Data updated to April 2026

Hong Kong MSO License (Money service operator)
Complete Application Guide

Based on Part 3 of the Anti-Money Laundering and Terrorist Financing Ordinance (AMLO, Cap. 615), this article provides a systematic interpretation of the application conditions, procedures, fees, and ongoing compliance requirements for Hong Kong MSO licenses and currency exchange and remittance service licenses.

~1,100

Number of licensed MSOs
As of December 2025

2

License validity period
Renewal required periodically

HK$3,310

New license application fee
Official Fee Standard

Homepage / Market Background

Market Background: Current Status of Hong Kong's Money Services Industry

As an international financial center and a core hub of the Greater Bay Area, Hong Kong has a huge demand for cross-border capital flows. Currency exchange and remittance services are the basic financial infrastructure supporting international trade, tourism consumption, and cross-border remittances.

~1,100

Number of companies holding valid MSO licenses in Hong Kong
As of December 2025

Approval rate decline

The number of applications has increased since 2023, but the approval rate has decreased significantly.

≥3 months

Estimated processing time for license application

2012

AMLO takes effect, MSO licensing system established.

Supervision Trend Analysis

Stricter approval standards

Customs officials are more cautious in reviewing applicants' qualifications, backgrounds, and operational capabilities, rigorously screening applicants to ensure that only companies with a high degree of compliance are approved. Common reasons for rejection include incomplete documentation, unclear business plans, and applicants whose backgrounds do not meet requirements.

Rising compliance costs

The costs of compliance consulting, internal control systems, and employee training continue to rise, putting significant pressure on small and medium-sized enterprises (SMEs). Customs requires MSOs to have comprehensive AML/CFT policies, IT systems, and internal control mechanisms.

Dual-track system formed

With the impending implementation of the VA Dealing licensing system, a complementary dual-track regulatory framework will be formed between MSO (fiat currency side) and VA Dealing (virtual asset side). Cross-border payment and crypto payment companies may need to hold both licenses simultaneously.

Global 1

International Standards Alignment

Hong Kong continues to align with FATF anti-money laundering standards, and the AML guidelines (June 2023 edition) have incorporated CDD requirements (HK$8,000 threshold) for virtual asset transfers.

AMLO Part 3: Any person who carries on the money service business in Hong Kong without a license issued by this Department commits an offence. On conviction on indictment, he is liable to a fine of HK$1,000,000 and imprisonment for 2 years.

— Section 29 of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)

Homepage / License Definition

License Definition: What is an MSO license?

6 license types × 6 business scopes — Find the license combination that best suits you

An MSO license (Money Service Operator Licence; also commonly referred to as money service operator license Hong Kong or Hong Kong money service operator license in English search contexts) is a statutory operating qualification issued by the Commissioner of Customs and Excise (CCE) of Hong Kong in accordance with Part 3 of the AMLO, authorizing the licensee to legally operate money exchange services and/or remittance services in Hong Kong.

Comparison of the two business types

Dimensions Currency exchange services Remittance Services
definition Exchanging one currency for another in the form of a business transaction Transferring money from one place to another for others in the form of a business
AMLO Terms and Conditions Article 1 Definition Article 1 Definition
Typical scenarios Foreign exchange shops, hotel exchange counters, airport exchange Cross-border remittances, labor remittances, trade settlement
License requirements Must hold an MSO license Must hold an MSO license

Key features

Regulatory Authority

The Hong Kong Customs and Inland Revenue Department (C&ED) is headed by the Commissioner of Customs and Excise (CCE).

Legal basis

AMLO (Cap. 615) Part 3

License validity period

The contract is for 2 years and renewal must be applied for at least 45 days before its expiry date.

License Type

A unified license can cover both currency exchange and remittance services.

Applicable Subjects

Anyone (individual, partnership, company) operating a money service business in Hong Kong.

