The SFC AML/CFT Guideline for licensed corporations and SFC-licensed virtual asset service providers is Hong Kong’s operative Securities and Futures Commission guidance on anti-money laundering and counter-financing of terrorism controls for securities-sector intermediaries and SFC-licensed VASPs. The guideline is issued under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and the Securities and Futures Ordinance (Cap. 571). The current seventh edition is dated June 2023, with most revised requirements effective from 1 June 2023 and the immediate-submission element of the virtual asset Travel Rule effective from 1 January 2024.
Key provisions of the Hong Kong SFC AML/CFT Guideline
The guideline is designed to set out statutory and regulatory AML/CFT requirements and the standards that licensed corporations and SFC-licensed VASPs should meet. It covers risk-based AML/CFT systems, customer due diligence, ongoing monitoring, terrorist financing, sanctions and proliferation financing controls, suspicious transaction reports, record-keeping, staff training, wire transfers, third-party deposits and payments, and virtual asset-specific controls.
Scope and legal effect
The guideline applies to licensed corporations and virtual asset service providers licensed by the SFC under the AMLO. It does not operate as standalone criminal liability for every failure to comply, but the guideline is admissible in proceedings under the AMLO or SFO, and relevant provisions must be taken into account where applicable. The SFC may also consider failures to comply in disciplinary, misconduct, or fitness-and-properness assessments.
Risk-based AML/CFT systems
The guideline expects financial institutions to take reasonable measures to mitigate money laundering and terrorist financing risks and to implement AML/CFT systems commensurate with identified risks. Those systems include compliance management arrangements, independent audit, employee screening, ongoing training, senior management oversight, and the appointment of compliance and money laundering reporting officers.
Customer due diligence and monitoring
Chapter 4 addresses customer due diligence and how firms should determine the extent of measures under a risk-based approach. The 2023 amendments also aligned the guideline with legislative changes on politically exposed persons, trust beneficial ownership, and recognized digital identification systems. The SFC describes these amendments as linked to the Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Ordinance 2022.
Virtual asset requirements and the Travel Rule
Chapter 12 is the central crypto-related component. It addresses money laundering and terrorist financing risks involving virtual assets, including risk assessments, virtual asset-specific CDD and ongoing monitoring, virtual asset transfers, and third-party deposits and payments made in virtual assets. For Chapter 12, virtual assets include virtual assets as defined in AMLO section 53ZRA and security tokens that constitute securities under the SFO.
The guideline treats virtual asset transfers as a distinct AML/CFT risk area. It requires ordering, intermediary, and beneficiary institutions to handle required originator and recipient information when a virtual asset transfer is conducted. The SFC describes the relevant transfer requirements as the Travel Rule, reflecting FATF Recommendation 16 adapted for virtual assets. Required information must be submitted securely, and from 1 January 2024 the relevant immediate-submission requirement applies before or when the virtual asset transfer is conducted.
Status and timeline
The SFC announced the revised AML/CFT guidelines on 24 May 2023, following consultation on proposed regulatory requirements for virtual asset trading platform operators. The Gazette notice was published on 25 May 2023 and stated that the AML/CFT Guideline would become effective on 1 June 2023, except for paragraphs 12.11.10 and 12.11.13, which became effective on 1 January 2024. As of 17 June 2026, the SFC guidelines index continues to list this guideline as the latest version dated 1 June 2023.
Why it matters for Hong Kong virtual asset regulation
The guideline is part of Hong Kong’s broader SFC virtual asset trading platform regime. Its AML/CFT provisions sit alongside the SFC’s VATP Guidelines and related licensing materials, but this profile focuses only on the AML/CFT guideline. It should be read as a legal-reference summary for editorial and research purposes, not as legal, compliance, tax, investment, or trading advice.