Drafting robust, audit-ready compliance manuals, AML/CFT policies, and operational controls that satisfy SFC case officers without overburdening daily execution.
The SFC routinely rejects off-the-shelf, generic compliance manuals that fail to reflect the applicant’s actual operating workflows, trading systems, and risk profile. Case officers scrutinize every policy to confirm direct alignment with the Code of Conduct for Persons Licensed by or Registered with the SFC and the Internal Control Guidelines.
An effective compliance manual must clearly establish practical protocols for anti-money laundering (AML/CFT), personal account dealing, conflicts of interest, client onboarding, complaints handling, cybersecurity, and regulatory reporting routines.
Standard tangible deliverables prepared and submitted for statutory review:
A master operational policy document codifying governance structure, licensing conditions, senior management responsibilities, staff code of conduct, and disciplinary frameworks.
Rigorous anti-money laundering and counter-terrorist financing policies aligned with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Cap. 615) and SFC AML Guidelines.
Rules governing employee investment declarations, pre-clearance procedures, restricted lists, minimum holding periods, and prevention of insider dealing and market misconduct under SFO Part XIII and XIV.
Written operational guidelines fulfilling SFC circulars on cybersecurity, electronic trading controls, data encryption, third-party vendor management, and business continuity planning.
Structured Roadmap
Detailed walkthrough of front-office execution, middle-office reconciliation, client fund flows, and third-party vendor relationships.
Drafting tailored manuals matching your organizational chart, Manager-in-Charge (MIC) hierarchy, and target client classifications (Professional Investors).
Review session with Responsible Officers, Directors, and Compliance Officers to verify operational feasibility and regulatory consistency.
Finalizing the complete manual pack ready for direct upload to the SFC WINGS portal during initial licence application or regulatory review.
This advisory module directly supports applications and ongoing governance for:
No. The SFC strictly requires manuals to reflect Hong Kong law, including the Securities and Futures Ordinance (Cap. 571), the SFC Code of Conduct, the Management, Supervision and Internal Control Guidelines, and Hong Kong AML regulations. Group policies can be referenced, but local policies must be standalone and localized.
Yes. The SFC routinely requests draft compliance manuals, AML policies, and risk management frameworks during the formal requisition phase to evaluate whether management has instituted adequate systems of control.
Compliance manuals must be reviewed and updated at least annually, or promptly whenever the SFC publishes new guidelines, circulars, or when the firm introduces new business lines or system changes.
Yes. We deliver a complete set of compliance registers, including Personal Account Pre-Clearance Registers, Gift & Hospitality Logs, Conflict of Interest Registers, Breach Registers, and Complaint Logs.