Business premises

A physical office address must be established in Hong Kong for customs inspection.

important hint

An MSO license does not cover virtual asset trading, custody, or brokerage services. If the business involves the exchange of virtual assets for fiat currency, the fiat currency side requires an MSO license, while the virtual asset side requires a separate VA Dealing license regulated by the SFC. These two licenses are not interchangeable.

Homepage / Target Audience

Target audience: Who needs an MSO license?

The following business scenarios require an MSO license to operate legally in Hong Kong.

Foreign exchange shop

Operating a physical store in Hong Kong, providing customers with currency exchange services.

horizontal1

Cross-border remittance service provider

We provide services for clients to transfer funds from Hong Kong to overseas or from overseas to Hong Kong.

Fintech remittance platform

Technology companies that provide remittance services through online platforms or apps.

Global 1

Cross-border payment company (fiat currency side)

Processing cross-border payments and settlements in fiat currencies. If virtual assets are also involved, a VA Dealing license is required.

Global 1

Trade settlement service provider

Provide currency exchange and cross-border fund transfer services for import and export trade.

Global 1

Labor remittance agent

Provide services for foreign workers to remit their wages back to their home countries.

Exempt Entity List

Exempt Entity Categories Legal basis Condition
government agencies AMLO Article 24 Unconditional exemption
Recognized institutions (banks) AMLO Article 24 Unconditional exemption
SFC Licensed Corporation AMLO Article 24 Money services only attached to its licensed business
Approved insurance companies AMLO Article 24 Money services only attached to its insurance business
Recognized Insurance Broker AMLO Article 24 Money services only attached to its brokerage business
Appoint insurance agent AMLO Article 24 Money services only attached to its agency business
SVF licensee AMLO Article 24 Money services only included with its SVF business
Designated retail payment system operators/settlement institutions AMLO Article 24 Money services are limited to those included with its designated business.
Hotel-related currency exchange / Industry practice

Currency exchange services offered to guests by hotels typically do not require an MSO license if they are merely ancillary services to the hotel's business and not its main business. However, if a hotel operates currency exchange as an independent business, it must apply for a license.

Homepage / Business Scope

Scope of business: Activities permitted by the MSO license

MSO licenses cover two main categories of business: currency exchange and remittance.

Item Explain
Core Definition Operating as a business, exchanging one currency for another.
Client Individual customers, corporate customers
Currency range All fiat currencies, excluding virtual assets.
Business Model Physical stores and online platforms (must have a physical office address)
Pricing requirements Exchange rates must be displayed in a prominent location at the business premises.
Item Explain
Core Definition Operating as a business, transferring money from one place to another for others.
Client Individual customers, corporate customers
Funding Scope Fiat currency, excluding virtual assets
Business Model Physical outlets and online platforms
Compliance requirements Cross-border remittance CDD and record keeping requirements must be met.

Activities explicitly prohibited

Virtual asset trading

You may not buy, sell, broker, or exchange virtual assets (including cryptocurrencies and stablecoins).

Virtual asset custody

You must not hold the private keys to virtual assets for your clients.

Securities/Futures Trading

Prohibited from engaging in securities or futures trading regulated by the SFC

Accepting deposits

It is prohibited to accept public deposits in the form of a bank.

Homepage / Application Requirements

Application Requirements: 6 Core Requirements

To apply for an MSO license, you must meet the requirements of the following six categories.

The applicant must be one of the following:

  • A limited company incorporated in Hong Kong
  • An unlimited liability company registered in Hong Kong
  • Overseas branch offices registered with the Hong Kong Companies Registry
  • Partnerships operating in Hong Kong
  • Individual (operating under an individual's name)

Both Hong Kong residents and non-residents are eligible to apply. Shareholders can be individuals or companies. A valid business registration certificate is required.

