AMLAWARE | Knowledge or Suspicion
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Knowledge or Suspicion

17 Jun Knowledge or Suspicion

Topic Progress:

Under Hong Kong law, insurers must report any knowledge of information or activities that could reasonably be assumed to indicate potential money-laundering activities. This includes:


  • Actual knowledge,
  • Knowledge of circumstances that would indicate facts to a reasonable person, and
  • Knowledge of circumstances that would cause a reasonable person to make additional inquiries.


Even if an insurer has no direct knowledge or proof of money-laundering activities, a report must still be filed if there is a reasonable basis for suspicion. This includes reporting any suspicious transaction based upon what is known about the customer.


The difference between normal or regular business activities conducted by the customer and those which are unusual or out of the ordinary is a key factor in deciding whether to report a suspicious transaction. This determination is based upon your knowledge of the customer and the customer due diligence process, beginning at the outset of the business relationship.