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Hong Kong Customs and Excise Department
Responsible for MSO licensing since April 1, 2012、Fit and proper review、Premises inspection and ongoing supervision。
1. Background and legal basis of Hong Kong’s MSO licensing system
Hong Kong Money Service Operator，MSO) licensing system will be implemented by the Hong Kong Customs and Excise Department from April 1, 2012，The legal basis is the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Anti-Money Laundering and Counter-Terrorist Financing Ordinance) Chapter 615 of the Laws of Hong Kong (Anti-Money Laundering Ordinance)。Any person operating a currency exchange service or remittance service in Hong Kong，In principle, a license must be obtained before starting business；Convicted for operating without a license through public prosecution procedures，The maximum penalty is a fine of HK$1 million and imprisonment for 2 years.，If convicted under summary procedure, the maximum penalty is a fine of HK$100,000 and imprisonment for 6 months.。
This page is based onHong Kong Electronic Legislation Chapter 615 "Anti-Money Laundering and Counter-Terrorist Financing Ordinance"、Hong Kong Customs and Excise Department "Guidelines on Money Service Operator Licensing" (May 2026 Edition)and compilation of current application documents。88MSO does not represent Hong Kong Customs；Whether the specific business constitutes monetary services，should be based on the actual contract、service location、client、Fund control rights and payment path judgment。
Judge the business first，Re-establish team and rent premises：Setup、Technology platform、Neither the payment interface nor the name "cross-border payment" itself is equivalent to obtaining an MSO license.，Nor can it replace the regulatory characterization of each capital flow.。Involving virtual assets、Stored Value Facility、securities or restricted areas，Other licenses and cross-border laws must be assessed separately。
2. License core information
Legal business
Exchange/Remittance
Licenses are not graded by brand or technology；Application can cover currency exchange、Send money or both。
License term
Usually two years
Customs usually issues a reminder 90 days before expiration；The licensee must submit an application for license renewal at least 45 days before expiry.。
3. Regulated business scope and license boundaries
License plate boundary description
The "Anti-Money Laundering Ordinance" refers to only two legal categories of "money services": currency exchange services and remittance services.。The application scope should be explained with the website、Customer Agreement、System process、bank account、The settlement partner and actual fund flow are consistent。Authorized organization、Some licensed corporations、Authorized Insurer、Stored value facility licensees, etc., are only exempted if they meet statutory incidental business conditions.，There is no automatic exemption because other entities within the group are licensed。
currency exchange services
Refers to currency exchange services carried on as a business in Hong Kong。Retailers accept foreign currency as part of major transactions，And under legal conditions, the hotel can only purchase services in non-Hong Kong dollars for guests in Hong Kong dollars.，Not part of the general MSO currency exchange service。Quotes should be checked when making judgments、make a deal、Collection、Delivery currency and customer contact location。
Remittance service
Including one or more of the following services carried out as business in Hong Kong：To remit or arrange for remittance to a place outside Hong Kong；Receive or arrange to receive payments from outside Hong Kong；Arrange to receive payment outside Hong Kong。Whether to use a bank、payment service provider、Agent or technology platform，It will not automatically change the judgment of the actual arrangement of remittances.。
4. Hong Kong MSO license application requirements、Documents and fees
Hong Kong Customs review application subject、All persons subject to fit and proper testing、Business and management premises、Where the accounting records are kept、business plan、Banking and settlement arrangements and the AML/CFT regime。Current licensing guidelines do not set a unified statutory minimum registered capital，However, the applicant must still prove that the proposed model can continue to operate with a business plan and financial information。
Application subject and supporting documents
personal、Partnerships or corporations can apply。Corporate applicants must declare each director and ultimate owner；Ultimate owners include those who directly or indirectly own or control more than 25% of the issued share capital、More than 25% of the voting rights，or the individual who exercises ultimate control over management。Application documents usually include：
- Form 1 and Appendix
- Supplementary information form
- Form 3A for individuals or Form 3B for corporations
- Certificate of company registration
- Business registration certificate
- Articles of Association
- Latest annual return and subsequent changes submitted
