High-value cash sales of gold, jewellery, and gemstones make DPMS businesses a frequent target for money laundering. AMLO requires CDD for cash transactions of HK$120,000 or above.
⚠ CDD Threshold: Cash transactions ≥ HK$120,000
AMLO Obligations
CDD on buyers for qualifying cash transactions at or above HK$120,000
Enhanced CDD for international buyers or high-value repeat customers
Transaction records and CDD documents retained for 5 years
Suspicious Transaction Reports filed within 2 working days
How JustAML Helps
Instant identity check at point of sale for qualifying transactions
Automatic HK$120,000 threshold alert and CDD trigger
Risk assessment for international or high-value buyers
5-year transaction and CDD records maintained automatically
💎
DPMS Compliance Suite
Precious Metals & Jewellery · AMLO Ready
01
KYC & ID Verification
Core
02
Sanctions & PEP Screening
Core
03
Adverse Media (CDD)
Core
04
Cash Threshold Monitor
Specialist
05
Risk Assessment
Core
06
5-Year Record Keeping
Core
Licensed since 2018
🏛️
Trust & Corporate Service Providers (TCSP)
TCSPs form and administer companies, trusts, and foundations — structures frequently misused as money laundering vehicles. Licensed since 2018, they face some of AMLO's strictest obligations.
AMLO Obligations
Mandatory TCSP licence under the Companies Registry
CDD on all clients and verification of beneficial ownership
Enhanced screening for PEPs, high-risk jurisdictions, and shell structures
Ongoing monitoring for corporate ownership changes
How JustAML Helps
Verify beneficial owners through complex corporate structures
Enhanced PEP and sanctions screening for all directors and shareholders
Ongoing monitoring for corporate changes and ownership transfers
TCSP-specific transaction monitoring and risk templates
🏛️
TCSP Compliance Suite
Trust & Corporate Services · AMLO Ready
01
KYC / KYB Verification
Core
02
Enhanced PEP Screening
Core
03
Beneficial Ownership CDD
Specialist
04
TCSP Transaction Monitor
Specialist
05
Ongoing Corporate Monitor
Core
06
5-Year Record Keeping
Core
IA AML Guidelines
🛡️
Insurance Brokers
Life insurance products — including single-premium policies and policy assignments — can be exploited to place and layer illicit funds. The IA's AML guidelines require robust CDD at policy inception.
IA AML Guidelines
CDD on policyholders, beneficial owners, and third-party payers at inception
Enhanced CDD for high-value single premium and investment-linked policies
Monitoring for unusual premium payments, early surrenders, or policy assignments
Record retention for the life of the policy plus 5 years
How JustAML Helps
CDD on policyholders, beneficiaries, and third-party payers
Transaction monitoring for unusual premium payment patterns
Risk assessment tailored to product type (single premium, ILAS, etc.)
Full record keeping across the policy lifecycle
🛡️
Insurance Compliance Suite
Insurance Brokers & Intermediaries · IA Ready
01
Policyholder KYC
Core
02
Beneficiary Screening
Core
03
Premium Payment Monitor
Specialist
04
Product Risk Assessment
Specialist
05
Adverse Media (CDD)
Core
06
Policy Lifecycle Records
Core
SFC AML Guidelines
📈
Stock & Securities Trading
Securities accounts can be used to layer illicit funds through trading activity. SFC AML guidelines require client onboarding CDD, ongoing monitoring, and transaction surveillance.
SFC AML Requirements
CDD on all clients before account opening — individuals and corporates
Beneficial ownership verification for corporate and trust accounts
Ongoing screening for changes in sanctions or PEP status
Transaction monitoring for patterns indicative of layering
How JustAML Helps
Streamlined KYC for individual and institutional clients
Sanctions and PEP screening at account opening and on an ongoing basis
Beneficial ownership verification for corporate account holders
Transaction monitoring for layering patterns
📈
Securities Compliance Suite
Licensed Brokers & Dealers · SFC Ready
01
Client Onboarding KYC
Core
02
Sanctions & PEP Screening
Core
03
Beneficial Ownership Check
Specialist
04
Adverse Media (CDD)
Core
05
Trading Pattern Monitor
Specialist
06
Ongoing Monitoring
Core
AMLO 2018 · EAA
🏠
Estate Agents
Property transactions are the most common vehicle for large-scale money laundering. Added to AMLO in 2018, estate agents must perform CDD on both buyers and vendors — and report suspicious transactions.
AMLO / EAA Requirements
CDD on buyers and vendors in residential and commercial property transactions
Verify identity of authorised representatives acting on behalf of clients
Monitor for unusual payment structures (multiple payers, cash, overseas transfers)
STR to JFIU for transactions with suspicious features within 2 working days
How JustAML Helps
Rapid identity verification for buyers, vendors, and their representatives
Risk assessment considering property type, price, and client background
Automated evidence pack for STR filing
🏠
Real Estate Compliance Suite
Estate Agents · AMLO & EAA Ready
01
Buyer & Vendor KYC
Core
02
Sanctions & PEP Screening
Core
03
Property Transaction Monitor
Specialist
04
Payment Structure Analysis
Specialist
05
STR Evidence Pack
Specialist
06
5-Year Record Keeping
Core
C&ED Licensed
💱
Money Service Operators (MSO)
Currency exchange and remittance businesses handle large volumes of cash — making them high-risk for placement of laundered funds. CDD is mandatory for all qualifying transactions.
⚠ Exchange ≥ HK$8,000 · Remittance ≥ HK$25,000
C&ED / AMLO Requirements
CDD for currency exchange transactions ≥ HK$8,000
CDD for remittance transactions ≥ HK$25,000
Structuring detection: multiple transactions to circumvent thresholds
STR to JFIU within 2 working days; records for 5 years
Real-time transaction monitoring with structuring detection
Instant customer identity verification at the counter
Complete transaction records with 5-year retention
💱
MSO Compliance Suite
Money Exchange & Remittance · C&ED Ready
01
Counter KYC Verification
Core
02
Threshold Auto-Trigger
Specialist
03
Structuring Detection
Specialist
04
MSO Transaction Monitor
Specialist
05
Sanctions & PEP Screening
Core
06
5-Year Record Keeping
Core
FATF Recommendation 8
🌿
NGOs & Charities
Non-profit organisations are specifically identified by FATF Recommendation 8 as vulnerable to terrorist financing abuse. Regulators expect NGOs to assess their TF risk and implement proportionate controls.
FATF Rec. 8 & Best Practice
Conduct a terrorist financing risk assessment of the organisation's activities
Perform CDD on significant donors and counterparties
Monitor international fund transfers for unusual patterns
Maintain governance records for trustees, directors, and key persons
How JustAML Helps
Screen donors against global sanctions and terrorism financing lists
Terrorist financing risk assessment aligned with FATF Recommendation 8
Monitor international fund transfers for suspicious patterns
Governance and compliance record keeping for trustees and directors
🌿
NGO / Charity Compliance Suite
Non-Profits & Charities · FATF R.8 Ready
01
Donor Screening
Core
02
TF Risk Assessment (FATF R.8)
Specialist
03
International Fund Monitor
Specialist
04
Trustee / Director KYC
Core
05
Adverse Media (CDD)
Core
06
Governance Records
Core
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