Anti-Money Laundering and Counter Financing of Terrorism

Regulatory Compliance

Anti-Money Laundering and Counter Financing of Terrorism

Anti-Money Laundering and Counter Financing of Terrorism

Organisations offering designated services are faced with a multitude of money laundering and terrorism financing risks. Assisting reporting entities (excluding remittance network providers, hotels and gaming venues) with their regulatory compliance and offering practical guidance on the identification, mitigation and the management of their money laundering and terrorism financing risks.

Hong Kong

Core Obligations


Requirement for AML/CFT Risk-Based Assessment

AML/CFT Systems for Designated Non-Financial Businesses and Professions (DNFBPs)

Customer Due Diligence (CDD) Requirements

Simplified Customer Due Diligence in Low Risk Cases

Enhanced Due Diligence Measures in High Risk Cases

Ongoing Monitoring of CDD

Prohibition on Terrorist Financing, Financial Sanctions and Proliferation Financing

Reporting Suspicious Transactions (ST) and Responding to Law Enforcement Requests

Record Keeping

Staff Training

Wire Transfers

Correspondent Banking Relationship

Establish Private Banking CDD

Legal Landscape

Anti-Money Laundering and Counter-Terrorism Financing Ordinance (Cap. 615)

Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405)

Organized and Serious Crimes Ordinance (Cap. 455)

United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575)

Payment Systems and Stored Value Facilities Ordinance (Cap. 584)

Securities and Futures Ordinance (Cap. 571)

and 29 other compliance sources


Hong Kong Monetary Authority

Hong Kong Securities and Futures Commission

Insurance Authority Hong Kong

Law Society of Hong Kong

Hong Kong Institute of Certified Public Accountants

Estate Agents Authority

Companies Registry

Hong Kong Customs and Excise Department

Inland Revenue Department

Legal Expert


Partner | ONC Lawyers

PRACTICE AREAS: Litigation & Dispute Resolution, Regulatory, Compliance & Internal Investigations, Criminal Litigation, Trade & Customs Litigation, Shareholders’ Dispute and Insolvency matters, Domestic and International Arbitration, Cybersecurity & Privacy Law matters

Before joining the legal profession, DOMINIC has worked in the banking sector and as well as in the Independent Commission Against Corruption (ICAC).

Dominic’s practice focuses on advising clients on matters relating to anti-corruption, white collar crime, law enforcement, regulatory and compliance matters in Hong Kong, including advice on anti-money laundering. He also handles cases involving corporate litigation, shareholders’ disputes and insolvency matters, defamation cases, domestic and international arbitration cases, cybersecurity, data security and privacy law issues, competition law matters, e-Discovery and forensic investigation issues as well as property litigation. His expertise includes:

  • Advised Hong Kong listed, US multinational companies and money service operators (MSO) on anti-money laundering matters and practices.
  • Advised major international companies and Hong Kong listed companies on anticorruption and bribery and other white-collar crime issues.
  • Advised and assisted clients on urgent asset freezing injunctions and liaising with law enforcement agencies concerning fraudulent fund transfers due to business email scams and hacked email systems.
  • Advised the joint and several liquidators of a liquidation matter for over 10 years with considerable recovery for the creditors over the years.
  • Advised a major broadcasting company on defamation issues, judicial review applications, investigation by regulators and shareholders’ dispute issues.

Dominic is currently a board member of a charity that provides a home service for sick children and their families. He is supportive and actively participating in the activities of the charity.



Core Obligations


Designated Services

Designated Business Groups (DBGs)

Enrolments with AUSTRAC

AML/CTF Programs

Correspondent Banking Relationships

Customer Due Diligence

Ongoing Customer Due Diligence

Threshold Transaction Reports (TTRs)

Suspicious Matter Reports (SMRs)

International Funds Transfer Instruction (IFTI) Reports

Electronic Funds Transfers — Information Requirements

Cross-border Movement (CBM) Reports

Compliance Reporting and Information Requests

Record Keeping

Financial Transaction Reporting and Record Keeping for Cash Dealers

Dealing with Proceeds or Instruments of Crime and Preventing the Support of Terrorism

AUSTRAC Industry Contribution Levy

Legal Landscape

Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)

Anti-Money Laundering and Counter-Terrorism Financing (Prescribed Foreign Countries) Regulation 2018 (Cth)

Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) (Cth)

Australian Transaction Reports and Analysis Centre Industry Contribution Act 2011 (Cth)

Australian Transaction Reports and Analysis Centre Industry Contribution (Collection) Act 2011 (Cth)