- Equity and control structure
- Proof of identity and address
- Premises documents
- business plan
- AML/CFT Policy
- Proof of bank account and bank confirmation
Premises documents should be prepared separately according to purpose：
- Stamp the lease or proof of title
- floor plan
- 4R photos showing indoor and outdoor signage
- Document from the owner giving permission for the premises to be used for money services business
- Mixed commercial premises require written entry consent from each occupier
- Documents issued abroad、Non-Chinese or English documents and complex shareholding structures，Authentication may be required、Certified translation or additional explanation
Government charges and overall budget in 2026
Government charges and overall budget in 2026| project | Amount or billing method | Properties and description |
|---|---|---|
| First application for MSO license | HKD 3,810 yuan | statutory government charges；Applicable from May 15, 2026，The application fee is generally non-refundable if approved or rejected.。 |
| each additional business premises | HKD 2,440 yuan | Additional premises registered together with the first application will be charged on a per premises basis.。 |
| every fit and proper person | HKD 945 | Directors required to undergo testing、Partner、Calculation of the number of final owners and others。 |
| Basic license renewal fee | HKD 910 | Plus HK$410 for each additional premises and HK$945 for each suitable person。 |
| Add new directors、Partner or ultimate owner | HKD 945 per person | Matters subject to prior approval，Should not be appointed first and then reissued。 |
| Hong Kong Private Company Registration | Electronic submission of HKD1,545 yuan；Paper Hong Kong Dollar 1,720 yuan | Companies Registry Statutory Fees，In addition, current business registration fees and levies must be paid；The establishment of a company does not mean the approval of the MSO。 |
| company secretary、Registered address and annual return | Quote based on service plan | market cost，Not MSO government charges；The registration fee for annual returns submitted within 42 days of the anniversary date is currently HK$105。 |
| business premises、LMO and LPS | According to the lease and owner's quotation | market cost；Additional deposit should be charged、management fee、Apportionment of rates or government rent、stamp duty、Shop sign、furnish、Communications and Security。Virtual office quotes are not a substitute for physical premises accepted by customs。 |
| AML system、bank、Translation and professional services | Quote based on business complexity | market cost；Depends on customer volume、country risk、Transaction monitoring、Sanctions Screening、System integration、File language and number of patches。 |
Fit and proper people and governance
Individual applicant and each ultimate owner、Each partner and ultimate owner of the partnership applicant、Each director and ultimate owner of the corporate applicant must meet the fit and proper requirements。Customs will consider relevant convictions in Hong Kong and overseas、Money laundering or terrorist financing matters、Fraud、Corruption or dishonesty、Continued violation of the Anti-Money Laundering Ordinance、undischarged bankruptcy、liquidation or receivership，and other matters deemed relevant by the Commissioner。Customs will also verify information from government and law enforcement agencies。 Applicants must nominate a qualified sole proprietor、Partners or directors participate in competency assessment；The assessment results are one of the factors that determine the suitability of candidates。No senior management personnel participated in or passed the designated assessment，may be grounds for refusing to issue a license。See detailsHong Kong Customs and Excise Department's "Fit and Proper Criteria"。premises、LMO and LPS
Actual operation of money services、Meet customers with signs or promotional representations，Premises that are under the regular control of the applicant as owner or tenant，Should be listed as business premises。Completely residential buildings are not suitable for registration；Mixer's premises must be accessible to Customs officers，and obtain the written consent of each occupier。Joint operations with other MSOs on the same premises are not acceptable；When co-located with other businesses，Money service areas must be clearly separated and identifiable。 Businesses without fixed business premises must still maintain a physical Local Management Office (LMO) in Hong Kong that can be contacted in person and by telephone，Also have a correspondence address and be controlled by the licensee、Local records depository (LPS) where complete accounting records are available for inspection by Customs。LMO personnel must be sole proprietors、Partner、director、Ultimate Owner and/or Compliance Officer；Residential address or secretarial company、accounting firm、Service provider addresses such as law firms will not be accepted as LMOs。Business planning and cash flow
