TCSPs should assess customer risk by considering customer background, business nature, ownership structure, jurisdiction, delivery channel, transaction profile and high-risk indicators.
Why this matters
AML/CFT obligations are operational as well as documentary. A TCSP should be able to show not only that it has a policy, but also that relevant records, files and staff practices support the policy in practice.
Practical points for TCSPs
- Keep customer identification and verification records complete and accessible.
- Document risk ratings and approvals, especially for higher-risk customers.
- Maintain screening, ongoing monitoring and training records.
- Review policies and forms when regulations, business scope or customer profile changes.
How Chronovate AML can help
Chronovate AML provides AML/CFT independent review reports for Hong Kong TCSP licensees and optional add-ons such as AML/CFT Policy Manual, Customer Onboarding & EDD Forms Pack, Risk Assessment Form, Staff Training and post-review implementation support.