All directors, ultimate beneficial owners, and partners must pass a suitability test, with evaluation criteria including:

  • No criminal record (especially related to money laundering or fraud).
  • No bankruptcy record
  • Possess relevant industry experience and knowledge
  • Good business reputation

Applicants must have a physical place of business in Hong Kong:

  • A fixed physical office address is required (not a virtual office).
  • Must meet security and preservation requirements
  • The MSO license must be displayed in a prominent position.
  • Must be subject to irregular customs inspections

The following documents must be submitted:

  • Business plan (detailing business model, target customers, and expected transaction volume)
  • AML/CFT Policy and Procedure Documents
  • Company registration documents and business registration certificate
  • Identification documents of directors and shareholders
  • Bank account certificate

The following key personnel must be appointed:

  • Compliance Officer — Responsible for overseeing AML/CFT compliance
  • Chief Money Laundering Reporter (MLRO) – Responsible for assessing and submitting reports of suspicious transactions.
  • Key personnel must possess sufficient AML/CFT knowledge and experience.

Applicants must pass a customs interview and competency assessment:

  • Face-to-face interviews—to verify the authenticity of materials and assess the feasibility of the business plan.
  • Competency assessment – ​​to be completed within 30 days of the interview, using a Beta version of the sample business system.
  • Showcase the complete service process and compliance mechanism

With the approval rate for MSO license applications continuing to decline, professional guidance is crucial.

From business plan writing to AML policy development, from interview coaching to competency assessment preparation, Aiying provides you with end-to-end compliance support.

Book a free consultation View global licensing schemes

Homepage / Application Process

Application process: 5 steps from preparation to approval

Understand the complete process of applying for an MSO license and the estimated time for each stage.

Demand analysis and consulting

Preparing and submitting an application

Estimated time: 2-4 weeks (document preparation)
  • Prepare all application documents (business plan, AML policy, company documents, etc.).
  • Applications can be submitted through the Customs Online System (MSOS) or in person.
  • The application fee is HK$3,310 (an additional HK$2,220 for each additional business premises).
  • Each person required to pass the appropriate candidate test shall pay an additional HK$860.
Signing Mou and launching an investigation

Customs Preliminary Inspection

Estimated time: 2-4 weeks
  • Customs reviews the completeness of application documents
  • Send interview notice and payment notice
  • Invite for competency assessment
  • If the documents are incomplete, customs will request supplementary documents.
Complete the investigation and sign the Spa

Interview

Estimated time: 1-2 weeks (interviews to be arranged)
  • The applicant (or their representative) must attend the face-to-face interview in person.
  • Customs verifies the authenticity of the materials and examines the feasibility of the business plan.
  • Assess the management team's professionalism and understanding of regulatory requirements.
Complete the investigation and sign the Spa

Capacity Assessment

Estimated time: 1-4 weeks
  • It must be completed within 30 days after the interview.
  • Beta version of the demonstration business system
  • Showcase the complete service process and compliance mechanism
  • Stability and compliance of the customs assessment system
Complete the investigation and sign the Spa

License decision

Estimated time: Total estimated time: at least 3 months
  • Customs will make a decision after comprehensive assessment.
  • Approval: Issuance of MSO license, valid for 2 years.
  • Rejection: The applicant may appeal to the Anti-Money Laundering and Counter-Terrorism Financing Tribunal within 21 days.

Estimated total duration

From preparation to approval

At least 3 months

It is recommended to allow 4-6 months.

Renewal reminder
Confirmed

An MSO licence is valid for two years. The licensee must submit a renewal application to Customs at least 45 days before expiry. The renewal fee is HK$790 for one type of service or HK$1,095 for both services. From 15 May 2026, the renewal fee will be adjusted to HK$910 for one service or HK$1,260 for both services.

Homepage / Fee Details

Fee Breakdown: Official Fees and Hidden Costs

Understand the official fees and hidden costs of applying for and maintaining an MSO license.

09 Warning
Fees will be adjusted soon.

Under the 2026 amendment to Schedule 3 of the AMLO,MSO licence fees will change from 15 May 2026.This is the first adjustment since 1 April 2012,with increases of 10% to 15%.

