Registry for Trust and Company Service Providers
Unit 1208, 12/F, One Kowloon, 1 Wang Yuen Street, Kowloon Bay, Kowloon, Hong Kong

Highlights of Disciplinary Cases


Name of Licensee and Licence No. Contravention Disciplinary Action Taken
JUN HONG LOGISTICS COMPANY LIMITED (TC007406) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

3. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$20,000 (Decision Date: 1 March 2024)  
Statement of Disciplinary Action
JRC SECRETARIAL SERVICES LIMITED (TC005926) The Licensee has contravened:

1. Section 5(1) of Schedule 2 to the AMLO, namely, namely, the Licensee has failed to continuously monitor the business relationship with a customer by reviewing from time to time documents, data and information relating to the customer that have been obtained by the Licensee for the purpose of conducting customer due diligence to ensure that they are up-to-date and relevant. 

2. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

3. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Imposition of a pecuniary penalty of HK$7,000 (Decision Date: 1 March 2024)  
Statement of Disciplinary Action
WALE’X ENTERPRISE SERVICES LIMITED (TC000910) The Licensee has contravened:

1. Section 2 of Schedule 2 to the AMLO, namely, the Licensee has failed to take measures to verify the identity of its customers and their beneficial owners.

2. Section 5 of Schedule 2 to the AMLO, namely the Licensee has failed to continuously monitor the business relationships with its customers.

3. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

4. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

5. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand and imposition of a pecuniary penalty of HK$20,000 (Decision Date: 1 March 2024)  
Statement of Disciplinary Action
MINGYOU BUSINESS CONSULTING CO., LIMITED (TC005786) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 2(1)(d) of Schedule 2 to the AMLO.

3. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

4. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

5. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$24,000 (Decision Date: 8 February 2024)  
Statement of Disciplinary Action
PROWINA SECRETARIES COMPANY LIMITED (TC003754) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

3. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$15,000 (Decision Date: 1 February 2024)  
Statement of Disciplinary Action
LUEN FAT BUSINESS (HK) LIMITED (TC007130) The Licensee has contravened section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand and imposition of a pecuniary penalty of HK$4,000 (Decision Date: 1 February 2024)  
Statement of Disciplinary Action
TIMES ENTERPRISES REGISTRATION SERVICE (HK) LIMITED (TC007126) The Licensee has contravened:

1. Section 5(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to continuously monitor the business relationship with a customer by reviewing from time to time documents, data and information relating to the customer that have been obtained by the Licensee for the purpose of conducting customer due diligence to ensure that they are up-to-date and relevant.

2. Section 20(1) of Schedule 2 to the AMLO on the record-keeping requirements.

3. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand and imposition of a pecuniary penalty of HK$5,000 (Decision Date: 1 February 2024)  
Statement of Disciplinary Action
HK ZHONGSHENG SECRETARIAL SERVICES LIMITED (TC008558) The Licensee has contravened:

1. Section 9 of Schedule 2 to the AMLO, namely, the Licensee has failed to carry out the special requirements when customer is not physically present for identification purposes.

2. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

3. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$12,000 (Decision Date:11 January 2024)  
Statement of Disciplinary Action
JINETIC CONSULTANTS LIMITED (TC000026) The Licensee has contravened:

1. Section 2(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to verify the customer’s identity on the basis of documents, data or information as required under section 2(1)(a); and the Licensee has failed to verify the authority of the person purporting to act on behalf of a customer as required under section 2(1)(d).

2. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

3. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand and imposition of a pecuniary penalty of HK$18,000 (Decision Date: 11 January 2024)  
Statement of Disciplinary Action
GOLD SUCCESS CORPORATE CONSULTING LIMITED (TC005834) The Licensee has contravened:

1. Section 2(1)(d) of Schedule 2 to the AMLO.

2. Section 9 of Schedule 2 to the AMLO.

3. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand and imposition of a pecuniary penalty of HK$10,000 (Decision Date: 19 December 2023)  
Statement of Disciplinary Action
FULL PERFECT LIMITED (TC000638) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 9 of Schedule 2 to the AMLO, namely, the Licensee has failed to carry out the special requirements when a customer is not physically present for identification purposes.

3. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

4. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

5. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$10,000 (Decision Date: 19 December 2023)  
Statement of Disciplinary Action
SUN BRIGHT COMMERCIAL CONSULTANCY LIMITED (TC003030) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

3. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Imposition of a pecuniary penalty of HK$12,000 (Decision Date: 22 November 2023)  
Statement of Disciplinary Action
UNION COMMERCIAL CONSULTANCY LIMITED (TC003381) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

3. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Imposition of a pecuniary penalty of HK$8,000 (Decision Date: 22 November 2023)  
Statement of Disciplinary Action
HK RJ INT'L BUSINESS LIMITED (TC003883) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 2(1)(d) of Schedule 2 to the AMLO, namely, the Licensee has failed to identify, and take reasonable measures to verify the identity of, the person purported to act on behalf of the customer and the person’s authority to act on behalf of the customer.

3. Section 5(1)(a) of Schedule 2 to the AMLO, namely, the Licensee has failed to continuously monitor the business relationship with a customer by reviewing from time to time documents, data and information relating to the customer that have been obtained by the Licensee for the purpose of conducting customer due diligence to ensure that they are up-to-date and relevant.

4. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining politically exposed persons.

5. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

6. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$25,000 (Decision Date: 31 October 2023)  
Statement of Disciplinary Action
NEW HONGKONG INTERNATIONAL BUSINESS CO., LIMITED (TC005484) The Licensee has contravened:

1. Section 2(1)(a) of Schedule 2 to the AMLO.

2. Section 9 of Schedule 2 to the AMLO.

3. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

4. Section 20 of Schedule 2 to the AMLO on the record-keeping requirements.

5. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand and imposition of a pecuniary penalty of HK$15,000 (Decision Date: 30 October 2023)  
Statement of Disciplinary Action
S & F SECRETARIAL SERVICES LIMITED (TC000009) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

3. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$24,000 (Decision Date: 26 September 2023)  
Statement of Disciplinary Action
S & F ENTERPRISE MANAGEMENT COMPANY LIMITED (TC001499) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

3. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$24,000 (Decision Date: 26 September 2023)  
Statement of Disciplinary Action
TEP LIMITED (TC003763) The Licensee has contravened:

1. Section 9 of Schedule 2 to the AMLO.

2. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

3. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

4. Section 20 of Schedule 2 to the AMLO on the record-keeping requirements.

5. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to mitigate money laundering and terrorist financing risks.
Public reprimand and imposition of a pecuniary penalty of HK$6,000 (Decision Date: 18 August 2023)  
Statement of Disciplinary Action
UNION TOP CONSULTANTS LIMITED (TC004799) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 2(1)(d) of Schedule 2 to the AMLO.

3. Section 9 of Schedule 2 to the AMLO.

4. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

5. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

6. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$30,000 (Decision Date: 18 August 2023)  
Statement of Disciplinary Action
HONGKONG ATS COMMERCIAL SECRETARY LIMITED (TC002413) The Licensee has contravened:

1. Section 53S(1) of Part 5A of the AMLO, namely, a person has become an ultimate owner of the Licensee without prior written approval of the Registrar.

2. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

3. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.

4. Section 2 of Schedule 2 to the AMLO.

5. Section 9 of Schedule 2 to the AMLO.

6. Section 19(3) of Schedule 2 to the AMLO.

7. Section 23 of Schedule 2 to the AMLO.
Public reprimand and imposition of a pecuniary penalty of HK$33,000 (Decision Date: 26 July 2023)  
Statement of Disciplinary Action
KD (HK) INTERNATIONAL COMPANY LIMITED (TC001379) The Licensee has contravened:

1. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

2. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.

