ZENITH CONSULTING SERVICES LIMITED (TC005121)

The Licensee has contravened:

1. Sections 2(1)(a) and 3(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to take measures to identify and verify the identity of customers before establishing business relationship with customers.

2. Section 5(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to continuously monitor the business relationship with a customer by reviewing from time to time documents, data and information relating to that customer that have been obtained by the Licensee for the purpose of conducting customer due diligence to ensure that they are up-to-date and relevant.

3. Section 20(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to keep the original or copies of the documents and records obtained in the course of identifying and verifying the identity of customers in accordance with Part 2 of Schedule 2 to the AMLO.

4. Section 23 of Schedule 2 to the AMLO, namely, the Licensee has failed to take all reasonable measures to mitigate money laundering and terrorist financing risks.

Public reprimand and imposition of a pecuniary penalty of HK$10,000 (Decision Date: 19 July 2022)

Statement of Disciplinary Action