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