HK RJ INT’L BUSINESS LIMITED (TC003883)

The Licensee has contravened:

1. Condition 2 of the licence imposed by the Registrar 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 2(1)(d) of Schedule 2 to the AMLO, namely, the Licensee has failed to identify, and take reasonable measures to verify the identity of, the person purported to act on behalf of the customer and the person’s authority to act on behalf of the customer.

3. Section 5(1)(a) 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 the 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.

4. Section 19(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to establish and maintain effective procedures for determining politically exposed persons.

5. 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.

6. 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, order for remedial action and imposition of a pecuniary penalty of HK$25,000 (Decision Date: 31 October 2023)

Statement of Disciplinary Action