Enhanced Competency Framework (ECF) - AML/CFT

The objectives of the ECF-AML/CFT are twofold:

(a) to develop a sustainable talent pool of AML/CFT practitioners for meeting the workforce demand in this sector; and:

(b) to raise and maintain the professional competence of AML/CFT practitioners in the banking industry.
 

Although the ECF is not a mandatory licensing regime, authorized institutions ("AIs") are encouraged to adopt the ECF for the following purposes:

(a) to serve as a benchmark to determine the level of competence required and to assess the ongoing competence of individual employees;

(b) to support relevant employees to attend training programmes and examinations that meet the ECF benchmark;

(c) to support the continuing professional development of individual employees; and

(d) to specify the ECF as one of the criteria for recruitment purposes.
 

Please refer to HKMA circular on ''Enhanced Competency Framework on Anti-Money Laundering and Counter-Financing of Terrorism''  for details

The ECF-AML/CFT is targeted at "Relevant Practitioners", including new entrants and existing practitioners, engaged by an AI to perform AML/CFT compliance roles in its Hong Kong operation. Details of the respective roles are classified by a two-level qualification structure (i.e. Core Level and Professional Level).

The qualification structure of ECF-AML/CFT comprises two levels:

(a) Core Level – suitable for entry-level staff with less than three years of relevant work experience in AML/CFT compliance; and

(b) Professional Level – suitable for staff with three years or above of relevant work experience in AML/CFT compliance.

The Core Level consists of five training areas to equip new entrants and staff in junior AML/CFT roles with the essential fundamentals for performing their AML/CFT duties, and the Professional Level consists of five training areas aims to develop further the knowledge of the more experienced practitioners.

Grandfathering arrangement for ECF-AML/CFT (Core Level) ended on 30 April 2017 and the grandfathering application for ECF-AML/CFT (Professional Level) ended on 31 December 2018.
 

A Relevant Practitioner may be grandfathered on a one-off basis based on his or her years of qualifying work experience upon implementation of the relevant level of qualification. Such work experience need not be continuous. The detailed grandfathering requirements are as follows:
 

a) Core Level – A Relevant Practitioner may apply for grandfathering if he or she has possessed at least 3 years of work experience in AML/CFT compliance as at 31 December 2016. (The grandfathering period for Core Level ended on 30 April 2017.)

b) Professional Level – A Relevant Practitioner may apply to the HKIB for grandfathering if he or she has possessed at least 8 years of AML/CFT compliance work experience, of which 3 years is at managerial level or above, as at 31 March 2018.  (The grandfathering period for Professional Level ended on 31 December 2018).

For other individuals performing AML/CFT compliance roles but not working in an AI during the grandfathering period, they may submit their applications to the HKIB for grandfathering within three months from the date of joining the AML/CFT compliance function of an AI and becoming Relevant Practitioners. However, they should have met all the applicable grandfathering criteria on or before the applicable dates prescribed above. 

Relevant Practitioners who are holders of the Certified Anti-Money Laundering Specialist certification or the International Diploma in AML awarded by the Association of Certified Anti-Money Laundering Specialists and the International Compliance Association (ICA) respectively are eligible for seeking exemption for both the Core Level and the Professional Level of the ECF-AML/CFT, subject to successful completion of a bridging training programme. The bridging training programme shall be offered, administered and conducted by HKU School of Professional and Continuing Education (HKU SPACE) and the certification as AAMLP or CAMLP shall be offered and administered by Hong Kong Institute of Bankers (HKIB).
 

The bridging training programme covers various topics on local regulatory framework, risk-based approach, AML/CFT specialist risks areas and financial inclusion. Relevant Practitioners are required to fully attend the 6-hour training sessions and obtain a pass in the assignment.
 

Exemption for ECF-AML/CFT (Core Level): Upon completion of the Bridging Course with HKU SPACE, Relevant Practitioners who have less than 3 years of relevant work experience in AML/CFT can apply for AAMLP Certification.
 

