The activities of MSO companies are regulated by Hong Kong’s Anti-Money Laundering and Counter-Terrorist Financing Ordinance. The ordinance states that companies providing any money services are required to obtain an MSO licence to conduct their business.
Money services include the following activities:
1. money changing services means services for the exchanging of currencies that are operated in Hong Kong as a business, excluding services operated by a person who manages a hotel if the services:
2. remittance services means services that are operated in Hong Kong as a business*:
*one or more of these activities can be used
The description of remittance services also covers the activities of payment agents: even if a company does not make a cross-border payment directly, but accepts funds from a client and makes payment to a person designated by the client, that transaction falls within the scope of “remittance services”.
The minimum number of directors is 1.
A director may be either an individual or a legal entity. However, at least one director must be an individual.
At least one company director must pass a Competence Assessment. It is a special test that must be taken in person at a Hong Kong university authorized by the Regulator. The test is designed to assess how the management of an MSO-licensed company is familiar with Hong Kong’s anti-money laundering and counter-terrorist financing (AML/CTF) legislation.
Compliance officer (CO) is a company employee responsible for overseeing and monitoring the company’s AML/CTF compliance.
Money laundering reporting officer (MLRO) is a company employee responsible for reporting suspicious transactions.
Employees holding the CO and MLRO positions must be Hong Kong residents. Both CO and MLRO must be employed by the company under an employment contract.
One employee can act both as CO and MLRO simultaneously.
The minimum number of shareholders and beneficial owners of a company is 1.
A shareholder can be either an individual or a legal entity. A company’s beneficial owner is always an individual who ultimately controls the company.
Every private Hong Kong company must have a secretary. The secretary must be a Hong Kong resident licensed to provide the relevant services.
A company must maintain an office in Hong Kong from which it directly conducts its business within Hong Kong. The company must keep all its records (primarily accounting records) at this office address and be able to make them available for inspection at any time. Furthermore, all official communications from Hong Kong authorities will be sent to this address.
The company’s office address is publicly available and is specified in its licence.
Only one MSO-licensed company may occupy the office. If another company (without an MSO licence) also operates from the same premises, its business and document flow must be clearly separated from those of the MSO-licensed company.
The Regulator will not accept the address of a company’s secretary, legal adviser, or accountant as the office of an MSO-licensed company.
There is no statutory minimum authorized capital.
All directors, COs, MLROs, shareholders, and beneficial owners of the company must be fit and proper to hold their positions. This means, in particular, that these persons:
0. Incorporate a Hong Kong company.
1. Rent an office for the company.
2. Hire a CO and MLRO, as well as all other employees required by the company.
3. Open accounts required for the company’s operations.
4. Submit an application for an MSO licence to the Regulator. The application must be accompanied by the following documents:
5. Pay MSO licence fees. If the licence application is rejected, licence fees are non-refundable.
6. Do an interview with the Regulator.
7. Pass a Competence Assessment for the director in Hong Kong.
The Regulator’s review of the application (up to sending an invoice for the licence fee and an invitation to an interview and Competence Assessment) takes approximately 2-3 months. In total, the entire process of obtaining an MSO licence in Hong Kong takes approximately 9-12 months provided all necessary steps are completed promptly.
The total of licence fees payable depends on the company structure. The main fees are:
The licence is valid for two years. Before the licence expires, it must be renewed if the company still wishes to provide MSO services. The renewal procedure is largely similar to the initial application.
Also, the company (like any other private Hong Kong company) is required to file an Annual Return and renew its business registration every year.
Payment for MSO licence application services is made in four stages:
Stage I – services of:
Payment must be made before we proceed with incorporation of the company.
Stage II – assistance with opening necessary bank accounts for a Hong Kong company.
Payment must be made before we proceed to help with account opening.
Stage III – drafting the compliance manual, AML/CFT risk management policy, and other policies required by the company based on the specific MSO activities it will perform.
Also 50% of fees for:
Payment must be made before we proceed to draft the policies and submit the application.
Stage IV – the remaining 50% for the services specified in Stage III.
Payment must be made after a date is set for the director’s Competence Assessment.
|
Services
|
Fees (USD)
|
|
Stage I
|
|
|
Total cost of company incorporation* (including preparation and provision of the company’s original constitutive documents and their apostilled copies, share issue documents and common seal)
*does not include Compliance fee |
2 500
|
|
Searching for office space:
|
|
|
- GSL services of searching for office space, agreeing the terms of and arranging the signing of the office rent agreement are charged on an hourly basis at the rate USD 300 / hour, with a report on the work done
|
300 / hour
minimum deposit – USD 1 200 |
|
- GSL agency fee, if the rent agreement is signed
(payable once) |
10% of annual sum
|
|
- the HK realtor’s fee, if any, is paid additionally as invoiced by the realtor (the fees of local realtors can equal a monthly or two monthly rents)
|
according to the realtor’s invoice
|
|
Recruiting staff
|
15 – 25% of annual salary
|
|
Stage II
|
|
|
Assistance with opening a Hong Kong account
|
3 500
|
|
Assistance with opening a bank account outside Hong Kong*
*the final cost will depend on the specific bank where you open the account; |
from 2 500
|
|
Assistance with opening an account in an Electronic Money Institution (EMI)
|
2 900
|
|
Stage III
|
|
|
Drafting the compliance manual, AML/CFT risk management policy, and other policies required by the company based on the specific MSO activities it will perform
|
300 / hour,
but at least USD 3 500 per document |
|
50% of fees for preparing and submitting a Money Service Operator (MSO) licence application*
Supporting the MSO licence application process and liaising with the Regulator Arranging an interview with the Regulator and having the director take a Competence Assessment *does not include government fees |
from 7 500
|
|
Stage IV
|
|
|
50% of fees under Stage III
|
from 7 500
|
|
Company and licence renewal
|
|
|
Annual administration (starting from the second year)*
*does not include Compliance fee |
2 185
|
|
MSO licence renewal for another 2 years
|
from 10 000
|
|
Compliance fee
|
|
|
Compliance fee
Payable in the cases of: |
440 (standard rate – includes the check of 1 individual)
+ 200 for each additional individual (director, shareholder, or beneficial owner) or legal entity (director or shareholder) if such legal entity is administered by GSL + 265 for each additional legal entity (director or shareholder) if such legal entity is not administered by GSL 550 (rate for High Risk companies – includes the check of 1 individual) 135 (signing of documents) |
*The fees are valid as of August 2026.