Board of directors,
(COMPANY NAME)____________________________________________
Dear Sir/Madam,
Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) (Amendment)
Ordinance 2018 (Ord. No. 4 of 2018) which extended the scope of the Anti-Money Laundering and
Counter Terrorist Financing (Financial Institutions) Ordinance (Cap 615) (AMLO) was effective as from
1 March, 2018. This amended AMLO thereof covers designated non-financial business and professionals
which includes our practice as certified public accountants.
Under the Anti-money laundering procedures manual for accountants there states the legal
requirements, “It is mandatory for accounting practices to have anti-money laundering (AML) and
counter terrorist financing (CFT) policies and procedures including customer due diligence (CDD), record
keeping, ongoing monitoring, reporting of suspicious transactions and screening persons and entities
designated by the United Nations Security Council, in relation to financial sanctions and terrorist
financing, when they engage in specified transactions with a client……”
Our accounting practice has to adhere to requirements in the HKICPA Code of Ethics (Sections
210 and 240) in HKSQC1 and HKICPA Guidelines on Anti-Money Laundering and Counter-Terrorist
Financing for Professional Accountants (“the Guidelines”).
Therefore, we shall carry out and complete sets of forms in order to verify and identify the entity
that you own and operate, the intermediary entities and the beneficial owners. We may also have to carry
out sanction report on individuals who are owners and/or directors/operators from international validation
searches through Reuters or Dow Jones which provide world-check. In short, we have to complete health
check on your operation through information obtained by completing the forms on “Know your Client”
(KYC) and “Customer Due Diligence” .
In view of the immense time spent in every entity, we have to charge a base fee to cover part of
our time cost. We have no intention to recover the full cost as we anticipate a long relationship between
you and us.
Yours faithfully,
PWPlus CPA Limited
Attached is a fee scale charge on the assignment for your reference.
FEE CHARGES
Verification and identification of the entity (company), number of beneficiaries including
intermediaries (usually for holding of shares exceeding 25%, controllers of the company (usually the
directors) plus out-of-pocket sanction/world check fees on number of searches.
HK$
(i) Base fee 1,800
Out-of-pocket expenses
Sanction/world check fees through public search providers
such as Reuters/Dow Jones
Each search 200
(ii) Each additional related company with common
shareholders and directors 800
Out-of-pocket expenses for search fees
Only on additional search each at 200
The above charges are one-off. On-going monitoring for subsequent years will only be charged if
much time is spent. Out-of-pocket expenses of search fees will be applied if needed.