Exemption for ECF-AML/CFT (Professional Level): Upon completion of the Bridging Course with HKU SPACE, Relevant Practitioners who have more than 3 years of relevant work experience in AML/CFT can apply for CAMLP Certification.
 

For schedule and enrollment of the Bridging Course, please visit: ”HKU SPACE'' 

To support and facilitate the talent development in the AML/CFT related sector specifically in banking, HKIB has developed learning programmes – the “Enhanced Competency Framework on Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) (Core Level) ” & “Enhanced Competency Framework on Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) (Professional Level) ”to help individuals attain the Core Level and the Professional Level of the competency standards set by the ECF-AML/CFT. It will facilitate the building of professional competencies and capabilities for relevant practitioners in AML/CFT related sectors in banking through attaining the relevant professional qualification(s) to achieve the required competency level(s).

Upon completion of the programme, participants should be able to:

• Explain what money laundering/ terrorist financing (ML/TF) is and how to relate it to the banking and finance sector and the work of Relevant Practitioners in Hong Kong.

• Specify the importance of ML/TF in relation to the Hong Kong banking and finance sector..

• Describe the Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) International Standards and the related Hong Kong legal and regulatory framework.

• Identify key elements of the AML/CFT risk management framework in-system design and assess the related risks.

• Assess transaction patterns and apply customer due diligence requirements to identify suspicious transactions for reporting.

• Apply and assess the ongoing AML/CFT monitoring system and investigation process.

The programme is opened to members / non-members of HKIB. Candidates must fulfill the stipulated minimum entry requirements:

• Students of Associate Degree (AD)/Higher Diploma (HD) in any disciplines (QF L4); OR
• Equivalent qualifications or above; OR
• Mature applicants* with 3 years of relevant banking experience with recommendations from employer

* Mature applicants (aged 21 or above) who do not possess the above academic qualifications but with relevant banking experience and recommendation from their employers will be considered on individual merit.

Training & Examination Details (ECF on AML/CFT – Core Level)

 ^* For learners who would like to select “Tutorial” rather than “Tuition” are recommended to have at least 2 years of relevant work experience or have been taking up senior officer grade or above in AML/CFT functions.

#A digital version of training material (i.e. Study Guide and PPT Slides) will be provided before the training commencement.  Printed version will only be available at an additional cost of HKD600 (including delivery fee) on request by learners.  

Upon completion of the programme, participants should be able to:

• Assess and analyze the compliance risk of different operations by applying a risk-based approach and take current and emerging AML/CFT.

• Develop compliance programme, control measures assessment tools and internal standards to manage compliance and fraud risk to align with laws and regulations particularly related to AML/CFT.

• Track and monitor of activities critical to compliance and detect non-compliance issues, suspicious and illegal transactions based on observation, data analysis and regulatory requirements.

• Manage and investigate incidents of non-compliance and develop mitigation strategies to minimize the impacts of breaches of regulations.

• Build an effective AML/CFT risk management system with risk-based approach to ensure regulatory changes and related compliance programme and measures are well communicated to the employees.

The programme is opened to members / non-members of HKIB. Candidates must fulfill the stipulated minimum entry requirements:

• Advanced Certificate for ECF on Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) awarded or grandfathered by The Hong Kong Institute of Bankers (HKIB)

The programme is opened to members / non-members of HKIB. Candidates must fulfill the stipulated minimum entry requirements:

• Certificate for Module (Enhanced Competency Framework on Anti-Money Laundering and Counter-Financing of Terrorism Professional Level) awarded by HKU SPACE

Training  (ECF on AML/CFT – Professional Level)

^*Learners are required to attend both training at HKU SPACE and tutorial at HKIB

*The Study Guide is available for collection and payment at the HKIB office or you may arrange courier service for delivery.
Study guides are now available for purchase at HKIB

For schedule and enrollment of the ECF on AML/CFT (Professional Level) Training, please visit: HKU SPACE

Students will receive an invitation email from HKIB for the tutorial session & examination within 6 - 8 weeks after successfully completing the training session with HKU SPACE


Examination (ECF on AML/CFT – Professional Level at HKIB) 

Upon completion of the programme, participants should be able to:

• Analyze the compliance risk of different operations by apply a risk-based approach and take current and emerging AML/CFT trends, regulatory requirements, techniques and typologies into account.