Australian Transaction Reports and Analysis Centre Industry Contribution Determination 2017 (No. 1) (Cth)

Privacy Act 1988 (Cth) Sch 1 Pt 3(6)

includes over 70 compliance sources


United Nations Security Council (International)

Attorney General's Department (Australia)

Australian Securities and Investments Commission (Australia)

Australian Transaction Reports and Analysis Centre (Australia)

Department of Home Affairs (Australia)

Department of Foreign Affairs and Trade (Australia)

The Treasury (Australia)

Office of the Australian Information Commissioner (Australia)

and 5 other regulators

Legal Expert


Special Counsel | Mills Oakley

ROBIN has more than 35 years' experience acting for Australian and international clients in mergers and acquisitions and corporate advisory matters. He has acted for many international clients setting up operations in Australia, advising about the Australian operations and assisting with the expansion of the business in Australia and in using Australia as a base for expansion into Asia. His clients include businesses in the financial services, manufacturing, tourism, aged care and resources industries, as well as acting for professional services operations.

Robin has been nominated as a ‘Best Lawyer’ in Australia in the areas of Construction/ Infrastructure Law, Commercial Law and Corporate Law.



Core Obligations


Specified Business Operator

Overview of Customer Due Diligence Procedures

Details of Customer Due Diligence

Suspicious Transaction Reporting (STR)

International Transactions

Implementation of AML/CFT programme

Comply with international sanctions

Prepare for Foreign Exchange inspection by Authority

Legal Landscape

Act on Prevention of Transfer of Criminal Proceeds

Foreign Exchange and Foreign Trade Act

Act on Special Measures Concerning Asset Freezing, etc. of International Terrorists

Act on Punishment of Financing to Offences of Public Intimidation

and 22 other compliance sources


Financial Services Agency

Japan Financial Intelligence Center

Ministry of Finance

and 8 other regulators

Legal Experts


Partner | Chuo Sogo Law Office, P.C.

PRACTICE AREAS: Financial Regulation, AML/CFT, Corporate Law, M&A, Financial Transactions, Investment, Commercial Litigation

KOJI's main areas of practice encompass broad range of corporate commercial transactions, corporate finance, mergers & acquisitions and general corporation works. In addition, he has advised on various financial institutions in all aspects of their operations, with a focus on financial regulatory matters. Especially, with his experience worked at the Financial Services Agency, Japanese Government, he has been working on compliance issues of financial institutions including AML/CFT, countermeasures against Anti-Social Forces, personal data protections. He has also worked for clients in commercial and banking litigations in Japan, and dispute resolutions.

Koji has represented both Japanese and overseas clients, mainly focusing on financial institutions including banks, insurance companies, security brokerages, asset management companies, investment funds, credit card companies, leasing companies and non-bank finance companies. Such representation extends to complex financial regulatory matters (including issues relating to the Banking Act, the Insurance Business Act, the Financial
Instruments and Exchange Act, the Money-lending Control Act, the Investment Act and the Asset Securitization Act), structured finance and litigations arising from the sales of financial instruments.

Koji graduated from Kyoto University in 2003, the Legal Training and Research Institute of the Supreme Court of Japan in 2004, and Northwestern University School of Law in 2012. He was admitted as Attorney at Law in Japan (2004) and New York (2013).


Associate | Chuo Sogo Law Office, P.C.

PRACTICE AREAS: Financial Regulation, AML/CFT, Commercial Litigation

EIKI TAKAHASHI is an attorney at law working at Chuo Sogo Law Office, P.C. and was seconded to the Financial Services Agency (FSA) from January 2016 to April 2018, where he was primarily involved in supervisory work related to AML/CFT and countering anti-social forces, as well as inspection and supervision of the virtual currency (crypto-assets) sector. Since returning to the firm, he has been providing financial regulatory advice to financial institutions, including banks and virtual currency exchanges, on AML/CFT and other matters.

He also has experience in corporate legal advice and litigation, M&A-related work, debt collection and financial litigation.