Official Fee Schedule

Fee Items Current fees (HK$) Adjusted fees (effective May 15, 2026) Applicable scenarios
New license application fee 3,310 3,810 First application for MSO license
Each additional business premises (new application) 2,220 2,440 Each additional business location when applying for a new application
Test fee for suitable candidates (per person) 860 945 Each director/shareholder/partner who must pass the test
Renewal application fee 790 910 Renew every 2 years
Each additional business premises (renewal) 355 410 Each additional operating location upon renewal
Applying to become a licensed director/ultimate owner/partner 860 (per person) 945 (per person) New key personnel added during the license's validity period
New business premises 2,220 (per location) 2,440 (per location) New business locations during the license's validity period
Operating in a specific location 2,220 (per location) 2,440 (per location) Applying to operate at a specific location

Implicit cost estimation

Registered capital
Industry Practice

HK$500,000

Substantial registered capital

Compliance advisory fees
Industry Practice

HK$50,000-200,000

Assistance with application documents and AML policies

Office rental
Confirmed

Depending on the location

A physical office address is required.

IT system development
Industry Practice

HK$30,000-100,000

Transaction monitoring and record keeping system

Audit Fees
Industry Practice

HK$10,000-30,000/year

Annual audit and compliance review

staff training
Confirmed

HK$15,000-40,000/year

AML/CFT Training and Continuing Education

Cross-license fee comparison

Dimensions MSO VA Dealing VA Custody VHTP
Regulatory Authority Customs and Excise Department (C&ED) SFC SFC SFC
Application fee HK$3,310 HK$4,740 (refer to Type 1) ≥HK$129,730 (refer to Type 3) HK$14,220 (three sets combined)
annual fee None (2-year renewal HK$790) HK$4,740/year ≥HK$129,730/year HK$14,220/year
Minimum capital HK$500,000 (Industry Practice) HK$5,000,000 HK$10,000,000 HK$5,000,000
Valid period 2 To be determined To be determined Continued effectiveness

Homepage / Continuous Compliance

Continuous Compliance: Legal Obligations and Penalties of MSOs

After obtaining an MSO license, the licensee must continue to comply with the following legal obligations.

obligation Detailed requirements Legal basis
Customer due diligence (CDD) Wire transfers ≥ HK$8,000 require CDD; other transactions ≥ HK$120,000 require CDD; cash transactions ≥ HK$120,000 require CDD. AMLO Schedule 2
Continuous monitoring Continuously monitor business relationships and identify suspicious transactions. AMLO Schedule 2
Suspicious Transaction Report (STR) Any suspicious transactions must be reported to the Joint Financial Intelligence Unit (JFIU). AMLO Article 25A
record keeping All CDD information and transaction records must be retained for at least 5 years (after the business relationship ends). AMLO Schedule 2 Article 20
staff training Regularly conduct AML/CFT training for employees AML Guidelines Chapter 9
risk assessment Using a risk-based approach (RBA), ML/TF risks are assessed periodically. AML Guidelines Chapter 2
Reporting Obligation Details the term
Quarterly Report Submit a business report to customs every quarter. Within two weeks after the end of each quarter
Change Notice Customs must be notified of any changes to the business address, directors, shareholders, partners, bank accounts, etc. Within one month after the change
Licence display The original license must be displayed in a prominent position at each business premises. Continuing obligations
Annual Audit Complete financial records must be kept for auditing. Continuing obligations

Activities explicitly prohibited

Chief Compliance Officer (CO)

Must possess sufficient AML/CFT knowledge and experience, and be responsible for overseeing compliance.

Chief Compliance Officer (CO)

Must possess sufficient AML/CFT knowledge and experience, and be responsible for overseeing compliance.

director

Appropriate candidates must be tested and ultimately held responsible for the company's compliance.