3. Section 2 of Schedule 2 to the AMLO.

4. Section 19(3) of Schedule 2 to the AMLO.

5. Section 23 of Schedule 2 to the AMLO.
Public reprimand and imposition of a pecuniary penalty of HK$11,000 (Decision Date: 26 July 2023)  
Statement of Disciplinary Action
JOYCE PERFECT LIMITED (TC003364) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

3. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Imposition of a pecuniary penalty of HK$22,000 (Decision Date: 12 July 2023)  
Statement of Disciplinary Action
EXCEL ACCOUNTING SERVICES COMPANY LIMITED (TC001086) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

3. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Order for remedial action and imposition of a pecuniary penalty of HK$20,000 (Decision Date: 13 June 2023)  
Statement of Disciplinary Action
HONG KONG ACCOUNTING TAX LIMITED (TC001017) The Licensee has contravened:

1. Section 5(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to continuously monitor the business relationship with a customer by reviewing from time to time documents, data and information relating to the customer that have been obtained by the Licensee for the purpose of conducting customer due diligence to ensure that they are up-to-date and relevant.

2. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining whether a customer or a beneficial owner of a customer is a politically exposed person.

3. Section 20 of Schedule 2 to the AMLO on the record-keeping requirements.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to mitigate money laundering and terrorist financing risks.
Public reprimand and imposition of a pecuniary penalty of HK$10,000 (Decision Date: 31 May 2023)  
Statement of Disciplinary Action
TIN ON INTERNATIONAL COMMERCIAL SECRETARY LIMITED (TC002124) The Licensee has contravened:

1. Section 53S(1) of Part 5A of the AMLO, namely, a person has become an ultimate owner of the Licensee without prior written approval of the Registrar.

2. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

3. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.

4. Section 2 of Schedule 2 to the AMLO.

5. Section 9 of Schedule 2 to the AMLO.

6. Section 19(3) of Schedule 2 to the AMLO.

7. Section 23 of Schedule 2 to the AMLO.
Public reprimand and imposition of a pecuniary penalty of HK$28,000 (Decision Date: 16 May 2023)  
Statement of Disciplinary Action
CHEUNG WING HOLDINGS LIMITED (TC000902) The Licensee has contravened:

1. Section 53S(1) of Part 5A of the AMLO, namely, a person has become an ultimate owner of the Licensee without prior written approval of the Registrar.

2. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

3. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.
Imposition of a pecuniary penalty of HK$18,000 (Date of Decision:12 May 2023)  
Statement of Disciplinary Action
LEPUS PROFESSIONAL SERVICE COMPANY LIMITED (TC006050) The Licensee has contravened:

1. Section 53S(1) of Part 5A of the AMLO, namely, a person has become an ultimate owner of the Licensee without prior written approval of the Registrar.

2. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

3. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.
Public reprimand and imposition of a pecuniary penalty of HK$10,000 (Decision Date: 11 May 2023)  
Statement of Disciplinary Action
VALUE BUSINESS CENTER LIMITED (TC005242) The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar of Companies pursuant to section 53J of the AMLO, namely, the Licensee has failed to put in place adequate and proper anti-money laundering and counter-terrorist financing policies, procedures and controls, as evidenced by policy statement(s) or other written documents.

2. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining politically exposed persons.

3. Section 19(3) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures not inconsistent with the AMLO for the purpose of carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or 3 of Schedule 2; and to mitigate money laundering and terrorist financing risks.
Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$27,000 (Decision Date: 27 April 2023)  
Statement of Disciplinary Action
ALPINE ACCOUNTING & SECRETARIAL SERVICES LIMITED (TC005959) The Licensee has contravened:

1. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

2. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.
Public reprimand (Decision Date: 12 April 2023)  
Statement of Disciplinary Action
LANDIS & KADWELL FINANCIAL & TAX CONSULTING LIMITED (TC005832) The Licensee has contravened:

1. Section 53S(1) of Part 5A of the AMLO, namely, a person has become an ultimate owner of the Licensee without prior written approval of the Registrar.

2. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

3. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.

4. Section 19(1) of Schedule 2 to the AMLO.

5. Section 20 of Schedule 2 to the AMLO.
Imposition of a pecuniary penalty of HK$14,000 (Date of Decision:28 March 2023)  
Statement of Disciplinary Action
BRILLIANT SECRETARIAL SERVICES LIMITED (TC000624) The Licensee has contravened:

1. Section 53S(1) of Part 5A of the AMLO, namely, a person has become an ultimate owner of the Licensee without prior written approval of the Registrar.

2. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

3. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.
Public reprimand, ordering the Licensee to take remedial action and imposition of a pecuniary penalty of HK$28,000 (Decision Date: 23 March 2023)  
Statement of Disciplinary Action
FELICITY MANAGEMENT LIMITED (TC002581) The Licensee has contravened:

1. Section 53S(1) of Part 5A of the AMLO, namely, a person has become an ultimate owner of the Licensee without prior written approval of the Registrar.

2. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

3. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.
Public reprimand and imposition of a pecuniary penalty of HK$10,000 (Decision Date: 23 March 2023)  
Statement of Disciplinary Action
CHARTER FRIEND LIMITED (TC000800) The Licensee has contravened:

1. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

2. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.
Public reprimand and imposition of a pecuniary penalty of HK$15,000 (Decision Date: 28 February 2023)  
Statement of Disciplinary Action
JUN GANG BUSINESS SECRETARY (HONG KONG) CO., LIMITED (TC007108) The Licensee has contravened:

1. Condition 1 of the licence imposed by the Registrar pursuant to section 53J of the AMLO, namely, the Licensee has failed to ensure that a new Compliance Officer or Money Laundering Reporting Officer (as the case may be) is appointed within 7 days where a vacancy occurs in the two posts.

2. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

3. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.
Public reprimand and imposition of a pecuniary penalty of HK$32,500 (Decision Date: 27 January 2023)  
Statement of Disciplinary Action
AYASA GLOBO FINANCIAL SERVICES LIMITED (TC001109) The Licensee has contravened:

1. Section 53S(1) of Part 5A of the AMLO, namely, a person has become an ultimate owner of the Licensee without prior written approval of the Registrar.

2. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

3. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place. 
Imposition of a pecuniary penalty of HK$18,000 (Decision Date: 16 January 2023)  
Statement of Disciplinary Action
ZENITH CONSULTING SERVICES LIMITED (TC005121) The Licensee has contravened:

1. Sections 2(1)(a) and 3(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to take measures to identify and verify the identity of customers before establishing business relationship with customers.

2. Section 5(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to continuously monitor the business relationship with a customer by reviewing from time to time documents, data and information relating to that customer that have been obtained by the Licensee for the purpose of conducting customer due diligence to ensure that they are up-to-date and relevant.

3. Section 20(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to keep the original or copies of the documents and records obtained in the course of identifying and verifying the identity of customers in accordance with Part 2 of Schedule 2 to the AMLO.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to mitigate money laundering and terrorist financing risks.
Public reprimand and imposition of a pecuniary penalty of HK$10,000 (Decision Date: 19 July 2022)  
Statement of Disciplinary Action
THE LAW DEBENTURE CORPORATION (H.K.) LIMITED (TC002897) The Licensee has contravened:

1. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

2. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.  
Imposition of a pecuniary penalty of HK$33,000 (Decision Date: 17 June 2022)    
Statement of Disciplinary Action
LAW DEBENTURE TRUST (ASIA) LIMITED (TC002898) The Licensee has contravened:

1. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

2. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.  
Imposition of a pecuniary penalty of HK$43,000 (Decision Date: 17 June 2022)  
Statement of Disciplinary Action
NOVA BUSINESS SERVICES LIMITED (TC000745) The Licensee has contravened:

1. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

2. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.
Imposition of a pecuniary penalty of HK$10,000 (Decision Date: 31 May 2022)  
Statement of Disciplinary Action
GLOBAL CONSULTING MANAGEMENT LIMITED (TC006521) The Licensee has contravened:

1. Section 53U(1) of Part 5A of the AMLO, namely, a person has become a director of the Licensee without prior written approval of the Registrar.

2. Section 53W(1) of Part 5A of the AMLO, namely, the Licensee has failed to notify the Registrar of changes in its particulars within 1 month beginning on the date on which the changes take place.
Public reprimand (Decision Date: 30 April 2022)  
Statement of Disciplinary Action