Compliance Manager (Trust Company & Money Service Operator)

Location: Hong Kong

Reporting to: Chief Compliance Officer / Board of Directors

Role Purpose

The Compliance Manager is responsible for overseeing and implementing the compliance framework for a licensed Trust or Company Service Provider (TCSP) and Money Service Operator (MSO) in Hong Kong. The role ensures full compliance with applicable laws and regulations, including AML/CTF, sanctions, and regulatory reporting obligations, while supporting business operations in a compliant and risk-controlled manner.

Key Responsibilities

1. Regulatory Compliance & Governance

• Ensure ongoing compliance with Hong Kong regulatory requirements, including:

  • Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO)

  • Trust or Company Service Providers (TCSP) regime

  • Money Service Operator (MSO) licensing requirements under C&ED

• Monitor regulatory developments and advise management on regulatory changes impacting trust and MSO operations

• Assist in regulatory inspections, audits, and inquiries by relevant authorities (e.g. C&ED, Police, other competent authorities)

2. AML / CFT & Sanctions Compliance

• Implement and maintain AML/CFT policies, procedures, and internal controls for trust and MSO activities

• Oversee Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) , and ongoing monitoring processes

• Review and approve higher-risk clients, transactions, and structures

• Monitor and assess sanctions exposure and ensure compliance with applicable sanctions regimes

• Identify, investigate, and escalate suspicious activities and prepare Suspicious Transaction Reports (STRs) where required

3. Client Onboarding & Risk Assessment

• Conduct and review client risk assessments for trust clients, corporate structures, UBOs, and MSO customers

• Ensure proper documentation and verification of:

  • Trust settlors, beneficiaries, protectors, and controllers

  • Corporate clients, shareholders, directors, and UBOs

• Maintain risk-based classification and periodic review of client files

4. Policies, Procedures & Internal Controls

• Draft, update, and maintain compliance manuals, AML policies, and internal guidelines

• Ensure segregation of duties and adequate internal controls between trust and MSO operations

• Support implementation of transaction monitoring tools and compliance systems

• Maintain proper record-keeping in accordance with regulatory retention requirements

5. Training & Compliance Culture

• Conduct regular AML/CFT and compliance training for staff

• Promote a strong compliance culture across trust and MSO business lines

• Provide ongoing guidance to front-office and operations teams on compliance matters

6. Reporting & Management Support

• Prepare compliance reports for senior management and the board

• Assist in annual compliance reviews and independent audit coordination

• Support licensing renewals, bank due diligence, and third-party onboarding (banks, payment institutions, crypto platforms where applicable)

Requirements & Qualifications

Mandatory

• Minimum 1-3 years of compliance experience in Hong Kong within one or more of the following:

  • Trust companies / TCSPs

  • Money Service Operators (MSO)

  • Banks, financial institutions, or regulated fintech companies

• Strong knowledge of Hong Kong AML/CTF regulations , TCSP and MSO regulatory frameworks

• Hands-on experience with CDD, EDD, STR filing, and regulatory inspections

• Ability to work independently and manage compliance across multiple regulated activities

Preferred

• Experience acting as Deputy MLRO, MLRO, or Compliance Officer

• Familiarity with trust structures, offshore entities, and complex ownership chains

• Professional qualifications such as ACAMS, ICA, CPA, or legal background

• Experience dealing with banks, regulators, and external auditors

Skills & Competencies

• Strong analytical and risk-assessment skills

• High attention to detail and documentation standards

• Excellent communication skills in English and Chinese (Mandarin)

• Ability to balance regulatory compliance with business efficiency

• Strong integrity and professional judgment

Working Arrangement

• Full-time / Part-time / Outsourced arrangement acceptable

• May concurrently support both Trust Company and MSO entities within the group