Money Laundering

Circulars

18 Sep 2001

Money Laundering

18 September 2001

The Chief Executive|
All authorized institutions

Dear Sir/Madam,

There has been some media speculation that Osama bin Laden and
his associates may maintain bank deposits in Hong Kong as well as
in other financial centres.

The HKMA wishes to stress that it has no information or evidence
that deposits related to bin Laden are held here. If such deposits
were to be held in Hong Kong, it is likely they would be in the
names of shell corporations or nominee names. If so, detection
would not be straightforward. There is a certain amount of
information in the public domain about companies that may be
related to the bin Laden "group" (see for example an article on
page 6 of the Financial Times of 17 September 2001). But at this
point in time the HKMA has no independent verification of this
information.

Despite the practical difficulties, the HKMA expects that
institutions will review their accounts carefully in order to check
that there are no accounts that, on the face of it, raise
suspicions about connection with possible terrorist activities.

In keeping with "know your customer" principles, institutions
should also exercise care in relation to the opening of new
accounts where there are doubts about the beneficial ownership
and/or the purpose for which the accounts are to be held.

In the event that any suspicious accounts and/or transactions
are identified, institutions should notify the Joint Financial
Intelligence Unit and also, in this instance, the HKMA.

Yours faithfully,

( D T R Carse )
Deputy Chief Executive

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Last revision date : 01 August 2011