Hong Kong MSO License: Key steps & insights

Exploring the financial services sector in Hong Kong? If you’re considering setting up a money changing or remittance service, you’d need an MSO (Money Service Operator) license to get started, whether you’re an individual or a company.

What is an MSO?

Money Service Operator (MSO) is a person or an institution which operates a money changing service or a remittance service.

The service of money changing, as implied by its name, involves the exchange of different currencies. However, it's important to note that this excludes the common exchange of foreign currencies for local ones by tourists at hotel counters, which is regarded as "incidental."

The term "remittance service" refers to the process of sending funds from Hong Kong to an overseas location or receiving funds in Hong Kong from abroad. This definition also encompasses any arrangements made for such sending or receiving of funds.

What is required to be an MSO in Hong Kong?

Any individual or company operating a money service is required to be licensed with the Commissioner of Customs & Excise (CCE) under the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (Chapter 615 of the Laws of Hong Kong), also known as the AMLO.

Under the AMLO, money services are not limited to the traditional physical counters providing money changing or remittance services but also cover mobile operations with no fixed premises, including online operations.

If a person or institution operates without a license, that person or institution commits an offence and is liable on conviction on indictment to a fine of (a) HK$1,000,000 and to imprisonment for 2 years, or (b) on summary conviction to a fine of $100,000 and to imprisonment for 6 months.

What are the mandatory requirements to apply for an MSO License?

  • Incorporation and valid corporate registration documents
  • Suitable premises used for the operation of a money service or local management office, and local place for storage of books and records
  • “Fit and proper person” as director and ultimate owner of the company
  • Appoint a competent Compliance Officer and Money Laundering Reporting Officer
  • Comprehensive Business plan
  • Documented anti-money laundering and counter-terrorist financing policy
  • Pass a written competence assessment
  • Bank account for operating money service business

How long is the application process?

The processing time varies and depends on various factors. Factors include the time taken in the preparation and submission of the required forms, supplementary information and supporting documents, the time taken for completing the written competence assessment, on‐site inspection at the business premises, and the time required for CCE to obtain records from other authorities to perform a fit and proper person test.

In general, the MSO license is valid for 2 years. In order to maintain continuous operation of the money service, the licensee must apply for renewal before the license expires.

Fidinam can help you obtain an MSO license in Hong Kong

The advantage of an MSO license in Hong Kong extends beyond legal requirements, as it offers a strategic foothold in one of the world’s major financial hubs.

Our expert team at Fidinam is here to guide you every step of the way in obtaining an MSO license and operating your money service business through:

  • Providing consultancy and support during the entire process
  • Incorporation of the Hong Kong company or registration of non-Hong Kong company wishing to operate as MSO
  • Supporting in the preparation of application forms, business plan and anti-money laundering and counter-terrorist financing policy
  • Providing training and support to prepare the applicant for the written competence assessment
  • Supporting in the opening of the appropriate bank account
  • Liaising with CCE
  • Supporting in the recruitment of competent Compliance Officer, Money Laundering Reporting Officer and other employment requirements of the company


Get in touch with us via the form below or info@fidinamgw.com.

Get in touch with Fidinam Hong Kong