Experience

Timothy Loh LLP Advised Global Electronic Payments Provider on Compliance with Economic Sanctions

Our AML and Economic Sanctions Practice together with our DLT and FinTech Practice advised a global electronic payments provider on the Hong Kong framework for implementing sanctions contained in the resolutions of the Security Council of the United Nations. The global electronic payment provider client handles over US$700 billion of payments annually and is subject to AML and sanctions compliance risk in approximately 200 jurisdictions around the world.

Our regulatory lawyers provided guidance on the following:

  • the framework by which U.N. sanctions are implemented in Hong Kong, including advising on criminal regimes established by the United Nations Sanctions Ordinance ("UNSO") and the United Nations (Anti-Terrorism) Ordinance ("UNATMO")

  • advising on the specific sanctions adopted and enforceable in Hong Kong under the UNSO, including the precise scope of prohibited conduct for each sanction on each jurisdiction

  • advising on the reporting requirements under UNATMO

  • advising on the various levels of penalties for breaching UNSO, UNATMO or the AMLO

  • advising on the constitutional and implementation issues regarding UN sanctions imposed under UNSO

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