Guidelines for Submission of Business Planby Applicant for Money Service Operator Licence/Licensee

These guidelines set out key elements that should be included in the business plan so as toallow the Money Service Supervision Bureau (“MSSB”) to have a comprehensive
understanding of the applicant’s proposed money service business and its mode of operation.
At a minimum, the applicant should include in the business plan the following items set out inthe table below.
The business plan should ensure that the applicant pays attention to both the broad
operational and compliance objectives of the new business. The MSSB is obliged to look
into the applicant’s entire business operation from the anti-money laundering andcounter-terrorist financing (“AML/CFT”) perspective. As such, it is important that theapplicant will provide all necessary information to MSSB for examination and has thenecessary resources to execute the business plan and comply with both the statutory andregulatory requirements. Failure to provide this information may delay or hinder theprocessing of your application. In addition, the applicant is required to confirm in writing inthe business plan that he/she is well aware of and will comply with the statutory requirementthat if there is any change in the particulars that are provided to the Commissioner ofCustoms and Excise (“Commissioner”) for the grant or renewal of money service operator(“MSO”) licence, the licensee must notify the Commissioner in writing of change within one
month beginning on the date on which the change takes place.

Item
No.

Required
information

Detail of the required information

1

Company name

Provide information on the company name, business name,website address, business logo and trademark that will be
used to promote the money service business.

2Company history

Provide information on the applicant’s history, the source ofcapital and whether the applicant is associated with orcontrolled by any entities or group company.

3

Key executives ofsenior
management

Provide information on the key executives of the senior
management including their nationality, employment
history, qualification and education level.

1Ver.(12/2019)4

Location of key
management

Location of senior management (where key businessdecision is made).
If there is any back-end office in or outside Hong Kong,elaborate the function/purpose of this office and its
whereabouts.

5Customers andlocation ofcustomers

Provide information on the potential and expectedcustomers including their geographical location andnationality, mode of contacting with the customers etc.

6Business
operation in Hong
Kong and its key
objective

Elaborate in detail on what business operation will takeplace in Hong Kong and the reason of obtaining a licence
locally. The business operation should detail the entire
transaction process such as placing the transaction order,
handling and processing of order, movement of funds,
compliance function, and accounting and record keeping
function, etc.

7

Delivery channels
of product andservice offered

Provide information on the type of product and service to beoffered and the timeline of launching these product andservice.
Elaborate in detail on how each type of product and service
are carried out and the entire delivery channel including
processing of orders and fund flows going through each
foreign agent or foreign MSO in different jurisdictions.
If foreign agents or foreign MSOs are used to transfer or
receive funds, please provide information on all agents andoverseas MSOs together with the service agreement.
Elaborate the measures taken to protect customer funds
against risk of loss in the event of nonfulfillment of otheragent or MSO both inside and outside Hong Kong.

8Bank account

Provide information of any bank accounts used for thebusiness, such as account number and owner of the bankaccount (No third party bank account is allowed), etc.
Note:
If the applicant considers there is no need to open bankaccount for the business, the applicant is required to provide
details on how will the company provide money service
without bank account.

9Profitability andfinancial
information of thebusiness

Provide information on the expected profit margin andturnover on each type of product and service for the next
two years and the running capital for the daily operation of
the business

2Ver.(12/2019)10

Organizational
structure

Organization of the group of companies in Hong Kong
Elaborate the group of companies (include the parent
company, local branches and subsidiaries), their locations
and respective functions. Attach an organizational chart of
the group of companies and provide a brief description andbusiness carried out by each entity within the group.
Organization of the international group of companies
outside Hong Kong
Elaborate the international group of companies to which theapplicant belongs. Attach an organizational chart of theinternational group of companies and provide a brief
description and business carried out by each entity within
the group.

11Local businesspremises

If the applicant’s business premises are shared by “otherbusinesses” (including businesses not belong to theapplicant), elaborate the nature of the “other businesses”.
Elaborate whether the “other businesses” in the applicant’sbusiness premises are also owned by the applicant/director
or partner or staff of the applicant.
Elaborate whether the “other businesses” in the applicant’sbusiness premise have any business relationships with theapplicant. If yes, elaborate the nature of the business
relationships.

12Local humanresources

Management team of the applicant
Elaborate the composition of the management team. Total
number of the members, their position, roles andresponsibilities (e.g. compliance functions, reporting ofsuspicious transactions), full time/part time, the reportinglines.
Employee of the applicant
Elaborate the composition of the employees. Total numberof employees, their position, roles and responsibilities (e.g.
compliance functions, reporting of suspicious transactions),
full time/part time, the reporting lines.

13

Use of outsourcedservices

Provide the name and nature of any outsourced services
used by the applicant for AML/CFT purpose.
For example, external audit function, any specified
intermediary.

14

Computerized /screening systems

Elaborate the computerized systems and other automation
systems used in the business.
3Ver.(12/2019)For example, name of the commercial service or databaseprovider for automated AML solution and sanction
screening, etc.
15

Acting as agent or
principal

If the applicant also acts as an agent for “other local MSO”
and/or “overseas company/business entity”, provide thename of the “other local MSO” and/or the “overseascompany / business entity”. Elaborate the functions ofacting as agent by the applicant.
If the applicant also acts as a principal for “other localMSO” and/or “overseas company/business entity”, provide
the name of the “other local MSO” and/or “overseascompany / business entity”. Elaborate the functions ofacting as principal by the applicant.

16

Other types ofbusiness
relationships

If the applicant’s business involves the use of other third
party’s payment platform or network, e.g. digital wallet,etc., explain the role of the payment platform / network in
the applicant’s business.
If the applicant’s business involves the activities oflocal/cross-boundary physical cash movement, provide thename of the company/person in relation to such activities.

17

Subject to othersupervision

Whether the applicant’s local business or internationalgroup of companies to which the applicant belongs is also
subject to other type of supervision (e.g. holding licencegranted by other regulator/competent authority). If yes,provide the name of the other regulator/competentauthority.

4Ver.(12/2019)