KEY WILL ACCOUNTANTS & ADVISORS LIMITED (TC008593)

The Licensee has contravened:

1. Section 2(1)(a), (b) and (d)(ii) 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 and to verify the authority of the persons purported to act on behalf of its customers.

2. Section 5(1) of Schedule 2 to the AMLO, namely, the Licensee has failed to continuously monitor the business relationships with its customers by reviewing from time to time documents, data and information relating to the customers 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 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 20(1)(b)(i) 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 its customers or any beneficial owner of the customers in accordance with Part 2 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.

Public reprimand, order for remedial action and imposition of a pecuniary penalty of HK$25,000 (Decision Date: 20 January 2026)

Statement of Disciplinary Action