Anti-Money Laundering (AML) Compliance Policy 

Stellaris Asset Management Limited (“we,” “our,” “us”) is committed to maintaining the highest standards of integrity and compliance in all aspects of our business operations. As part of our ongoing efforts to prevent money laundering (ML) and the financing of terrorism (FT), we have implemented an Anti-Money Laundering (AML) Compliance Program in accordance with the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (AMLO), and other applicable laws and regulations in Hong Kong.

Our AML policy is designed to detect and prevent money laundering activities and terrorist financing by adhering to the legal and regulatory requirements established by the Hong Kong Monetary Authority (HKMA), the Securities and Futures Commission (SFC), and other relevant authorities.

1. Commitment to Compliance 

We are fully committed to preventing our services from being used for the purpose of money laundering, terrorist financing, or any other illegal activities. To that end, we ensure that our employees, agents, and business partners comply with all relevant laws and regulations.

We maintain a robust and ongoing AML compliance program to:

  • Identify, assess, and manage the risks of money laundering and terrorist financing.
  • Prevent the use of our services for illegal activities.
  • Monitor and report suspicious transactions to the appropriate authorities.

2. Customer Due Diligence (CDD) 

We conduct comprehensive Customer Due Diligence (CDD) to verify the identity of our clients and ensure they are not involved in illegal activities. As part of our CDD process, we collect and verify the following information:

  • Personal Identification Information: Full name, date of birth, nationality, and identification number (e.g., HKID card, passport).
  • Contact Information: Address, phone number, and email address.
  • Financial Information: Source of wealth, source of funds, and employment or business details.
  • Risk Profiling: We conduct an assessment of the potential money laundering or terrorism financing risks associated with each client, based on factors such as the client’s background, country of origin, and the nature of their business activities.

We apply Enhanced Due Diligence (EDD) for high-risk clients, which may include politically exposed persons (PEPs), individuals from high-risk jurisdictions, or clients with complex ownership structures.

3. Ongoing Monitoring 

Once a client’s identity has been verified, we continue to monitor their transactions and account activities to detect any suspicious activities that may indicate money laundering or terrorist financing. This includes:

  • Transaction Monitoring: Regularly reviewing transaction patterns for irregularities or suspicious activity.
  • Ongoing Risk Assessment: Continuously assessing clients’ risk profiles based on their financial activities and other factors.
  • Alert Systems: Using automated systems to flag unusual or suspicious transactions that fall outside of normal activity patterns.

If any unusual or suspicious activity is detected, we will immediately escalate the issue to our AML Compliance Officer for further investigation.

4. Reporting Suspicious Transactions 

In compliance with the AMLO, we are required to report suspicious transactions to the Joint Financial Intelligence Unit (JFIU) of the Hong Kong Police Force. A suspicious transaction report (STR) must be submitted if we have reasonable grounds to suspect that a transaction involves proceeds from crime or may be related to terrorism financing.

Our employees are trained to identify and report suspicious activity promptly. We ensure that all reports are handled with confidentiality and that no actions will be taken against individuals or entities solely based on suspicion until the investigation is completed.

5. Record Keeping 

We maintain records of all customer information, transactions, and the steps taken to verify and monitor clients for a minimum of seven years, as required by the AMLO. These records are kept secure and are readily available for inspection by the regulatory authorities.

The following records are kept:

  • Customer identification documents.
  • Correspondence and transaction records.
  • Any internal reports on suspicious transactions or activities.

6. AML Compliance Officer 

To ensure effective implementation of our AML compliance program, Stellaris Asset Management Limited  has appointed an AML Compliance Officer who is responsible for overseeing all AML-related activities. The responsibilities of the AML Compliance Officer include:

  • Ensuring that the company’s AML policies and procedures are up to date and comply with current laws and regulations.
  • Conducting regular training and awareness programs for employees regarding AML laws and best practices.
  • Reviewing and investigating any reports of suspicious activity or non-compliance.
  • Submitting suspicious transaction reports (STRs) to the JFIU as required.
  • Liaising with regulatory bodies on AML-related matters.

7. Training and Awareness 

We provide regular training to our employees to ensure that they understand the latest AML laws and the procedures necessary to identify and manage potential money laundering risks. All new employees undergo mandatory AML training as part of their onboarding process, and ongoing training is provided at least annually.

Our training covers:

  • The identification of red flags or suspicious activities.
  • The proper procedures for reporting suspicious transactions.
  • An overview of the legal obligations under Hong Kong’s AML laws.

8. Record of Non-Compliance and Disciplinary Actions 

Any employee or representative found to have violated the company’s AML policies will be subject to disciplinary action, which may include termination of employment or reporting the violation to the relevant authorities.

9. Review and Audits 

We conduct regular internal audits and assessments of our AML procedures to ensure they remain effective and compliant with regulatory requirements. These audits are carried out by our internal compliance team and, where appropriate, external auditors.

In addition, we continuously review our risk management practices to ensure that we are addressing emerging risks, especially as financial crimes and money laundering techniques evolve.

10. Cooperation with Regulatory Authorities 

Stellaris Asset Management Limited fully cooperates with local regulatory authorities, including the Securities and Futures Commission (SFC), Hong Kong Monetary Authority (HKMA), and law enforcement agencies, in matters relating to money laundering and terrorist financing investigations. We are committed to adhering to all regulatory guidelines and ensuring that our operations meet the highest standards of legal compliance.

11. Confidentiality and Data Protection 

We take the confidentiality and security of client data seriously. Any personal or financial information obtained during the course of our AML checks will be kept secure and confidential. We ensure that our procedures align with Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) to protect client data from unauthorized access or misuse.

12. Amendments to This Policy 

We reserve the right to amend or update this AML Compliance Policy at any time to reflect changes in regulatory requirements or internal procedures. Any changes to the policy will be communicated to employees and clients, as necessary.