Hong Kong HKICPA Auditor and AML/CFT Specialist for MSO Licence Applicant

We are a newly incorporated Hong Kong limited company in the process of obtaining a Money Service Operator (MSO) licence from the Customs and Excise Department (C&ED). The company will operate remittance and/or currency exchange services. The MSO licence application is in progress; the business has not yet commenced operations and has no material transaction history to date. We require a single provider — or a practice that can coordinate both functions — to cover two distinct but complementary engagements: • Part A — Statutory Financial Audit under the Companies Ordinance (Cap. 622) and the Inland Revenue Ordinance for the company’s first financial year. • Part B — AML/CFT Compliance Framework Review against C&ED’s AML/CFT Guideline for MSOs (June 2023), Schedule 2 of the AMLO (Cap. 615), and FATF standards for money or value transfer services — assessed at the framework design level, since the company is pre-operational. We prefer a single party for continuity and cost efficiency, but will consider a lead firm that sub-contracts the AML component to a named and qualified specialist — provided both deliverables are coordinated under one engagement agreement. Part A — Statutory Financial Audit Scope • Audit of the company’s financial statements for its first financial year in accordance with Hong Kong Standards on Auditing (HKSAs) and Hong Kong Financial Reporting Standards (HKFRSs) • Issuance of a signed auditor’s report expressing an opinion on whether the financial statements give a true and fair view • Preparation or review of financial statements for filing with the Companies Registry and submission to the Inland Revenue Department alongside the Profits Tax Return Context The company is pre-operational. The first financial year will contain only incorporation costs, bank account setup fees, professional fees, and minimal administrative expenditure. There are no revenues, no customers, and no money service transactions. The audit should therefore be straightforward in scope, with low fieldwork complexity. Hard Requirement The statutory audit must be conducted and the auditor’s report signed by a Certified Public Accountant (Practising) holding a valid practising certificate issued by HKICPA, as regulated by the AFRC. Please confirm your HKICPA CPA (Practising) registration number and firm name in your proposal. Proposals that do not confirm this credential will not be reviewed for Part A. Part B — AML/CFT Compliance Framework Review Scope • Independent review of the AML/CFT Policy document against C&ED’s AML Guideline requirements (Chapters 2–9, June 2023 version) • Assessment of the ML/TF risk assessment framework for adequacy and risk-based approach (RBA) alignment • Review of CDD/EDD procedures for individual and legal person customers • Evaluation of the proposed transaction monitoring design, including threshold logic (HKD 8,000 for wire transfers; HKD 120,000 for occasional transactions) and STR escalation pathway • Assessment of the sanctions screening methodology and proposed IT/screening tool • Review of compliance management structure: CO and MLRO appointment, reporting lines, and independence from operational functions • Delivery of a written gap analysis report (3–8 pages) with findings and remediation recommendations Assessment Without Live Data Since the company is pre-operational, your review will be scenario-based. We will provide a projected transaction profile (estimated monthly volume by service type, average ticket size, target customer geography and risk tier). You will be asked to: • Evaluate whether our monitoring thresholds and escalation logic are proportionate to the projected risk profile • Assess whether our IT/screening infrastructure is adequate for the expected transaction complexity • Review our onboarding procedures for the customer types we intend to serve and identify any CDD gaps before go-live Combined Requirements For the engagement to be awarded to a single provider, the following must be met across both parts: Statutory Audit (non-negotiable) • Valid HKICPA CPA (Practising) certificate, AFRC-registered • Experience issuing auditor’s reports for HK-incorporated companies • Familiarity with IRD filing requirements and Profits Tax Return preparation for newly incorporated entities AML/CFT Review • Working knowledge of Hong Kong AMLO (Cap. 615) and C&ED’s AML/CFT Guideline for MSOs — specify which version and any C&ED circulars you have worked with • Direct experience with MSO, remittance agent, or MVTS compliance in Hong Kong or an equivalent FATF-compliant jurisdiction • Ability to evaluate IT and operational controls: transaction monitoring logic, sanctions screening tools (e.g. Refinitiv World-Check, ComplyAdvantage, LexisNexis, or equivalent), and CDD data capture systems • Familiarity with FATF Guidance for a Risk-Based Approach for Money or Value Transfer Services (2016) • Strong written English; the gap analysis report must be clear enough to present to a C&ED officer Nice to Have • Prior experience supporting an MSO licence application in Hong Kong • CAMS, ICA, ACAMS, or equivalent AML certification • Experience with IRD tax advisory for financial services companies Not a Fit If • You are not a licensed CPA (Practising) registered with HKICPA and cannot lawfully sign an auditor’s report in Hong Kong • You are proposing the AML review only without a credentialled audit partner for Part A • You would approach the AML component purely as a document-drafting exercise with no substantive gap analysis • You cannot deliver both parts within a coordinated timeline and under a single engagement agreement Engagement Structure and Timeline Part A (Statutory Audit): deliverable is a signed auditor’s report and reviewed/prepared financial statements. Timeline to be agreed based on the financial year-end date. Part B (AML/CFT Review): deliverable is a written gap analysis report. Target: 10–15 business days from receipt of our documentation package. Both deliverables are expected within 4–6 weeks of engagement start. Strong performers will be invited for an annual retainer covering statutory audit renewals and ongoing AML/CFT advisory once the licence is granted and operations commence. To Apply Submit your proposal with: your fixed-price quote broken down by Part A and Part B separately, confirmation of HKICPA credentials, and answers to all five screening questions above. Proposals without credential confirmation or screening answers will not be reviewed.