The business plan must fully describe the detailed business model、Organizational structure、payment or settlement system、target customers、Staffing and financial arrangements。The practical document should also itemize the products、Contracting entity、Service area、Customer source、Online or offline channels、Estimated number and amount of transactions、TOLL、Fund flow at every step、bank account、Agents and payment partners、outsourcing system、Accounting and Financial Forecasting。 If the applicant does not plan to operate through a bank account，Must explain in detail how the payment will be collected、exchange、deliver、Reconciliation and record keeping。Business plan must be accompanied by application form、contract、website、System demonstration、Bank purpose description and AML/CFT policy consistent，and by a sole proprietor、each individual partner、Directors and ultimate owners approved according to customs list。AML/CFT system and personnel
System must be based on institutional money laundering and terrorist financing risk assessment，Cover customers、Country or region、product、Serve、Transaction and delivery channel risks，and implement customer due diligence、Identification of ultimate beneficial owner、Continuous monitoring、Sanctions and high-risk customer screening、Internal escalation and reporting of suspicious transactions to the Joint Financial Intelligence Unit、record keeping、Employee screening、Ongoing training and independent audits。 Senior management must approve and oversee the AML/CFT system，Appointment of management-level Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO) responsible for suspicious transaction reporting。Both persons should have sufficient knowledge、Qualifications、Permissions、Access to resources and materials，Usually work in Hong Kong；When the size of the organization allows, the two functions can be performed by the same person，But the responsibility、Substitution and conflicts of interest must still be arranged in writing。See detailsHong Kong Customs and Excise Department's "Guidelines for Money Service Operators on Combating Money Laundering and Counter-Terrorist Financing"。5. Application process and customs review cycle
Hong Kong Customs has not committed to a unified review and approval days in the current licensing guidelines。Actual time depends on data completeness、business complexity、Repair speed、Premises inspection、Obtain suitable candidate information and competency assessment progress from other agencies；No agency can guarantee a fixed release date。
first step：Define business and application entities
Exchange by currency、remit、Arrangements for inward remittance and overseas collection draw contractual relationships and capital flows item by item.；Confirmation subject、Equity chain、Each director and ultimate owner、CO、MLRO、Banking and settlement partners，Then decide on business premises or no fixed premises model。
Step 2：Complete documents and submit
Complete form 1、Schedule、Supplementary information、Form 3A or 3B、business plan、AML/CFT policy and supporting documents，Can be passed through customs MSOS system、Submit by mail or in person。Information or documents are not completed within the specified deadline，Application may be deemed invalid and not processed。
Step 3：Pay the fees、Interview and original document verification
After all the information is ready，Customs issues interview notice、Payment Notice and Invitation for Nomination for Ability Assessment。Verify payment records and original documents during the interview，The applicant signs the application in front of customs officers，and explain the business plan、AML/CFT Policy、capital flow、Premises and system operations。
Step 4：review、Evaluation and written decision
Customs conducts fit and proper person verification、Capacity assessment and necessary premises inspections，and may request clarification or supplementary documents。The final result will be notified in writing by the Customs；If you refuse to deal，The applicant may appeal to the Anti-Money Laundering and Counter-Terrorist Financing Review Tribunal before the expiration of 21 days after the refusal notice.。
6. Licensed、Renewal and ongoing supervision
Statutory and regulatory responsibilities after licensing
- Display the original license in a conspicuous place at the business premises specified in the license，and continue to maintain the approved premises、LMO and LPS。
- each relevant individual、Partner、Directors and ultimate owners must continue to be fit and proper；Add new directors、Partner、Obtain approval from the Commissioner of Customs and Excise before the ultimate owner or business premises。
- Other registration information changes，Written notification in Form 6 must be given within one month from the date of change；When there is a major change in the business model，The business plan and AML/CFT policy should be updated simultaneously and checked whether prior approval is required。
- When operating using a bank account，The account must be with a licensed company、sole proprietor、Partner、Held in the name of director or ultimate owner，and consistent with the approved funding flow。