New Zealand

Core Obligations

Customer Due Diligence

Suspicious Activity Reports

Prescribed Transaction Reports

Record Keeping

AML/CFT Programme

Risk Assessment

Other AML/CFT Compliance

Cross-border Transportation of Cash

Legal Landscape

Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (NZ)

Privacy Act 1993 (NZ)

Crimes Act 1961 (NZ)

Evidence Act 2006 (NZ)

Companies Act 1993 (NZ)

Customs and Excise Act 2018 (NZ)

and 21 other compliance sources


Department of Internal Affairs

Ministry of Justice

Ministry of Business, Innovation and Employment

New Zealand Customs Service

Legal Expert


Partner | Bell Gully

PRACTICE AREAS: Media, Consumer law, Intellectual property, Litigation and dispute resolution, Privacy and data protection, Information, communications and technology, Food, beverage and hospitality, Cybersecurity, Anti-Bribery and Corruption

TANIA advises on all aspects of advertising promotions, including impacts of the Gambling Act, Fair Trading Act and Privacy Act. She is also experienced in advising on food and wine labelling issues, involving advice on the Food Standards Australia New Zealand (FSANZ) Code, the Food Act, the Wine Act and related regulations and industry codes.

She has a strong media law background, advising on defamation claims, appearing in Court on name suppression issues, and providing media law training to journalists. She advises on all aspects of intellectual property law, including copyright, passing off and trade mark infringement disputes and litigation.

In addition to her particular areas of expertise, Tania provides general advice on commercial and contractual disputes and litigation with successful outcomes for her clients.

Tania is recommended for intellectual property by The Legal 500 Asia Pacific 2020, which notes her specialties as media, advertising, privacy law and IP matters. Tania is also recommended as a recognised practitioner by Chambers Asia Pacific 2020 for Technology, Media and Telecoms.



Core Obligations


Counter-terrorism financing

AML onboarding and transaction monitoring

MAS Notices and Guidelines

The anti-money laundering regime

Compliance requirements

International regulation and compliance

MAS Enforcement

Customer identification processes

Legal Landscape

Monetary Authority of Singapore Act

Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act

Terrorism (Suppression of Financing) Act

Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act 2019

Securities and Futures Act

and 71 other compliance sources


Monetary Authority of Singapore

Legal Experts


Partner | RHTLaw Asia

PRACTICE AREAS: Restructuring & Insolvency, Fraud, Asset Recovery & Investigations, Family, Probate & Trusts

He was listed in Who’s Who Legal 2015 and 2019 for Investigations, Who’s Who Legal 2019 for Asset Recovery and “Recommended” by Doyles’ Guide on Leading Singapore Family & Divorce Lawyers in 2015.

He is a Certified Fraud Examiner (ACFE), a member of the Chartered Institute of Arbitrators (CIArb) and INSOL International, and an affiliate of the Society of Trust and Estate Practitioners (STEP). He also holds certification in IT risk, governance, security and computer forensics and is a Certified Blockchain Professional (IIB).




Partner | Rajah & Tann Singapore LLP

PRACTICE AREAS: Restructuring & Insolvency, Fraud, Asset Recovery & Investigations

LIONEL has been recognised in several publications as a leading lawyer in insolvency, banking and commercial litigation as well as an authority on cross border asset tracing and investigations, including Asian Legal Business Legal Who’s Who, Chambers Asia Pacific (2008 to 2019), International Financial Review Law Review (2004 to 2010), International Who’s Who (for Insolvency as well as Investigations) 2011 to 2019, The Legal 500 Asia Pacific (2005 to 2019), and Euromoney’s Banking Finance and Transactional Expert Guide (2013, 2014). Lionel has also been recognised amongst his peers as being one of the leading lawyers in Singapore in the latest editions of Singapore’s Best Lawyers (2013 to 2019). Lionel has been variously described in these publications as a “top litigator” who “interacts extremely well with clients” and “can always be relied on to provide first class legal advice and practical solutions.”

United Kingdom

Core Obligations


AML/CTF Programs

Customer Due Diligence

Suspicious Activity Reports



Legal Landscape

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ('MLR 2017') (now amended by 2019 Regulation)

Money Laundering and Terrorist Financing Regulations 2019 (the Amending Regulations)

The Proceeds of Crime Act 2002

The Terrorism Act 2000

The Anti-Terrorism, Crime and Security Act 2001

Sanctions and Money Laundering Act 2018

and 30 other compliance sources

Regulators & Enforcement agencies

Crown Prosecution Service

National Crime Agency

HM Revenue & Customs (HMRC)

Financial Conduct Authority

Office of Financial Sanctions Implementation

and 8 other regulators

Legal Experts


Legal Counsel | Kingsley Napley

PRACTICE AREAS: Criminal Litigation

ALISON is Legal Counsel in Kingsley Napley’s Criminal Litigation team. Alison is a highly experienced criminal barrister. She joined Kingsley Napley in January 2020 from the public sector where, over a thirty-four year career as a government lawyer, she was a Registrar at the Criminal Appeal Office and then a prosecutor at Crown Prosecution Service Headquarters in London. She joins the pre-eminent financial crime team with a leading money laundering and proceeds of crime practice. Alison is a leading extradition lawyer and brings to the firm a varied and deep understanding of the prosecutor’s perspective, including international co-operation and Mutual Legal Assistance.



