COMPLIANCE GUIDES · AML/CFT

AMLO Schedule 2 Essentials:
What CDD Is, When It's Due, How Long Records Keep

Schedule 2 of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap.615) is the AML core every licensed corporation touches daily — how CDD is done, who needs enhanced scrutiny, and how long records must be kept.

Updated: 2026-10-16 Reading time: ~10 min Sources: AMLO Cap.615, SFC AML Guideline, JFIU
Home / Compliance Guides / AMLO Schedule 2
Who must comply: AMLO brings licensed corporations inside "financial institution" — brokers, asset managers and advisers all carry Schedule 2 duties. The SFC's AML/CFT Guideline for Licensed Corporations is the operative rulebook; inspections and enforcement measure you against it.

1. The five CDD measures (Schedule 2, s.2)

Customer Due Diligence is more than "collect an ID" — Schedule 2 lists five things to identify and verify:

  1. The customer's identity — reliable independent source documents (ID card, passport, corporate registration papers)
  2. The beneficial owner — for legal entities, trace through layers to the natural person(s) ultimately in control (generally ≥25% ownership or actual control)
  3. Persons purporting to act (PPTA) — e.g. authorised persons placing orders for the client
  4. Connected parties — directors of corporate customers, etc.
  5. Purpose and intended nature of the relationship — not a formality: genuinely knowing why the account exists (long-term investing? day trading? acting for others?)
Where firms slip: measure 5 gets the least real attention — a ticked "investment" checkbox satisfies nobody. Inspectors sample files and ask "how do you know the client's stated purpose matches their transaction pattern?" No answer = a finding.

2. When CDD is triggered (s.3)

Onboarding

Before establishing any business relationship — "open now, documents later" is a red line

Occasional txn

Before single or linked transactions of HK$120,000 or more

Suspicion

Any suspicion of money laundering or terrorist financing, regardless of amount

Doubt

When previously obtained identity information turns out inconsistent or stale

Wire transfers: transfers of HK$8,000 or more must carry originator information — Hong Kong's implementation of FATF Recommendation 16, the "travel rule".

3. SDD vs EDD — the two ends

SDD — SimplifiedEDD — Enhanced
WhenSpecified lower-risk situations (e.g. certain regulated financial institutions as customers, designated products)Higher risk: foreign PEPs, FATF-called high-risk jurisdictions, complex or unusually large transactions, high-risk non-face-to-face onboarding
WhatSome verification steps may be waived — but the customer must still be identifiedExtra documents/verification, source of wealth and source of funds, senior management approval, enhanced ongoing monitoring
Red lineAny ML suspicion kills SDD instantly. "The client is a listed company, so we went light" is an enforcement repeat offender.

4. PEP tiers — not all treated alike

5. Ongoing monitoring + record-keeping

6. Suspicious transaction reports (STR)

Spot something suspicious — file an STR to the Joint Financial Intelligence Unit (JFIU) via the STREAMS system. The duty comes from the Organized and Serious Crimes Ordinance (Cap.455), the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap.405) and the United Nations (Anti-Terrorism Measures) Ordinance (Cap.575) — failing to report is itself a criminal offence, with imprisonment on conviction.

Never tip off: disclosing the STR to the client or uninvolved colleagues after filing is a separate offence. Beyond your compliance officer and MLRO, don't discuss who was reported.

7. Official sources

DocumentLink
Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap.615), incl. Schedule 2elegislation.gov.hk ↗
SFC AML/CFT pages (guideline, circulars, FATF list updates)sfc.hk ↗
Joint Financial Intelligence Unit (JFIU) — STREAMS reportingjfiu.gov.hk ↗
FATF standards and high-risk jurisdiction listsfatf-gafi.org ↗

8. FAQ

Small firm, no budget for a dedicated MLRO?

The law requires a designated officer for AML reporting — small firms typically have an RO or compliance head double-hat the role, but the responsibility must be documented with real authority. "Too small to do it" is not a defence.

Do stale CDD documents need refreshing?

Ongoing monitoring requires data kept current — high-risk clients get periodic reviews; low-risk can run longer cycles, but trigger events (address change, pattern shift) force an immediate update.

How does eKYC / remote onboarding fit CDD?

Schedule 2 doesn't ban non-face-to-face onboarding, but it must use an approach acceptable under Code of Conduct paragraph 5.1 plus the extra safeguards — see the Remote Account Opening guide.

Can we keep trading for a client after filing an STR?

Yes — the law doesn't force termination — but on a risk-assessed basis. Continuing to process suspicious funds without reasonable explanation can itself be a money-laundering offence. Document the decision; when unsure, ask counsel.

Would your CDD file survive an inspection? Ask RegSir.

Describe your onboarding flow or scenario — RegSir cross-checks Schedule 2 and the SFC AML Guideline line by line.

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