- Unless otherwise specified in writing by Customs，Submit a periodic transaction return form in the specified form within two weeks from the beginning of each half-year；Expiration may result in license suspension or revocation。
- After the customer relationship ends，Customer due diligence records are kept for at least 5 years；Occasional transaction records shall be kept for at least 5 years from the transaction date。Employee training records should be kept for at least 3 years。
License renewal arrangements
The license is usually valid for two years。Customs generally issues license renewal and competency assessment reminders 90 days before expiry.，However, it is the legal responsibility of the license holder to renew the license on time，Table 2、Supplementary information、Statement of Fit and Properity、business plan、AML/CFT policies and supporting documents must be submitted no later than 45 days before expiration。After receiving the competency assessment invitation，The licensee must nominate a qualified person within 7 days；Nominees will generally participate in the assessment within 30 days after receiving the invitation。Not submitted on time、No one participated or no one passed the designated assessment，The license may automatically expire upon expiration or the renewal application may be refused.。Verification update from 2023 to 2026
| date | Verified regulatory matters | Impact on applicants and licensees |
|---|---|---|
| April 1, 2023 | Maximum penalty for operating without license increased | The maximum penalty for conviction upon indictment is increased to a fine of HK$1 million and imprisonment for 2 years.；Go online、You must first confirm that the license is valid before collecting payment or advertising.。 |
| June 1, 2023 | Revised MSO AML/CFT guidance takes effect | Application and ongoing operations should be governed by a risk-based approach、CDD、Continuous monitoring、Sanctions Screening、STR、Independent audit and training。 |
| 2024-2025 | Current information continues to require competency assessment、LMO/LPS and regular reporting | No unified minimum capital threshold was identified from the official information reviewed for this review；You should not set your own statutory capital figures or fixed approval cycles by citing unofficial information.。 |
| May 15, 2026 | Schedule 3 fee revision takes effect | First time application、Renew license、Fees for additional premises and suitable candidates shall be paid according to the new schedule for 2026；HKD 3 in old data,The basic application fee of 310 yuan is outdated。 |
Official search and declaration portal
Should be used immediately before tradingHong Kong Customs and Excise Department Online Register of Money Services OperatorsCheck legal entity name、License status and registered address。The public purpose of the register is to confirm whether counterparties are licensed，and the status will change，Therefore, this page does not copy or package third-party licensed lists as "successful cases"。For the judgment and submission methods of suspicious transaction reports, seeJoint Financial Intelligence Unit Suspicious Transaction Report：Submission time、Methods and required information》。 Projects involving virtual asset exchange or custody，Can be further comparedHong Kong Virtual Asset Service Provider License Requirements；Projects that require the establishment of application entities，Can refer toHong Kong and overseas company registration services。These pages are used to identify concurrent licensing and company formation matters，Not a substitute for case-by-case analysis of MSO business boundaries。7. Frequently Asked Questions about Hong Kong MSO License Application
Applicable to persons or institutions operating currency exchange or remittance services as a business in Hong Kong。Remittance services include remitting or arranging remittances overseas、Receive or arrange to receive payments from abroad，and arranging payment collection abroad。should be based on the actual service location、contract、Fund control rights and operational process judgment，Don’t draw conclusions just based on the names of “payment platform”, “fintech” or “virtual assets”。
The Anti-Money Laundering Ordinance divides money services into two categories: currency exchange services and remittance services.，Applicants may operate in one or both categories。It is not paid by "、OTC、Cross-border e-commerce" and other business name sub-brands；The actual products after being licensed must still fall within the business model disclosed and accepted during the application。
personal、Partnerships or corporations can apply。Each director and ultimate owner of the corporation、Each partner and ultimate owner of a partnership、Individual applicants and their ultimate owners are subject to a fit and proper examination；Senior managers must also participate in competency assessments as arranged by the Customs。The applicant shall appoint a Compliance Officer and a Money Laundering Reporting Officer，Both persons usually work in Hong Kong and have sufficient qualifications、Permissions、Access to resources and materials。
