GANGCHENG ENTERPRISE MANAGEMENT CONSULTING LIMITED (TC002460)

The Licensee has contravened:

1. Section 2(1)(a), (b) & (d) of Schedule 2 to the AMLO, namely, the Licensee has failed to take measures to verify the identity of its customers and their beneficial owners.

2. Section 9 of Schedule 2 to the AMLO, namely, the Licensee has failed to carry out the special requirements when customer is not physically present for identification purposes.

3. 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.

4. 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.

5. 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.

Statement of Disciplinary Action