2019-11-22
Added · Updated
The Securities and Futures Commission issued this circular to guide asset managers in identifying and handling dubious private fund and discretionary account arrangements that may facilitate market misconduct or money laundering. Senior management must implement robust procedures, including initial screening, detailed due diligence, and documented decision-making, to ensure arrangements are not used to evade regulatory obligations or laws. The regulator warns that failure to detect or report such suspicious activities constitutes a breach of conduct and anti-money laundering guidelines, potentially resulting in regulatory action against the firm and its management.