Circular to Licensed Corporations and Associated Entities - Anti-Money Laundering / Counter-Terrorist Financing
United Nations (Anti-Terrorism Measures) Ordinance

2 Mar 2018

Circular to Licensed Corporations and Associated Entities 

Anti-Money Laundering / Counter-Terrorist Financing 

United Nations (Anti-Terrorism Measures) Ordinance 

Further to our circular issued on 20 February 2018 Note 1 regarding the amendment by the United Nations Security Council (“the UNSC”) committee which administers the sanctions regime relating to ISIL (Da'esh) and Al-Qaida of its sanctions list, an updated list specifying terrorists and terrorist associates designated by the UNSC was published under section 4 of the United Nations (Anti-Terrorism Measures) Ordinance (“the UNATMO”) (Cap. 575) in the Gazette on 2 March 2018 (G.N. 1401 of 2018) Note 2 to reflect the amended sanctions list mentioned above.

Licensed corporations (“LCs”) and associated entities (“AEs”) are reminded to refer to Chapter 6 of the Guideline on Anti-Money Laundering and Counter-Terrorist Financing (“AML Guideline”) which contains guidance on the appropriate measures that LCs and AEs should take to ensure compliance with the UNATMO Note 3.  The Securities and Futures Commission (“SFC”) expects all new designations to be screened by LCs and AEs against their client lists as soon as practicable whenever there are updates.  LCs and AEs are also reminded to report any transactions or relationships they have or have had with any designated person or entity to the Joint Financial Intelligence Unit.

Should you have any queries regarding the contents of this circular, please contact Ms Kiki Wong on 2231 1569.

Intermediaries Supervision Department
Intermediaries Division
Securities and Futures Commission



Note 1 The circular issued on 20 February 2018 re: early alert on United Nations Sanctions can be found on the SFC’s website (
Note 2 The gazette notice can be found on the Government’s website(
Note 3 Under paragraph 6 of the Prevention of Money Laundering and Terrorist Financing Guideline issued by the Securities and Futures Commission for Associated Entities, AEs that are not authorized financial institutions are expected to have regard to the provisions of the AML Guideline as if they were themselves LCs.

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Page last updated : 2 Mar 2018