PRACTICE AREAS: Anti-Corruption, AML/Financial Regulatory, Public International Law, International/Transactional Criminal Law

ARVINDER SAMBEI is a practising barrister of over 30 years’ experience and one of the directors of London-based Amicus Legal Consultants.

She has previously held the posts of Head of Criminal Law at the Commonwealth Secretariat, Legal Adviser to the Permanent Joint Headquarters (PJHQ) at the UK’s Ministry of Defence and Principal/Senior Crown Prosecutor (Crown Prosecution Service of England & Wales). As a prosecutor, she had conduct of many of the UK’s high profile extradition, counter-terrorism, transnational and war crimes cases. In addition, her responsibilities
included liaison with other jurisdictions on treaty negotiations, extradition and mutual legal assistance requests.

As the Head of the Criminal Law Section at the Commonwealth Secretariat, she was responsible for ensuring design and delivery of programmes of assistance and training for member states to enhance criminal law systems.

Arvinder acts as an expert for many international and regional organisations (including Council of Europe, EU, IMF, and UN agencies) on anti-corruption & governance, AML/CFT, sanctions, international co-operation, asset recovery, economic crimes, corporate criminal liability, maritime crime and security, human rights and public international law. She has also been engaged in treaty and legislative drafting, state and project evaluation, and capacity building/technical assistance programmes.

She is a published author of legal texts (with Oxford University Press and others), an experienced trainer and has written articles, practitioner manuals and technical papers published by, inter alia, the Council of Europe, Commonwealth Secretariat, OECD, OSCE and UNODC on her areas of expertise.


United States

Core Obligations


Financial Institutions Subject to AML Compliance

AML Compliance Officer

AML Compliance Program

Risk Assessments

Customer Identification Program (CIP) or Know Your Customer (KYC) Program

Enhanced Due Diligence

Cash Reporting and Currency Transaction Reports (CTRs)

Suspicious Activity Reporting (SAR)

Reporting and Recordkeeping Requirements

Internal Controls

Independent Testing


Office of Foreign Assets Control (OFAC) Compliance Program

Information Sharing

Legal Landscape

The Currency and Foreign Transactions Reporting Act 1970

Money Laundering Control Act 1986

Money Laundering Suppression Act 1994

Antiterrorism and Effective Death Penalty Act 1996

and 9 other compliance sources


US Treasury Department

Financial Crimes Enforcement Network

Office of Foreign Assets Control

Internal Revenue Service

US Justice Department

Experienced Attorney Author


Founder | Finreg Partners

PRACTICE AREAS: Banking and Financial Services

DENA SOMERS is the founder of Finreg Partners, a regulatory compliance and risk management firm for the banking and financial services industries. Drawing on more than 20 years of legal and regulatory compliance experience in the banking and financial services industry, she helps clients navigate complex regulatory and compliance challenges by providing hands-on expertise in all areas of BSA/AML and consumer lending compliance. As a leading expert in her field, Dena provides compliance guidance and training nationwide on the most pressing issues in the industry, including, anti-money laundering, cybersecurity, cannabis and high-risk banking, GLBA and privacy compliance, Fintech, and regulatory risk management.

Prior to founding Finreg Partners, Dena served as General Counsel/Chief Compliance Officer to a national mortgage servicing company, regional mortgage lender, Fintech installment lender, and one of the largest Money Service Businesses in the U.S. In private practice, she has represented both consumers and financial institutions in a broad array of complex litigation matters for more than 15 years.

Dena authors several compliance and risk management publications for LexisNexis® including, Regulatory Compliance: Anti-Money Laundering and Counter-Terrorism Financing, BSA/AML Internal Audit and Risk Management, BSA and AML Service, BSA Officers Handbook, Bank and Credit Union Regulatory Compliance Alert, Bank Security Desk Reference, Loan Policies Manual, Self-Paced Loan Documentation and Training, and Bank Teller Training and provides guidance on the regulation of financial services as an attorney author for Lexis Practice Advisor. She has served as an expert witness in both federal and state courts and is an experienced public speaker on compliance and emerging trends, having presented before the Virginia legislature, CBS news, and numerous industry trade associations.

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