AML Updates

How Anti-Money Laundering and Counter-Terrorist Financing Oversight Is Taking Shape in the Legal Profession

• In the first quarter of 2026, The Law Society of Hong Kong introduced the AML/CTF Compliance Self Assessment Form (“AML/CTF Form”) as a mandatory exercise for all law firms, marking the first profession wide AML/CTF regulatory return with compliance consequences for non submission and a significant milestone in establishing a sustainable, proportionate, and risk based supervisory framework.
• For the first time in a sector wide AML/CTF exercise of this nature, a 100 per cent completion rate was achieved, reflecting the legal profession’s strong sense of regulatory responsibility and collective commitment to maintaining high AML/CTF standards across firms of all sizes.
• The exercise builds on the sector wide AML/CTF risk assessment conducted in 2022 by strengthening baseline understanding of risk exposure, identifying the supervised population, and providing deeper insight into how AML/CTF requirements are implemented in practice across the profession.
• The AML/CTF Form clarified The Law Society’s statutory responsibilities and supervisory powers, supported by targeted communications, published guidance on strengthening AML supervision, and extensive engagement through briefing seminars attended by over 1,250 practitioners from more than 500 firms.
• Designed as a preparatory, non enforcement exercise, the AML/CTF Form enabled The Law Society to assess current compliance levels, understand the distribution of higher risk services, identify areas requiring further guidance or training, and lay the groundwork for a phased supervisory approach including future inspections.
• Preliminary analysis shows a high level of self reported compliance and strong demand for further AML/CTF training, while also highlighting the need for firms to avoid over reliance on client familiarity and to ensure consistent application and documentation of risk assessments, client name screening, and source of funds verification.
• As part of its commitment to practical, risk based support for the profession, The Law Society has developed and launched a free Client Name Screening Tool, reinforcing that effective AML/CTF oversight combines supervision with accessible tools and guidance to assist firms in strengthening their compliance arrangements.
• Looking ahead to the next Financial Action Task Force Mutual Evaluation scheduled for 2029, The Law Society is taking proactive steps to ensure the legal profession is well prepared in advance by strengthening supervisory activities, deepening compliance culture, and maintaining close alignment with international AML/CTF standards.

Hong Kong Lawyer Journal - “President’s Message”, April 2026 Edition

The President’s Message: Successful Completion of the Anti-Money Laundering/Counter Terrorist-Financing Compliance Self-Assessment Form by Firms

• Full participation achieved: All firms submitted the AML/CTF Compliance Self-Assessment Form by the 2 March 2026 deadline, marking the first-ever 100% submission rate in a sector-wide exercise of this nature.
• Strong AML/CTF compliance levels declared by the firms: Preliminary review shows the vast majority of firms declared compliance with AML/CTF requirements, reflecting a profession-wide commitment to regulatory obligations.
• High demand for training: 90% of firms expressed interest in AML/CTF education, with over 1,250 participants from 500 firms attending related briefing seminars. These seminars focused on the AML/CTF oversight framework and practical guidance for completing the AML/CTF Form.
• Significant milestone for the profession: This exercise demonstrates not only collective diligence across firms of all sizes but also a shared understanding across the profession that regulatory compliance is a core professional responsibility, irrespective of firm size or resources. It marks a meaningful step forward in strengthening a credible, risk-based, and proportionate AML/CTF supervisory framework for the legal sector.

For details, please read The President’s Letter – P120326, dated 12 March 2026

The President’s Message: Launch of Law Society’s Client Name Screening Tool: Supporting Members in Regulatory Compliance

• What is the Client Name Screening Tool? A compliance tool developed by the Law Society to help law firms check the names of clients, beneficial owners, connected parties, and counterparties. It identifies whether they appear on the United Nations Sanctions List, are Politically Exposed Persons (PEPs), or have negative news associated with them, so firms can better assess their anti money laundering (AML) and counter terrorism financing (CTF) risks.
• Do law firms have to use the Tool? The Client Name Screening Tool is a free resource provided by the Law Society to assist members with their compliance, and its use is not compulsory. If your firm already has a screening solution in place, there is no need to change it. The Tool is primarily designed for smaller firms that mainly serve local clients. Firms with an international client base or engaged in cross-border/higher-risk transactions should carefully assess whether the Tool meets their operational needs before adopting it.
• Do I have to pay for the Tool? No. The Client Name Screening Tool is provided by the Law Society as a free resource for its members, and there is no charge for using it.
• How can I get the Tool? To obtain the Client Name Screening Tool, you need to log in to the Law Society’s Member Zone. Under the tab Support Members / Law Firms > The Law Society’s Client Name Screening Tool for Members”, you will find a request form. Please complete the form, and the Tool will be sent to you by email.
• Where can I find information about the Tool? All information about the Client Name Screening Tool is available on the Law Society’s Member Zone. By navigating to Support for Members/Law Firms and selecting The Law Society’s Client Name Screening Tool for Members, members can access comprehensive resources. A step by step User Guide (PDF) is provided with clear instructions on how to use the Tool. In addition, updated materials explain the scope and limitations of the AI features, outline relevant compliance considerations, and provide practical recommendations to assist firms in adopting the Tool effectively.

For details, please read The President’s Letter – P040326, dated 04 March 2026

The President’s Message: Submission Deadline of the AML/CTF Form – 2 March 2026 

• Reminder for law firms to complete and submit the AML/CTF Form to the Law Society by 2 March 2026. 
• Oversight Responsibility: Submission of the AML/CTF Form is a regulatory obligation for all  Hong Kong and foreign-registered law firms. 
• Submission Deadline: Firms must submit the AML/CTF Form by 2 March 2026.
• Submission Method: Online only. 
• Access to the AML/CTF Form: The Law Society’s AML main webpage under the “AML/CTF Compliance Self-Assessment Form” tab, as well as in the Members Zone under “Support for Members/Law Firms” > “AML/CTF”.
• Professional Conduct Reminder: Failure to submit the AML/CTF Form by the specified deadline may constitute professional misconduct, and the Law Society will follow up with firms that have not met the filing requirement accordingly. 

For details, please read The President’s Letter – P260226, dated 26 February 2026

The President’s Message: Mandatory Submission of the Anti-Money Laundering/Counter Terrorist-Financing Compliance Self-Assessment Form (“AML/CTF Form”) and Training Session

• Mandatory Requirement: All Hong Kong and foreign law firms must complete the AML/CTF Form as part of their professional and regulatory obligations.
• Oversight Responsibility: Submission of the Form is integral to the Law Society’s AML/CTF supervisory framework.
• Submission Deadline: Firms must submit the AML/CTF Form by 2 March 2026.
• Submission Method: Online only — no email or postal submissions will be accepted.
• Access to the AML/CTF Form: The online submission link is available on the Law Society’s AML webpage under the “AML/CTF Compliance Self Assessment Form” tab, which also provides FAQs and a sample form for reference.
• Professional Conduct Reminder: Timely submission is essential; failure to comply may amount to professional misconduct.
• AML/CTF Seminars: Following the session on 14 January 2026, another seminar will be held on 6 February 2026 covering AML supervision, the AML/CTF Form submission process, and introducing the new compliance tool for members, Client Name Screening Tool. You can register for the seminar through the Law Society Mobile App or the Hong Kong Academy of Law’s website. 

For details, please read The President’s Letter – P290126, dated 29 January 2026

Circular 26-1 (SD): Launch of the Anti-Money Laundering / Counter-Terrorist Financing Compliance Self-Assessment Form

Key Actions for Members:

• Completion of the AML/CTF Compliance Self Assessment Form (“AML/CTF Form”): All law firms are required to complete the mandatory AML/CTF Form. 
  
  • Submission deadline: 02 March 2026
  • Relevant assessment period: 01 January 2025 – 31 December 2025
  • Submissions must be made online only; email or postal submissions will not be accepted.
  • Online link to the AML/CTF Form is available on the Law Society AML website under the “AML/CTF Compliance Self Assessment Form” tab. 
  • FAQs and a sample AML/CTF Form are available under the AML/CTF Compliance Self Assessment Form” tab on the Law Society’s website to assist in completion. 
  • After clicking the “Submit” button,  you will receive a confirmation email acknowledging successful submission.
• Register for Training and Information Session: The Law Society will hold two online training sessions in early 2026 to guide members on completing the AML/CTF Form.  
  
  • Two information sessions are scheduled for 14 January 2026 and 6 February 2026.
  • Members can register via: Law Society App or Hong Kong Academy of Law website.
• Contact for Queries: Please call at (852) 2846 8804 or email: aml@hklawsoc.org.hk.

For details, please read:

• The President’s Letter – P020126 (dated 2 January 2026) and P080126 (dated 8 January 2026) 
• Circular 26-1 (SD)