How to Renew Category B Registration for Dealers in Precious Metals and Stones (DPMS) in Hong Kong

For dealers in precious metals and stones (“DPMS”) holding a Category B registration in Hong Kong, timely renewal is essential to ensure the uninterrupted continuation of precious metals and stones business involving specified cash transactions. A Category B registration is valid for three years, and failure to renew within the prescribed timeframe may result in immediate operational disruption, as well as potential criminal and regulatory liability if the registrant continues to operate with an expired registration.

The renewal process is administered by the Hong Kong Customs and Excise Department (the “C&ED”) and is governed by section 53ZUQ of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (“AMLO”).

On 25 March 2026, the Dealers in Precious Metals and Stones Supervision Bureau of the C&ED issued a circular “Category B Registration - Renewal Application” (“Renewal Circular”) setting out detailed guidance on renewal requirements and regulatory expectations.

This article offers DPMS Category B registrants a practical overview of the renewal process, key regulatory reassessment criteria, and the key compliance considerations that should be addressed ahead of submission.

1. What Is the Renewal Timeline for DPMS Category B Registration in Hong Kong?

The 60-Day Rule

A Category B registrant must submit its renewal application to the C&ED at least 60 days before the expiry date of its existing registration. If a Category B registrant fails to submit the renewal application before the 60-day statutory requirement or provide all the requisite documents to the C&ED, the renewal application may be deemed to be an invalid application which may not be further processed by the C&ED.

Category B registrants should therefore plan ahead, allowing sufficient time to gather documentation and complete internal checks before submission.

The 90-Day Reminder

The C&ED will issue a reminder email to Category B registrants approximately 90 days prior to the expiry of the registration. Whilst the reminder may be helpful, it is important to understand that reliance on this reminder does not discharge the registrant’s legal obligation. The absence or late receipt of the reminder email does not constitute a valid ground for a late application.

Registrants who have changed their contact email address should ensure that the C&ED has been notified of the update through the prescribed channels, in order to ensure receipt of the reminder. In all cases, Category B registrants are advised to maintain their own internal calendar alerts and compliance schedules, independent of any regulatory notifications.

What Happens If I Miss the Deadline to Renew My Category B Registration?

Failure to submit a timely renewal application may result in the registration lapsing automatically upon the expiry of the registration. Once a registration has lapsed, the Category B registrant is prohibited from carrying out both specified transactions and specified cash transactions until a new Category B registration is obtained. This could effectively require the firm to suspend a material component of its operations whilst a fresh application is processed.

Additionally, an incomplete renewal application (i.e. one submitted on time but without the requisite forms or supporting documents) may be deemed to be an invalid application by the C&ED. In such circumsatnces, the existing registration will lapse automatically upon the expiry of the validity period. The registrant must cease carrying out any specified transactions or specified cash transactions in the course of its precious metals and stones business.

Pursuant to section 53ZUQ(4) of the AMLO, where a Category B registrant submits a valid renewal application to the C&ED at least 60 days before the expiry of the registration, the registrant will be able to continue to operate after the expiry date if its renewal application remains pending, until the earlier of: (i) the C&ED’s grant or refusal to renew the registration; and (ii) withdrawal of the renewal application.

2. How Do I Submit a Category B Registration Renewal Application to the C&ED?

Submission Methods

A Category B registrant may submit its renewal application through either of the following channels:

• Online Application: Category B registrant may submit through the Dealers in Precious Metals and Stones Registration System (“DRS"); or
• By post or in person: Category B registrant may submit to the Dealers in Precious Metals and Stones Supervision Bureau, Customs and Excise Department, at Unit 3501, 35/F, Skyline Tower, 39 Wang Kwong Road, Kowloon Bay.

Registrants without a DRS account should refer to the C&ED’s circular “
Facilitation to Paper Mode Registrants – An Enhancement of the Dealers in Precious Metals and Stones Registration System” dated 4 November 2025 regarding arrangements for paper mode registrants.

What Documents Are Required to Renew a DPMS Category B Registration?

