On 19 Nov 2025, the HKMA reported that over 30% of Authorized Institutions have adopted AI for AML/CFT monitoring, with adoption expected to exceed 80% within 24 months. The HKMA will support this through targeted workshops on AI implementation approaches, risk detection use cases, and crypto asset ML/TF risks, while maintaining oversight of system effectiveness through regular reviews of submitted implementation plans.
This article was generated using SAMS, an AI technology by Timothy Loh LLP.
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Adoption Status of AI in AML/CFT Monitoring
On 19 Nov 2025, the Hong Kong Monetary Authority (HKMA) reported that 48 Authorized Institutions (AIs) have assessed the feasibility of deploying artificial intelligence (AI) to strengthen transaction monitoring systems for anti-money laundering and counter-terrorism financing (AML/CFT). The vast majority of AIs affirm AI's utility in enhancing the effectiveness and risk-based nature of ML/TF monitoring systems, with over 30% already adopting AI and adoption expected to exceed 80% within 12-24 months.
Approaches to AI Implementation
The HKMA observed two primary approaches to AI adoption among AIs: (1) a holistic transition replacing rules-based systems through comprehensive data restructuring and advanced analytics across broader customer and transactional data; and (2) a phased, building-block approach focusing initially on risk detection and alert prioritisation use cases. The HKMA noted scope for broader AI application beyond current use cases, with some AIs participating in the Generative AI Sandbox for AML/anti-fraud exploration.
HKMA Support Measures
To support AI adoption, the HKMA will roll out workshops covering comparative analysis of holistic vs. building-block approaches, AI use cases in risk detection and alert prioritisation, generative AI for suspicious transaction reports, and ML/TF risk management for crypto asset services. The first workshop, held on 19 Nov 2025 at Cyberport, focused on evaluating the relative merits of the two implementation approaches. These workshops will be accompanied by follow-up support and advisory publications.
Ongoing Oversight and Engagement
The HKMA will track adoption progress against implementation plans submitted by AIs and maintain regular review of transaction monitoring system effectiveness. AIs are directed to engage with their supervisory contacts in the HKMA’s AML and Financial Crime Risk Division for queries related to this guidance.
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