Irregularities Punishment Legal basis
Operating money services without a license Public prosecution: HK$1,000,000 fine + 2 years imprisonment; Summary proceedings: HK$100,000 fine + 6 months imprisonment AMLO Article 29
False statements/providing false information A fine of HK$50,000 plus 6 months imprisonment AMLO Article 52(2)
Violation of compliance requirements A fine of HK$50,000 plus 6 months imprisonment AMLO Articles 35-41
Disciplinary action (powers of the Director-General of Customs) Public reprimand, order to rectify the violation, and fine not exceeding HK$1,000,000 AMLO Article 43
Institutional AML violations The fine shall not exceed HK$10,000,000 or three times the illegal profits (whichever is higher). AMLO Article 5

Customs continues to strengthen MSO regulatory enforcement. In 2025, Customs detected 23 unlicensed money service cases and arrested 24 people; 22 cases involved social media platforms. From 2023 to March 2026, Customs published around 10 disciplinary cases.Common violations include:

Common violations
09 Warning

Failure to notify customs of changes to the bank account within the stipulated time (violation of Section 40)

09 Warning

Operating money services without a license through social media platforms

09 Warning

Insufficient AML/CFT compliance

09 Warning

Improper storage of records

09 Warning

Failure to display the licence as required

Enforcement Documents — January 13, 2026
Confirmed

Customs published its 2025 enforcement results:23 unlicensed operation cases were detected, 22 involving social media platforms, and 24 people were arrested.In four cases, bank accounts were linked to money laundering; one account holder was sentenced to 54 months imprisonment.

Judgment Hammer
Disciplinary Action Case – March 23, 2026
Confirmed

Customs published its 2025 enforcement results:23 unlicensed operation cases were detected, 22 involving social media platforms, and 24 people were arrested.In four cases, bank accounts were linked to money laundering; one account holder was sentenced to 54 months imprisonment.

horizontal1

Appeals Mechanism

Confirmed

Appellate Body: Review Tribunal (Money Laundering and Counter-Terrorist Financing)

Note: The appellate body is the "Review Tribunal for Money Laundering and Counter-Terrorism Financing", not the "Administrative Appeals Board".

Legal basis: AMLO Part 3 Division 5

Appeal period: within 21 days of receiving the decision notification

Homepage / MSO and VA Licenses

A Dual-Track System Explained: The Complementary Relationship Between MSO and Virtual Asset Licenses

Understanding the Licensing Portfolio Strategy under Hong Kong's Dual-Track Financial Services Licensing System

Five license combination strategies

Demand analysis and consulting

Pure fiat currency services

Currency exchange and/or remittance services are provided only.

MSO

Apply for an MSO license

Signing Mou and launching an investigation

Crypto payments (fiat currency + VA)

Provides fiat-to-cryptocurrency exchange and payment services.

MSO + VA Dealing

Applying for a VA Dealing License

Complete the investigation and sign the Spa

End-to-end encryption service

Provides end-to-end services for exchanges, OTC markets, and payments.

MSO + VATP + VA Dealing

Apply for VATP license

Regulatory applications and approvals

Custody + Payment

Provides VA custody and fiat currency settlement services

MSO + VA Custody

Apply for a VA Custody license

Complete delivery

Pure VA service

Only VA-VA transactions are offered; fiat currency is not involved.

VA Dealing (No MSO Required)

Applying for a VA Dealing License

Key differences comparison

Dimensions MSO License VA Dealing License
Regulatory Authority Hong Kong Customs and Excise Department (C&ED) Securities and Futures Commission (SFC)
Legal basis AMLO Part 3 The proposed amendments to the AMLO (expected to be submitted to the Legislative Council in the summer of 2026)
Business Scope Fiat currency exchange + remittance Virtual asset trading, brokerage, OTC
Asset types Only fiat currency Virtual assets (including stablecoins)
Minimum capital HK$500,000 (Industry Practice) HK$5,000,000
Valid period 2 To be determined
AML Standard Customs AML Guidelines SFC AML Guidelines
Interview Requirements Yes (Customs interview + competency assessment) To be confirmed
Compliance red lines
Confirmed

MSO licenses are prohibited from engaging in virtual asset trading activities. If an MSO licensee provides cryptocurrency exchange services under the MSO business structure, it will be considered as operating a VA Dealing business without a license, and will face a maximum fine of HK$5,000,000 and imprisonment for up to 7 years.

