Establish and maintain AML/CFT systems; oversight of compliance.
Develop AML/CFT policy; cover CDD, transaction monitoring and reporting.
Primary AML/CFT contact with Customs & Excise; manage RFIs and audits.
Ensure ongoing compliance incl. CDD for HKD 8,000; keep records 6+ years; periodic returns.
Lodge licence renewals and ad-hoc returns to C&ED; quarterly returns.
MLRO duties: central reporting to JFIU; identify/report suspicious transactions; maintain records.

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