The following documents must be submitted as part of a complete renewal application:

(i)  Completed Renewal Application Form

• Form 2(BR) for registrants holding a valid Business Registration Certificate, or
• Form 2(H) for registrants holding a valid licence under Part 2 of the Hawker Regulation (Cap. 132 sub. Leg. AI).

(ii) Fit and Proper Person Declaration Form(s)

• Form 3A (with Appendices I and II) for each individual required to satisfy the fit and proper test (i.e. sole proprietors, partners, individual directors, and individual ultimate owners), and/or
• Form 3B for each corporate partner or corporate director.
  
  Appendix I to Form 3A must be signed by the declarant in the presence of a witness who is an authorised officer of the C&ED, a practising professional (e.g. solicitor, accountant or auditor), a notary public, or a Justice of the Peace. The witness must verify the declarant’s identity against original documents and certify that the personal particulars are true and correct. The witness shall also certify that the Appendix I is signed by the declarant in his or her presence.

(iii) Description of Precious Metals and Stones Business and AML/CFT Measures (Renewal)

 The Category B registrant must submit either:

• the C&ED’s prescribed proforma (the Annex as set out in the Renewal Circular, the “Proforma”); or
• Category B registrant’s own descriptions of its precious metals and stones business and AML/CFT measures, provided that such descriptions contain all information prescribed in the Annex.

This document is a central component of the renewal assessment and is discussed in detail in Section 4 below.

(iv)   Photocopies of Requisite Supporting Documents

Category B registrants should refer to Chapter 16 of the “Registration Guide for Dealers in Precious Metals and Stones” published by the CEE in March 2026 (“Registration Guide”) for the full list of requisite supporting documents. Application forms and guidance notes are available on the DRS or from the Precious Metals and Stones Supervision Bureau at Unit 3501, 35/F, Skyline Tower, 39 Wang Kwong Road, Kowloon Bay, Hong Kong.

On receipt of the application, the C&ED will issue the registrant an acknowledgement receipt.

Where required, a reminder for provision of any outstanding documents will be issued. If the registrant fails to provide the requisite information or supporting documents before the date specified in the reminder, the renewal application may be considered invalid and may not be further processed.

When all requisite documents are received, the C&ED will email the registrant a payment notification and a notice for an interview.

3.  What Does the C&ED Assess When Reviewing a Category B Renewal Application?

The C&ED will conduct a substantive reassessment of whether the registrant continues to meet all statutory eligibility requirements for Category B registration. Firms should approach renewal with the same level of thoroughness as an initial application.

A.  Valid Business Registration Certificate

The registrant must hold a valid Business Registration Certificate issued under the Business Registration Ordinance (Cap. 310) at the time of the renewal application. Firms should verify that their business registration is current and that any changes to the registered business name, nature of business, or address have been properly updated.

B.  Fit and Proper Assessment

The C&ED will reassess whether the registrant and all relevant individuals continue to satisfy the fit and proper test. Relevant individuals include the sole proprietor (in the case of a sole proprietorship), each partner and each ultimate owner (in the case of a partnership), and each director and each ultimate owner (in the case of a corporation).

An ultimate owner is defined to include any individual who

1. owns or controls more than 25% of the issued share capital;
2. is entitled to exercise or control more than 25% of the voting rights at general meetings; or
3. exercises ultimate control over the management of the corporation.

The factors which the C&ED will take into consideration in determining whether a person is fit and proper include:

• the person’s financial status or solvency, including history of bankruptcy, liquidation, or winding up;
• whether the person had conviction in Hong Kong or elsewhere for any money laundering or terrorist financing offence or other offence involving fraudulent, corrupt or dishonest conduct; and
• whether the person had failed to comply with regulatory requirements imposed under the AMLO or other obligations applicable to DPMS registrants.

The C&ED conducts checks against records held by their department, other government departments and law enforcement agencies as part of the vetting process.