Homepage / Licensed Institutions

List of MSO Licensed Organizations

Search for information on MSO license holders issued by Hong Kong Customs and Excise Department.

Official Inquiry System

Hong Kong Customs provides an online MSO (Money Services Operator) licensee lookup system, which allows users to search by company name, license number, or type of service. It is recommended to verify the license status of any money service provider through the official system before cooperating with them.

Access to Customs Inquiry System

Source: Hong Kong Customs Money Services Supervision Division

How to check licensed organizations

  1. Access to the Customs MSO Licensee Inquiry System
  2. Search by company name, license number, or type of service.
  3. The system displays the license holder's license status, service type, and business address.
  4. It is recommended to verify the licensing status of any money service provider before cooperating with them.

~ 1,100

Total number of licensed companies (estimated)

Data updated to May 2025

Currency exchange services
About 800+
Remittance service
About 400+
Two services
About 200+

Examples of well-known licensed institutions

Organization name Service type status
Centennial Exchange Co., Ltd. Currency exchange, remittance effective
Western Union (Hong Kong) money transfer effective
MoneyGram (Hong Kong) money transfer effective
Tongjilong Foreign Currency Exchange currency exchange effective

Note: Licence numbers are subject to the official customs system; only examples of well-known institutions are shown here.

The above data are estimates; actual figures are subject to the official customs inquiry system. Some licensees hold two service licenses simultaneously. Please refer to the official customs inquiry system for a complete list of licensed organizations.

Homepage / Cross-jurisdictional

Alternative: Money service licenses in other jurisdictions

A comparison of money services licensing regimes in major global jurisdictions, including Hong Kong, Singapore, the United States, the United Kingdom, Dubai, and Australia.

Dimensions Hong Kong MSO Singapore MPI/CMS US MSB EMI/PI (UK) Dubai VARA AUSTRAC Australia
regulatory agency Customs and Excise Department (C&ED) MAS FinCEN + States FCA STICK AUSTRAC
Business scope Currency exchange + remittance Payment services + digital payment tokens Money services Electronic money + payment VA Brokerage + Trading Remittance + Digital Currency Exchange
Covering VA no Yes (DPT license) (Varies by state) section Be Yes (DCE registration)
Minimum capital HK$500,000 SGD 100,000 - 250,000 No federal requirements EUR 350,000 - 1,000,000 Depending on the category No minimum requirement
Application period ≥3 months 6-12 months 1-3 months (Federal) 6-12 months 3-6 months 3-6 months
Valid period 2 Continuously effective Valid indefinitely (registration required) Continuously effective Continuously effective Valid indefinitely (registration required)
Advantage Low cost, Greater Bay Area advantages Covers VA, with high international recognition Low barriers to entry and a large market EU passport VA friendly VA-friendly, Asia-Pacific radiation
Inferiority VA not covered Slow approval process and high capital requirements Compliance is complex in each state. Post-Brexit restrictions The market is relatively new AML compliance requirements are strict.

Select suggestions

Demand analysis and consulting

If the business only involves currency exchange and remittance

→ Hong Kong MSO

View MSO license application details

Signing Mou and launching an investigation

If the business involves encrypted payments and is primarily in the Asia-Pacific region

→ Hong Kong MSO + VA Dealing or Singapore MPI

View VA Dealing license application details

Complete the investigation and sign the Spa

If the business is oriented towards the European market

→ UK EMI/PI or EU MiCA

View details of UK EMI license application

Regulatory applications and approvals

If the business is oriented towards the US market

→ US MSB + State Licenses

View details of US MSB license application

Complete delivery

If the business is primarily VA and targets the Middle East

→ Dubai VARA

View Dubai VARA license application details

Obtain regulatory approval and pay the final payment

If the business targets the Asia-Pacific market and involves digital currency exchange

→ AUSTRAC Registration in Australia

View details of AUSTRAC registration in Australia

Need more information on global financial license application options?

