Regulatory Guide · Hong Kong
This page is based on Hong Kong Customs and Excise Department and Chapter 615，Organize the applicable businesses of MSO license、Application subject、fit and proper person、营业处所、business plan、Statutory charges、Anti-money laundering and license renewal requirements。
Guide overview
This guide only discusses the Money Service Operator License under Chapter 615 of the Laws of Hong Kong。Setup、Business registration or opening of a bank account does not in itself equate to permission to operate money services；Other payments、bank、Securities or virtual asset businesses may also be subject to different regulatory regimes。
Some exchange arrangements incidental to the main business or situations specified in the law may not be classified as money services.，Must be combined with actual capital flow、Judgment of service objects and business methods。Not having a specific business premises does not mean that there is no need for local arrangements in Hong Kong，Applicants must still provide a local management office、Correspondence address and local place where accounts and records are kept。
Current official information from Hong Kong Customs does not list a unified minimum paid-in capital or minimum liquidity threshold that applies to all MSO applicants.，Therefore, the internal budget should not be、Bank requirements or market practices are written into statutory capital requirements。
core requirements
Providing remittance services on a business basis in Hong Kong、Currency exchange services or both，Must obtain an MSO license from the Commissioner of Customs before commencing operations。Operating without a license is a criminal offense；Whether it falls within the regulatory scope should be judged based on actual services and capital flow.。
Individual applicants and ultimate owners、合伙的每名合伙人及最终拥有人、Every director and ultimate owner of the corporation is within the scope of the review。Customs will comprehensively consider relevant convictions、Non-compliance records、Bankruptcy、liquidation、Factors such as integrity and reliability，and assessed on a case-by-case basis。
When operating from specific premises，The premises must be suitable for carrying out money services；Where residential or mixed-use premises are involved, there are also requirements such as consent to enter。Models without specific business premises must still report to the local management office、Correspondence address and local place where accounts and records are kept。
New applications must describe business model、Organizational structure、Payment process、Customers and geographical distribution、Personnel arrangement、Funding sources and actual resources，and submit anti-money laundering and counter-terrorism financing policies commensurate with its business risks、Procedures and controls。
As of September 2, 2026，The initial application fee is HK$3,810；An additional HK$2,440 will be charged for each additional business premises；An additional HK$945 is charged for each person requiring a fit and proper determination.。The license renewal fee is HK$910，An additional HK$410 will be charged for each additional business premises，An additional fee of HK$945 will be charged for each suitable candidate。Schedule 3 should be checked again before submission。
Licensees are required to identify and verify customers、Beneficial owners and persons acting on behalf of clients，Understand the purpose of the business relationship，and take appropriate measures based on risks。Transaction records are generally kept for at least 5 years from the completion of the transaction；Customer information will be kept for at least 5 years during the duration of the business relationship and after termination.。
A first-time license is generally valid for 2 years from the date of approval.，However, the Commissioner may specify other periods on a case-by-case basis。Application for license renewal must be submitted at least 45 days before expiration；At the same time, directors who need prior approval or must report within the prescribed time limit should be continuously tracked.、ultimate owner、Changes in premises and other information。
Implementation path
Sorting out payment paths、Service objects、Transaction scenarios and revenue models，Determine whether to operate remittance business、Currency exchange or both，and identify any exclusions or exemptions that may apply。
Main output：Determination of regulated activitiesVerify and confirm official basis for actual business activitiesCreate an equity and control diagram，Identify the applicant、director、Partners and ultimate owners，and check the fit and proper person declaration and supporting documents in advance.。
Main output：Organizational and Ownership Chart、List of suitable candidatesCheck and determine the official basis of the applicant and examinerDeciding whether to use a specific business premises or no specific premises model，Prepare proof of address、occupancy or use arrangements、Required consent、venue photos，and local management and recordkeeping location information.。
Main output：Venue and local management records arrangement packageVerify and implement the official basis for business location arrangementsDescribe the business model、Organization and management location、Customers and regions、payment system、transaction process、Staffing、Source of funds、Estimated business volume and compliance resources，Ensure content is consistent with actual operations。
Main output：MSO business planVerify the official basis for preparing an executable business planAccording to product、channel、Complete institutional risk assessment for client and geographic risks，Develop customer due diligence、Continuous monitoring、record keeping、Suspicious transaction processing、Personnel training and internal control procedures。
Main output：Institutional Risk Assessment and AML/CFT PolicyCheck the official basis for establishing a risk-based anti-money laundering systemComplete the applicable application form、Supplementary information and attachments，Submit a supporting business plan、Anti-Money Laundering Policy、Fit and proper documents、Site information and other certifications，And pay according to the current fee schedule。
Main output：Complete application package and submission recordCheck, organize and submit complete application official basisSubmit additional information as required by customs、attend the meeting、Cooperate with premises inspections and related assessments；After obtaining the license, continue to follow up on customer due diligence、record keeping、Data changes、Prior approval matters and license renewal deadlines。
Main output：Inquiry response record and ongoing compliance calendarCheck and cooperate with the review and establish the official basis for the post-licensing calendarofficial source
Institutional evolution
Hong Kong Customs and Excise Department becomes the relevant authority for money service operators under Chapter 615，MSO licensing and supervision system begins to be implemented。
View the official source of Hong Kong Customs starting to supervise MSOsCustoms releases guidelines on current fit and proper criteria，Describe the good faith considerations in addition to statutory factors that will be considered on a case-by-case basis、Compliance and Financial Condition Matters。
View the official source of fit and proper guidance updatesHong Kong Customs MSO supervision page issuance of licenses in accordance with the revised regulations、Customer due diligence、Recordkeeping and Unlicensed Operation Enforcement Responsibilities。
View official sources for the implementation of the revised Anti-Money Laundering RegulationsCustoms updates anti-money laundering and counter-terrorism financing guidelines applicable to money service operators，Emphasis on designing policies based on business risks、Procedures and controls。
View the official source of the current version of the MSO Anti-Money Laundering GuidelinesCustoms releases updated licensing guidelines，Integrated application、premises、fit and proper person、Renew license、Ongoing liability and current charge information。
View the official source of MSO licensing guidance updatesThis page is used for data collection and work judgment.，Does not constitute legal advice。Specific requirements should be determined by applicable legislation、The latest rules and case conditions of the regulatory agency shall prevail.。
Check business facts and official basis first，Arrange materials again、Institutional and ongoing compliance efforts。
