The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) is Hong Kong’s core AML/CFT statute for customer due diligence, recordkeeping, supervision and licensing across covered financial institutions, money service operators and designated non-financial businesses and professions. For crypto markets, its most important current function is the statutory licensing framework for virtual asset exchange operators, introduced through the Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Ordinance 2022.
As of June 16, 2026, Cap. 615 is in force. The original ordinance was signed on July 7, 2011, published on July 8, 2011, and its principal operating provisions commenced on April 1, 2012. The current consolidated law is maintained by Hong Kong e-Legislation, with the latest cited consolidated update taking effect on May 15, 2026 after money service operator fee revisions.
Core AML/CFT framework under Cap. 615
Cap. 615 imposes statutory customer due diligence and recordkeeping requirements and gives relevant authorities supervisory and enforcement powers. Schedule 2 is the central operational schedule for CDD and recordkeeping, including customer identification, beneficial ownership, ongoing monitoring, risk-sensitive diligence and records that support regulatory review.
The ordinance operates alongside Hong Kong’s wider proceeds-of-crime and terrorist-financing laws. Suspicious transaction reporting and substantive money laundering or terrorist-financing offences are primarily addressed through other ordinances, including the Drug Trafficking (Recovery of Proceeds) Ordinance, the Organized and Serious Crimes Ordinance and the United Nations (Anti-Terrorism Measures) Ordinance. This profile therefore focuses on Cap. 615’s regulatory perimeter, licensing and AML/CFT compliance architecture.
Virtual asset exchange licensing
The 2022 amendment made Cap. 615 a central part of Hong Kong’s crypto regulatory perimeter. Under the amended ordinance, a person carrying on a business of operating a virtual asset exchange in Hong Kong, or actively marketing that service to Hong Kong investors, is subject to Securities and Futures Commission licensing. The SFC described the regime for centralised virtual asset trading platforms as coming into effect on June 1, 2023.
Licensed virtual asset exchange operators must satisfy a fit-and-proper test and comply with AML/CFT requirements, including CDD and recordkeeping. The regime is also linked to investor-protection standards, including safe custody of client assets, financial soundness, conflicts controls, audited accounts, financial reporting and the SFC’s inspection and investigation powers.
Affected sectors and regulators
- Financial institutions: banks, securities firms, insurers and related financial-sector participants are supervised through sector regulators and statutory guidelines.
- Money service operators: money changers and remittance operators are licensed under Cap. 615, with Customs and Excise responsible for the MSO licensing framework.
- DNFBPs and TCSPs: the 2018 amendments extended statutory CDD and recordkeeping requirements to legal professionals, accounting professionals, estate agents and trust or company service providers.
- Virtual asset trading platforms: the 2022 amendments placed virtual asset exchange operators under an SFC-administered AMLO licensing regime from June 1, 2023.
- Dealers in precious metals and stones: the 2022 amendments introduced a registration framework, with Category B registrants subject to AML/CFT supervision for specified cash transactions.
Status and timeline
The statute has evolved from a financial-institution AML/CFT framework into a broader cross-sector regime. The 2018 amendments extended coverage to designated non-financial businesses and professions and introduced TCSP licensing. The 2022 amendments added virtual asset exchange licensing and the precious-metals-and-stones dealer registration regime, with phase-in dates on April 1 and June 1, 2023. For virtual asset trading platforms that were already operating in Hong Kong before June 1, 2023, SFC transitional arrangements provided a non-contravention period through May 31, 2024 and a deemed-licensing arrangement from June 1, 2024 for applicants that met statutory conditions.
Cap. 615 remains an active reference point for Hong Kong crypto compliance because it anchors the SFC’s virtual asset exchange licensing regime. Readers should use the current consolidated text and sector-specific regulator guidance when checking legal status, because guidelines, fees and virtual-asset perimeter documents are updated separately from the ordinance text.