Visit Aiying Global License Application Center

Homepage / FAQ

FAQS

Most frequently asked questions about MSO license applications

An MSO license, issued by Hong Kong Customs and Excise Department, only permits the operation of exchange and remittance services between fiat currencies. A VA Dealing license, regulated by the SFC, allows the buying, selling, brokerage, and OTC trading of virtual assets. The two licenses are not interchangeable. If an MSO licensee provides cryptocurrency exchange services under the MSO business structure, it will be considered operating a VA Dealing business without a license.

An MSO licence is valid for two years.The licensee must submit a renewal application to Customs at least 45 days before expiry.The renewal fee is HK$790 for one service or HK$1,095 for both services. From 15 May 2026, it will be adjusted to HK$910 for one service or HK$1,260 for both services.

According to official customs guidelines, the processing time for applications is at least 3 months. In practice, due to stricter approval standards and increased application volume, it is recommended to allow 4-6 months. The preparation stage (company registration, document preparation, etc.) usually requires an additional 1-2 months.

Yes. Both Hong Kong residents and non-residents can apply for an MSO license. Foreign companies can apply by registering a branch or subsidiary in Hong Kong. However, they must have a physical office address in Hong Kong, and key personnel must pass a suitable candidate test.

AMLO does not explicitly stipulate a minimum registered capital requirement for MSOs. However, in industry practice, customs usually expects applicants to have registered capital of no less than HK$500,000 to demonstrate that they have sufficient financial strength to operate a money services business.

Yes. According to AMLO Part 3 Division 5, the applicant may appeal to the Review Tribunal within 21 days of receiving the notice of refusal. The Tribunal will independently review the Customs decision.

No. An MSO license only permits the operation of exchange and remittance services between fiat currencies. To operate a virtual asset-related business, a separate VA Dealing license is required. Using an MSO license to engage in cryptocurrency exchange will be considered unlicensed operation, punishable by a maximum fine of HK$5,000,000 and 7 years imprisonment.

Generally, it is not required. According to customs practice guidelines, the currency exchange services provided by hotels to guests are usually exempt, provided that: (1) they are for guests only; (2) they are not part of the hotel's main business; and (3) the amount and currency exchanged are limited. However, if the hotel's currency exchange service is large-scale or open to the public, it may need to apply for an MSO license.

This mainly includes: (1) Suspicious Transaction Report (STR) – to be reported to JFIU immediately upon discovery; (2) Large Cash Transaction Records – transactions of HK$120,000 or more must be recorded internally; (3) License Renewal Application – every 2 years; (4) Business Change Notification – any significant changes must be promptly notified to Customs. In addition, Customs may conduct compliance checks from time to time.

Under Section 29 of the AMLO, anyone who operates a money service without a license in Hong Kong is liable on indictment to a fine of HK$1,000,000 and imprisonment for two years. Furthermore, if money laundering or terrorist financing is involved, more severe criminal penalties may be imposed.

About Aiying

Aiying (License.aiying.cc) specializes in global traditional finance and Web3-related license application and acquisition consulting services. With teams primarily located in Hong Kong, the UAE, and Europe, and strong relationships with local regulators, Aiying has successfully secured applications and smooth operations for leading and mid-tier crypto and traditional institutions. Team members are qualified in Hong Kong, Europe (Ireland), the UK, the UAE, and other jurisdictions, with a global network ensuring 24/7 professional support. Headquartered in Asia, the team brings together experts in operations, marketing, law, regulatory compliance, and accounting, adhering to clients' business objectives to provide comprehensive and in-depth strategies and solutions.
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Pre-inspection mechanism

Aiying's "pre-screening mechanism"

To maximize your success rate, Aiying conducts an internal mock review of your application materials before formal submission. Our expert team acts as a regulator, scrutinizing each document from the most rigorous perspective to identify logical loopholes, data inconsistencies, and compliance gaps in advance.

This mechanism allows us to ensure that the materials submitted to regulators are highly professional, complete, and impeccable, thereby minimizing regulatory inquiry rounds, significantly shortening approval times, and reducing the license rejection rate by 67%.