as well as relevant regulations applicable to an MSO in Hong Kong, including the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), Financial Institutions (Resolution) Ordinance, and guidelines issued by Customs and Excise Department (C&ED).
We will not do business with:
- Individuals or entities subject to FATF, United Nations or Hong Kong sanctions.
- Shell banks, anonymous accounts, or opaque ownership structures.
- Customers connected with prohibited industries, organized crime, or terrorism.
Where permitted by law, certain exceptions will be reviewed on a case-by-case basis.
8. Reporting Suspicious Activities
If DNBC suspects that funds are linked to money laundering, terrorist financing, or proliferation financing:
- A Suspicious Transaction Report (STR) will be filed with the JFIU.
- Customers will not be informed, as this would constitute tipping-off.
- Affected accounts or transactions may be subject to restrictions, freezing, or termination.
This is both a legal obligation and a safeguard to protect the integrity of DNBC and the financial system.
9. Customer Rights and Responsibilities
As our valued customer, you have the right to fair, transparent, and professional service. At the same time, you are responsible for:
- Providing accurate and truthful information.
- Supplying documents promptly when requested.
- Cooperating with DNBC in all due diligence checks.
- Not using DNBC services for any unlawful or suspicious activities.
Failure to cooperate may result in DNBC refusing or terminating services and reporting the matter to authorities.
10. DNBC’s Rights
DNBC Hong Kong reserves the right to:
- Refuse to provide services if identity cannot be verified.
- Decline transactions that raise concerns of money laundering, terrorist financing, or sanctions violations.
- Close accounts if suspicious activities are detected.
- Report suspicious matters to authorities without informing the customer.
These measures ensure DNBC complies with the law and protects all customers.
11. Staff Training and Compliance Culture
All DNBC employees receive mandatory AML/CTF training on an annual basis and whenever necessary, ensuring they can:
- Recognize suspicious activities.
- Understand their legal obligations.
- Take the right steps to escalate concerns internally.
We foster a culture of compliance where every employee shares responsibility in protecting DNBC and its customers.
12. Cooperation with Authorities
DNBC Hong Kong fully cooperates with regulators and law enforcement agencies, including:
- The Customs & Excise Department (our primary regulator).
- The Joint Financial Intelligence Unit (JFIU) for suspicious transaction reporting.
- The Hong Kong Police Force and the Independent Commission Against Corruption (ICAC).
We provide timely documents, access, and support during inspections or investigations.
13. Conclusion
At DNBC Hong Kong, we see the fight against money laundering and financial crime as a shared responsibility. By working together with our customers and regulators, we aim to:
- Protect our customers and their funds.
- Safeguard the integrity of the financial system.
- Uphold Hong Kong’s reputation as a trusted international financial center.
We thank our customers for their cooperation and understanding in supporting these efforts.
Services Agreements: