Hong Kong MSO license approval rate has dropped significantly, how to overcome the high standard compliance threshold?
Gold Content of Hong Kong MSO Licence
Hong Kong MSO license, full name Money Service Operator, also known as "money service operator license", is a pass for enterprises to legally carry out currency exchange and remittance services in Hong Kong, and its gold content is highly recognized in the global financial market.
1. Major financial centers to enhance business reputation
As the most dynamic financial center in Asia and the global offshore RMB trading center, Hong Kong has unique advantages. Its "free port" status ensures the free entry and exit of funds, free from foreign exchange control restrictions, so that international funds regard Hong Kong as a safe and reliable place to store wealth, which greatly enhances the attractiveness of the market. Hong Kong accounts for about 70% of the global offshore RMB (CNH) trading volume. It is the world's largest offshore RMB trading and clearing center, and its trading activity is unmatched. A mature regulatory framework, a well-established open trading mechanism and a wealth of financial products have further consolidated Hong Kong's global financial position. As a result, enterprises holding MSO licenses can gain higher recognition in the international financial market and significantly enhance their legitimacy and market competitiveness. With the surge in demand for cross-border exchange and international remittances, the importance of MSO licenses has become increasingly prominent, which not only brings a leap in business reputation for enterprises, but also helps them to seize opportunities in the global financial arena and create greater commercial value.
2. Enhance customer trust and ensure compliance security
The MSO license is protected by Hong Kong law and every transaction is supervised by the General Administration of Customs and Excise (C & ED) to ensure 100 per cent compliance, security and confidentiality of financial transactions, and a significant increase in customer trust.
3. Simplified application process, cost-effective
Compared to other financial centres, the MSO licence application process in Hong Kong is straightforward and transparent, with no excessive regulatory burden, competitive licence fees and predictable overall process costs.
4. Diversified services, expand the scope of business
The MSO license allows companies to carry out a variety of financial services such as currency exchange, remittance and foreign exchange transactions in the Hong Kong market to meet the diverse needs of industries such as cross-border e-commerce, financial technology and virtual asset transactions.
Applicable objects of Hong Kong MSO license
Any individual or entity providing currency exchange and remittance services in Hong Kong must apply for an MSO licence from the Commissioner of Customs and Excise, including:
1. 货币兑换 Money Changing Service
A currency exchange service operated as a business in Hong Kong, but excluding incidental services in relation to the principal business. For example, a retail business that accepts foreign currency in a transaction or a person who manages a hotel runs the following business:
The service is operated on the premises of the hotel, mainly for the convenience of customers staying at the hotel;
Only transactions in which the person purchases non-Hong Kong dollar currency for Hong Kong dollar currency.
2. Remittance service Remittance Service
A service carried on as a business in Hong Kong that provides one or more of the following transactions:
send money or arrange for it to be sent outside Hong Kong;
to receive money from, or cause to be received from, a place outside Hong Kong;
Arrangements for the collection of money outside Hong Kong.
The MSO licence is valid for two years. If you wish to continue operating the Money Service, you must apply for renewal of your licence 90 days before and 45 days after the expiry date.
If you are a financial institution already regulated by the Securities and Futures Commission or the Hong Kong Monetary Authority, such as an authorized bank, a licensed company and an authorized insurance company, you do not need to apply for an MSO licence.
Application Conditions for Hong Kong MSO
The following strict requirements are required to apply for an MSO licence:
1. Company qualification
The applicant must be a limited liability company or unlimited liability company incorporated in Hong Kong, or a branch of an overseas company registered in the Hong Kong Registry.
Both Hong Kong residents and non-residents can apply to hold an MSO licence, and the shareholders can be individuals or companies.
2. Registered capital
The company is required to pay a registered capital of HK $500000, and the source of funds must be legal and traceable.
3. Determination of suitable candidates
The directors (at least one), shareholders and ultimate beneficiaries of the company are to be determined by the appropriate person of the General Customs and Excise Department (C & ED).
Applicants are required to submit a certificate of non-criminality, bank flow and a suitable person application form, which must be signed in the presence of a witness (an authorized officer of customs, a practicing lawyer, an accountant, an auditor or a notary public).
Restrictions: Individuals or companies with a criminal record that have declared bankruptcy and have not restored their rights, as well as companies managed by such persons, are not eligible to apply.
4. Business office or office address
A physical office address in Hong Kong, authorized by a formal lease agreement with the landlord and approved by C & ED, is required for business activities and meetings.
The residential address may be used as the office address, provided that the written consent of each occupier is obtained and a stamped copy of the lease or title record, the floor plan and the area of the residence are provided.
In the absence of a specific business office, a local management office (LMO) must be designated to hold the company's books and records, and the address must be subject to customs site inspection.
5. DOCUMENT REQUIREMENTS
Submit company documents, including business registration certificate, articles of association, personal data of all directors, shareholders, partners and ultimate beneficiaries.
Provide a detailed business plan that describes the scope of services, target markets and risk management measures.
Submit Anti-Money Laundering (AML) and IT policies and a letter of authorization signed by all partners or board members.
6. Interviews and competency assessments
Applicants are required to demonstrate their business capabilities to C & ED and demonstrate the functionality and compliance of the technology platform by demonstrating the Beta version of the website or App. Demo needs to demonstrate currency exchange, remittance and other service processes, in line with anti-money laundering and KYC requirements. Customs will assess system stability and compliance.
The applicant is also required to attend a face-to-face interview. C & ED will verify the authenticity of the materials, examine the feasibility of the business plan, the professionalism of the management team and the understanding of supervision, and judge the applicant's operational ability based on the interview performance and technical demonstration.
Difficulty in Application for MSO Licence in Hong Kong
1. The type of business determines the difficulty of approval.
Offline business scenarios, such as daily low-value currency exchange, are easier to pass C & ED approval due to low capital density and simple transactions. However, if it is an online business scenario involving high-frequency and large-value receipts and payments, such as cross-border payments or virtual asset transactions, it is necessary to prove strong anti-money laundering risk control capabilities, which significantly increases the difficulty of approval. Due to the high capital density of the money business itself, it will be classified by banks as a high money laundering risk business, regardless of how well the business description and compliance are done. Banks are very reluctant to open accounts for such businesses at the dual risk of having their banking licences revoked and high fines, especially if the founding team itself does not have a banking background.
2. Tighter regulation pushes up the application threshold
With the surge in demand for MSO licenses from cross-border e-commerce, financial technology and virtual asset trading enterprises, the number of applications continues to rise. However, in order to meet international anti-money laundering standards, Hong Kong Customs has greatly increased the regulatory requirements in accordance with the Anti-Money Laundering and Terrorist Financing Ordinance (Chapter 615), which has made it more difficult to approve MSO licenses, which can be described as "one license is difficult to obtain". The most important application difficulty lies in the change of regulatory attitude. In practice, C & ED is more cautious in examining the qualifications, background and conditions of applicants, and strictly selects to ensure that only enterprises with high compliance ability and reliable operation background can be approved. According to Hong Kong Customs data, MSO license applications have increased significantly since 2023, but the approval rate has declined. As of May 2025, only about 1100 companies in Hong Kong hold valid licenses..
The increase in the difficulty of applying for MSO licenses is reflected in the following points:
Rejection rate increased: regulatory "zero tolerance" for non-compliant applications, rejection rate increased significantly, common reasons include incomplete documents, business plan is not clear. The customs will also strictly examine the applicant's background, assess his qualifications, real purpose to prevent speculators from reselling after applying for a license, and whether the applicant or the group behind it has the financial and operational capacity to support the stable operation of the company in the next three years.
Documentation requirements have increased: business plans, AML/KYC policies, financial statements, shareholder background, etc. have to be submitted, with a significant increase in variety and complexity.
Rising compliance costs: Increased costs for compliance consultants, internal control systems and staff training, especially for small and medium-sized enterprises.
Best Scheme for MSO Licence Application in Hong Kong
In the face of the high threshold and complex process of MSO license application in Hong Kong, choosing a professional team is the key to successfully obtain a license. Rengang Yongsheng provides you with a one-stop solution. With many years of successful cases, it is well versed in the approval process of C & ED to ensure that the enterprise fully meets the strict requirements of the Anti-Money Laundering and Terrorist Financing Regulations (AMLO). We provide full process support from company registration, detailed document preparation to customized AML/KYC policy and transaction monitoring system, covering legal consultation, office registration and anti-money laundering system construction, ensuring the accuracy of application materials and greatly improving the approval rate.
Rengang Yongsheng also provides transparent cost advice, including compliance consultants, legal advice and supplementary material fees, to help you plan your budget efficiently.
By optimizing the application process, we help you quickly obtain an MSO license within 7-9 months and seize market opportunities!