Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Statement
Effective Date: Aug 20, 2026
Company: Grand Pine Investment Limited
Corporate Seat: Kowloon, Hong Kong
Our Commitment
Grand Pine Investment Limited is committed to maintaining robust safeguards against money laundering, terrorist financing, proliferation financing, fraud, and other forms of financial crime.
As a wealth advisory and transaction management firm operating from Hong Kong, we maintain a risk-based compliance framework designed to identify, assess, mitigate, monitor, and report financial-crime risks associated with our clients, counterparties, transactions, and business relationships.
Our AML/CFT framework is designed with reference to applicable Hong Kong laws and regulatory requirements, including the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (“AMLO”), the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405), the Organized and Serious Crimes Ordinance (Cap. 455), the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575), applicable sanctions requirements, and relevant guidance issued by Hong Kong regulatory and law-enforcement authorities. We also take into account applicable international standards established by the Financial Action Task Force (FATF).
1. Client Due Diligence (CDD) & Know Your Customer (KYC)
Before establishing a business relationship or providing applicable services, Grand Pine Investment Limited conducts appropriate customer due diligence based on the nature and risk profile of the relationship.
Our procedures may include:
- Identity Verification: Verification of clients, directors, authorized representatives, trustees, signatories, and other relevant persons using reliable and independent documentation or information.
- Beneficial Ownership: Identification and, where applicable, verification of the beneficial owners and persons exercising ultimate ownership or control of corporate entities, trusts, foundations, and other legal arrangements.
- Purpose and Nature of the Relationship: Obtaining sufficient information to understand the purpose and intended nature of the proposed business relationship and the expected activity associated with it.
- Authority to Act: Where a person acts on behalf of a client or entity, we take appropriate measures to verify that person’s identity and authority to act.
These measures are applied on a risk-sensitive basis, with enhanced due diligence applied where circumstances indicate increased money-laundering or terrorist-financing risk. Hong Kong’s AML framework expressly provides for customer identification, beneficial-owner identification, understanding the purpose and intended nature of a relationship, and ongoing monitoring.
2. Source of Wealth & Source of Funds
Grand Pine Investment Limited does not knowingly accept funds or assets derived from unlawful activities.
Depending on the risk profile of a client or transaction, we may request information and supporting documentation concerning:
- The client’s source of wealth;
- The source and origin of funds;
- The economic rationale for a transaction;
- Ownership and control structures;
- Bank or financial-account information;
- Corporate transactions, investment proceeds, inheritance, dividends, business income, or other legitimate sources of wealth.
Where information provided is insufficient, inconsistent, unverifiable, or otherwise raises material financial-crime concerns, we may decline to establish or continue the relationship or transaction.
3. Risk-Based Monitoring
Grand Pine Investment Limited applies ongoing monitoring appropriate to the nature, size, complexity, and risk profile of each business relationship.
Our monitoring framework may consider:
- Unusual or unexplained transaction activity;
- Transactions inconsistent with a client’s known business or financial profile;
- Unusual third-party payments or transfers;
- Complex or unnecessarily opaque ownership structures;
- High-risk jurisdictions or unusual cross-border activity;
- Transactions involving unrelated parties or jurisdictions without an apparent legitimate purpose;
- Adverse information identified through reliable public or commercial sources;
- Attempts to provide incomplete, inconsistent, or unverifiable information.
Hong Kong authorities identify, among other indicators, unexplained third-party payments, unusual offshore-account activity, unrelated jurisdictions, unverifiable information, and reluctance to provide supporting documentation as potential suspicious-transaction indicators.
4. Sanctions & Politically Exposed Persons (PEPs)
Where applicable, clients, beneficial owners, counterparties, and relevant transaction parties are screened against appropriate sanctions, PEP, and adverse-media databases.
Our sanctions controls take into account applicable Hong Kong sanctions requirements, including United Nations sanctions implemented in Hong Kong, together with other sanctions-screening measures appropriate to our risk assessment and business activities. Hong Kong’s sanctions framework includes implementation of United Nations Security Council sanctions through the United Nations Sanctions Ordinance and related regulations.
PEP relationships are subject to appropriate risk assessment and, where required, enhanced due diligence and senior-management oversight.
5. Enhanced Due Diligence
Where a client, beneficial owner, transaction, jurisdiction, or other relevant circumstance presents elevated financial-crime risk, Grand Pine Investment Limited may apply enhanced due diligence measures.
Such measures may include:
- Obtaining additional identification and ownership information;
- Establishing and verifying source of wealth and source of funds;
- Obtaining additional information regarding the purpose of transactions;
- Increasing the frequency of monitoring and review;
- Obtaining appropriate senior-management approval before establishing or continuing a higher-risk relationship.
Our controls are intended to be proportionate to the identified ML/TF risks rather than applying identical procedures to every client. Hong Kong AML guidance follows a risk-based approach, with enhanced measures expected where risks are higher.
6. Suspicious Transaction Reporting
Grand Pine Investment Limited maintains procedures for identifying and escalating transactions or circumstances that may give rise to suspicion of money laundering, terrorist financing, or other financial crime.
Where applicable legal obligations are triggered, suspicious transaction reports are submitted to the Joint Financial Intelligence Unit (JFIU) in accordance with Hong Kong’s reporting framework.
Applicable Hong Kong legislation requires reporting where a person knows or suspects that property represents proceeds of, or is connected with, relevant criminal conduct or terrorist property. Financial institutions subject to the SFC’s AML/CFT regime are expected to submit suspicious transaction reports to the JFIU as soon as reasonably practicable where the relevant reporting threshold is met.
Grand Pine Investment Limited will not disclose the existence or contents of a suspicious transaction report where such disclosure would breach applicable anti-tipping-off requirements.
7. Record Keeping & Confidentiality
We maintain appropriate records relating to client identification, beneficial ownership, due diligence, risk assessments, transactions, monitoring, and compliance reviews in accordance with applicable Hong Kong legal and regulatory requirements.
Records are maintained in secure systems with appropriate access controls and safeguards against unauthorized access, alteration, or disclosure.
For entities subject to the relevant AMLO requirements, record-keeping and customer due-diligence obligations are maintained in accordance with the applicable statutory retention periods and regulatory requirements. Hong Kong’s AML framework specifically imposes CDD and record-keeping requirements on covered financial institutions and designated non-financial businesses and professions.
8. Compliance Governance
Grand Pine Investment Limited maintains internal policies and procedures designed to support effective AML/CFT risk management.
Our compliance framework may include:
- Customer and institutional risk assessments;
- Client onboarding and verification procedures;
- Beneficial-ownership identification;
- Sanctions and PEP screening;
- Transaction monitoring;
- Escalation and investigation procedures;
- Suspicious transaction reporting procedures;
- Periodic compliance reviews;
- Staff awareness and AML/CFT training; and
- Appropriate record-keeping and internal controls.
The scope and application of these controls are reviewed periodically to reflect changes in applicable Hong Kong requirements, our business activities, and the financial-crime risk environment.
9. Our Zero-Tolerance Approach
Grand Pine Investment Limited does not knowingly facilitate or participate in money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful financial activity.
We reserve the right, subject to applicable law and contractual obligations, to refuse onboarding, restrict activity, suspend services, terminate relationships, or take other appropriate measures where financial-crime risks cannot be adequately mitigated.
Our objective is to maintain a transparent, responsible, and risk-sensitive operating environment consistent with the integrity expected of businesses operating from Hong Kong’s international financial centre.