JINETIC CONSULTANTS LIMITED (TC000026)

The Licensee has contravened:

1. Section 2(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to verify the customer’s identity on the basis of documents, data or information as required under section 2(1)(a); and the Licensee has failed to verify the authority of the person purporting to act on behalf of a customer as required under section 2(1)(d).

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 and imposition of a pecuniary penalty of HK$18,000 (Decision Date: 11 January 2024)

Statement of Disciplinary Action