• Manage and investigate incidents of non-compliance and develop mitigation strategies to minimize the impacts of breaches of regulations.

• Facilitate financial inclusion and balance the interests of internal and external stakeholders in the bank's AML/CFT framework.

The programme can be completed in 2 weeks. The total number of contact hour is 6 for the entire course. The major syllabus as follows:

• Overview of Hong Kong AML/CFT regulatory framework and International AML/CFT regime.

• Application of the risk-based approach.

• Customer due diligence in the cross-border context.

• The risk-based approach and AML/CFT risks in specialist areas.

• Trade-based money laundering and tax/fiscal risk.

• Ensuring financial inclusion.

• Key drivers for de-risking. 

The programme is opened to members / non-members of HKIB. Candidates must fulfill the stipulated minimum entry requirements:

• Applicants shall hold the Certified Anti-Money Laundering Specialist certification or the International Diploma in AML awarded by the Association of Certified Anti-money Laundering Specialists and the International Compliance Association respectively.

For schedule and enrollment of the bridging course, please visit HKU SPACE

Applicant should complete and sign the Application Form, together with the appropriate examination fee, and return by email, or by hand to HKIB Office on or before the corresponding enrolment deadline.

Late entries for tutorial will be accepted up to 7 days after the stipulated application deadlines. An additional late entry fee of HK$200 will apply.

Late entries examinations will be accepted up to 14 days after the stipulated application deadlines. An additional late entry fee of HK$200 will apply

For schedule and enrollment of the Training and Examination, please visit our HKIB website.

Associate Anti-Money Laundering Professional (AAMLP): Relevant Practitioners who have completed the Advanced Certificate for ECF on AML/CFT training and passed the corresponding examination are eligible to apply for the certification as AAMLP which is issued by HKIB and recognized by HKMA. (Work experience is not a prerequisite for obtaining the certification)

Certified Anti-Money Laundering Professional (CAMLP): Relevant Practitioner who have at least 3 years of relevant work experience in AML/CFT, completed the Professional Certificate for ECF-AML/CFT training and passed the corresponding examination are eligible to apply for the certification as CAMLP which is issued by HKIB and recognized by HKMA.

You may download the Certification Guidelines and Application Form for application.

To ensure the Relevant Practitioners maintain their competency levels by updating their existing knowledge and skill set, they are required to fulfill the CPD requirements as stated by HKMA.

As a general guideline, All AAMLP/CAMLP holders are required to comply with annual Continuing Professional Development (CPD) Scheme. AAMLP/CAMLP holders are required to undertake a minimum of 10/12 hours of verifiable CPD, of which at least 5/6 hours should be on AML/CFT while the remaining CPD hours should be on compliance (including financial crime compliance), risk management, ethics, or legal and regulatory requirements.

Individuals who completed the training / tutorial and passed at the relevant examinations are eligible to apply exemption to the relevant module(s) under another HKIB programme(s), namely the Advanced Diploma Programme for Certified Banker (QF Level 4, QR Registration No.: 18/000081/L4, Validity Period from 15/02/2018 to 14/02/2022) or the Professional Diploma for Certified Banker (QF Level 5, QR Registration No.: 18/000082/L5, Validity Period from 15/02/2018 to 14/02/2022) respectively.

Upon fulfilling the entry requirement, completing the remaining modules of the programme and satisfying the required years of work experience, they may also be awarded the respective Certified Banker (Stage I) or the Certified Banker (Stage II) Professional Qualifications.

The Advanced Diploma Programme for Certified Banker and Professional Diploma Programme for Certified Banker are the CB professional banking qualification programmes developed and offered by HKIB. They are intended to raise the professional competencies of banking and financial practitioners in Hong Kong to meet modern demands, while providing a transparent standard with international recognition.