Anti-money laundering & counter-terrorist financing (AML/CTF) policy summary
Last updated: 29.05.2025
1. Our Commitment
Rize HK Limited is committed to preventing money laundering, terrorist financing, and the misuse of its services. We adhere to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), as well as the applicable guidance issued by the Joint Financial Intelligence Unit (JFIU), and align our practices with relevant international standards and regulatory expectations. Our policies, procedures, and internal controls are tailored to identify, assess, monitor, and mitigate financial crime risks in line with our obligations.
2. Risk-Based Approach
We apply a comprehensive risk-based approach (RBA) to AML/CTF. All customers, services, delivery channels, and jurisdictions are assessed to determine the level of financial crime risk. Enhanced controls are implemented for high-risk scenarios, and simplified measures may apply to low-risk cases, subject to regulatory allowances.
3. Customer Due Diligence (CDD)
Prior to establishing any business relationship, Rize HK Limited performs CDD by identifying and verifying customer identity, including beneficial ownership and control structures.
4. Enhanced Due Diligence (EDD)
EDD measures are applied to customers and transactions presenting higher risk, such as politically exposed persons (PEPs), high-risk jurisdictions, or unusual activity. These measures may include verifying the source of funds and wealth, obtaining additional documentation, or conducting more frequent reviews and monitoring.
5. Ongoing Monitoring
Rize HK Limited monitors customer activity on an ongoing basis using a combination of internal procedures and technological tools. This includes monitoring transaction patterns, reviewing behaviour against expected profiles, and initiating internal reviews or investigations when needed.
6. Sanctions and Screening
We screen customers and connected parties against mandatory international sanctions lists including: — The United Nations Security Council (UNSC) — The Office of Foreign Assets Control (OFAC) — The Hong Kong SAR Government (published via Government Gazette) Additional lists may be incorporated based on regulatory guidance, emerging risks, or specific customer profiles. Screening is performed at onboarding and regularly thereafter. Manual and automated checks are applied as appropriate.
7. Adverse Media
Negative or adverse media screening is applied when relevant to assess reputational risks. Media sources may indicate potential involvement in financial crimes or unethical behaviour. Manual screening may be conducted during onboarding or reviews, particularly for higher risk customers.
8. Transaction Monitoring
We maintain transaction monitoring practices that include reviewing financial activity against risk typologies. Monitoring is performed both retrospectively and in real time, combining automated systems with human analysis. Activity inconsistent with the customer profile is subject to investigation.
9. Data Storage
Customer and transaction records are securely stored in line with regulatory requirements. Rize HK Limited retains AML/CTF-related data for at least 5 years from the end of the business relationship or the date of the transaction, whichever is later.
10. Reporting
Suspicious activity is escalated to the Money Laundering Reporting Officer (MLRO), who evaluates the matter and, if necessary, reports it to the Joint Financial Intelligence Unit (JFIU) of Hong Kong. All reports are properly documented and retained.
11. Governance and Training
Our AML framework includes an appointed MLRO, clearly defined roles across the business, and regular compliance oversight. Employees receive ongoing AML training tailored to their role and regulatory expectations.
12. Policy Review
This Policy is reviewed at least annually or upon significant regulatory updates. Amendments are made as necessary to ensure continued compliance and effectiveness in managing AML/CTF risks.
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