The current Hong Kong Customs and Excise Department licensing guidelines reviewed this time do not stipulate a unified statutory minimum registered capital or amount of cash on hand.。Applicants must still submit financial arrangements in their business plan、Estimated trading volume、Banking and settlement routes、Cost and staffing，Enable Customs to judge whether the model is genuine and sustainable；The lack of a unified threshold does not mean that there is no need to prepare operating funds or explanations of funding sources.。
The virtual address cannot be used directly as the local management office required by customs。Applicants without fixed business premises must still maintain a physical LMO in Hong Kong that can be contacted in person and by telephone；Residential address，and secretarial firms、Addresses of service providers such as accounting firms or law firms will not be accepted by customs as LMOs。It must also be set up and controlled by the licensee、Hong Kong LPS for customs inspection of complete records。
Applications can be made under the "no specific business premises" mode，For example, only using mobile electronic devices to trade or meeting in the client's office，However, the applicant must declare an entity LMO、Correspondence address and LPS。Customs will check whether the LMO is genuine and accessible.、Qualified personnel are stationed at the site and can serve as supervisory contact points；Failure to maintain the LMO may result in suspension or revocation of the license。
Current information does not stipulate the same fixed number of people for all applicants。At a minimum, senior management oversight is required、CO and MLRO functions，and ensure the LMO has a sole proprietor、Partner、director、The ultimate owner and/or CO acts as customs liaison officer。CO and MLRO can be held concurrently by the same person if the size of the organization permits.，However, applicants must prove their qualifications、independence、time investment、Substitute and actual execution ability。
At least the detailed business model should be covered、Organizational structure、payment or settlement system、target customers、Staffing and financial arrangements。for ease of review，Service areas should also be listed、channel、Estimated number and amount of transactions、gradual flow of funds、bank account、Agents and partners、TOLL、outsourcing system、Accounting processing and abnormal transaction control，and make sure the content and form、contract、The website and system demo are consistent。
Core documents include Form 1 and Appendix、Supplementary information form、Form 3A or 3B、Principal and Equity Documents、Proof of identity of directors and ultimate owners、Business registration and annual return documents、Lease or proof of ownership of the premises、floor plan、interior and exterior photos、Owner and necessary occupiers agree、business plan、AML/CFT Policy、Proof of bank account and confirmation of bank purpose。Ultimately, the list of supporting documents and case supplementary requirements in the current customs form shall prevail.。
From May 15, 2026，The basic fee for first-time application is HKD3,810 yuan，HKD 2 per additional business premises,440 yuan，HK$945 per suitable candidate。The basic license renewal fee is HK$910，Plus HK$410 for each additional premises and HK$945 for each suitable person。Setup、Business registration、office、AML system、bank、Translation and professional services are extra，Not the MSO statutory application fee。
Hong Kong Customs and Excise Department’s current licensing guidelines do not promise to unify the number of days for approval。The time depends on whether the information is complete、Business and ownership structure complexity、patch response、Premises inspection、Fit and proper verification and competency assessment arrangements for other organizations。Application plans should set aside separate documents for preparation、regulatory review、Replacement and rectification time，Service provider estimates should not be written as customs commitments。
An established company cannot be、An application has been submitted or an interview has been arranged to be described as already licensed.，Nor should you operate a regulated money service before the license comes into effect。From April 1, 2023，Convicted for operating without a license through public prosecution procedures，The maximum penalty is a fine of HK$1 million and imprisonment for 2 years.。Website promotion、Customer signing、Boundary review should be completed and license status confirmed before collecting or arranging customer payments.。
The license is usually valid for two years，Form 2 must be submitted at least 45 days before expiry、Supplementary information、Statement of Fit and Properity、business plan、AML/CFT policy and supporting documents。Regular semi-annual transaction declarations must also be submitted on a daily basis.、Continue to maintain LMO and LPS、Keep records、training staff、Monitor transactions，and adding new directors、Partner、Obtain approval from the ultimate owner or premises；Changes to other registration information must be notified within one month。