The Hong Kong Monetary Authority (HKMA) announced on 22 July 2025 that it had reprimanded 33 Financial Services Limited (33FS) and ordered it to pay a pecuniary penalty of HK$1.6 million for contravening section 8Q of the Payment Systems and Stored Value Facilities Ordinance (PSSVFO), after the stored value facility licensee failed to fulfil a minimum licensing criterion under the ordinance.
The action followed an HKMA investigation which found that, between 1 December 2019 and 31 August 2023, 33FS failed to have adequate and appropriate systems of control to comply with the HKMA's Guideline on Anti-Money Laundering and Counter-Financing of Terrorism for stored value facility licensees.
AML CONTROLS AT A STORED VALUE FACILITY
The deficiencies covered three areas: obtaining sufficient information on the purpose and intended nature of business relationships with customers; carrying out customer due diligence on the business entities on whose behalf individual customers acted; and ensuring that business partners acting as outsourced entities for 33FS properly performed and documented the identification and verification of customers in line with its internal requirements.
In deciding the penalty, the HKMA took into account the seriousness of the findings and the fact that 33FS has a previous disciplinary record under the PSSVFO, the need to send a clear deterrent message to the industry, the remedial measures 33FS has taken to strengthen its controls, and its cooperation in resolving the regulator's concerns.
Raymond Chan, Executive Director (Enforcement and AML) at the HKMA, said: “CDD measures are crucial for combatting ML and TF risks. Verifying the identity of customers and understanding the purpose and intended nature of the business relationships are essential elements of CDD measures. SVF licensees should ensure that they have effective CDD measures in place.” On the same day, the HKMA separately announced penalties totalling HK$16.2 million on three banks for anti-money laundering control failures.