Firms that have had ownership or management changes should take particular care to confirm that any new partner, director, or ultimate owner received prior written approval from the C&ED (via Form 4) before assuming their role. Under sections 53ZUW, 53ZUX and 53ZUY of the AMLO, assuming such a role without prior C&ED approval, without reasonable excuse, constitutes a criminal offence carrying a maximum penalty of HK$50,000 and six months’ imprisonment.

C. Key Personnel Appointments

As required by the Renewal Circular, a registrant must have in place the following key personnel:

1. A senior management staff

A senior management staff  is normally the sole proprietor, a partner authorised in writing by all partners of the Category B registrant , or a director authorised by the board of directors. This senior management staff is responsible for implementing effective AML/CFT policies that can adequately manage the money laundering and terrorist financing risks identified;

1. A Compliance Officer (“CO”)  

The CO is appointed by senior management staff and is responsible for the oversight of the applicant’s AML/CFT systems and compliance measures; and

1. A Money Laundering Reporting Officer (“MLRO”)

The MLRO is appointed by senior management staff and serves as the central reference point for reporting suspicious transactions to the Joint Financial Intelligence Unit (“JFIU”).

Both the CO and the MLRO must normally be based in Hong Kong. Except the sole proprietor, partner, director, or ultimate owner serves as both the CO and the MLRO, the CO and the MLRO must be held by an employee of the applicant under the Employment Ordinance (Cap. 57).

Particulars of the senior management staff, a director (where applicable), the CO and the MLRO must be disclosed in the Proforma (at sections B.11 to B.14).

D. Ongoing AML/CFT Compliance

The C&ED will assess whether the registrant has maintained an effective AML/CFT framework throughout the registration period and whether its policies, procedures, and controls remain adequate. The substantive AML/CFT requirements are set out in Schedule 2 of the AMLO. The key areas of assessment of the AML/CFT measures are set out in Part B of the Proforma and are discussed in Section 4 below.

4.  What Is the Proforma and Why Is It Critical for Category B Renewal?

The Annex to the Renewal Circular sets out the prescribed proforma that Category B registrants must complete (or replicate in their own format). It is divided into two parts.

Part A — Descriptions of the Precious Metals and Stones Business

Part A requires the Category B registrant to describe its business background and structure, including company history, organisational structure, number of employees, business nature, and the types of goods and services provided. The registrant must also disclose any material changes since the approval of its last application or the submission of its most recent annual return, with particular reference to any changes in the business pattern of specified cash transactions.

Where the registrant belongs to a Hong Kong or overseas group, it must also provide details of the group holding company, the business relationship between the registrant and the group, and whether the group holding company is subject to other forms of regulation or supervision.

Part B — AML/CFT Measures

Part B requires the Category B registrant to demonstrate across several areas that it has maintained an effective AML/CFT programme. The principal areas addressed include:

• Policies, procedures and controls: Whether adequate written AML/CFT policies and procedures are in place, as evidenced by policy statements or other written documents;
• Customer due diligence (“CDD”): Whether CDD measures are conducted before establishing business relationships or carrying out specified cash transactions, including identifying and verifying the identity of customers, their beneficial owners, and persons acting on their behalf, and obtaining information on the purpose and intended nature of the business relationship;
• Enhanced due diligence (“EDD”): Whether EDD measures are applied in high risk situations, such as where customers are politically exposed persons (“PEPs”) or have not been physically present for identification purposes;
• Risk-based ongoing monitoring: Whether a risk-based approach to ongoing monitoring of business relationships and transactions is in place, with a view to identifying transactions inconsistent with the registrant’s knowledge of the customer and detecting suspicious transactions;
• Staff policies and guidelines: Whether staff have been provided with policies or guidelines covering CDD procedures, criteria for identifying suspicious transactions, and relevant AML/CFT measures;
• Third-party screening: Whether a third-party screening system is used to identify PEPs and persons designated on terrorist financing and proliferation financing sanctions lists during CDD;
• Record-keeping: Whether transaction records and CDD records are maintained at business premises, including the duration and method of record-keeping. The registrant is also required to provide an Album of Record-Keeping (Part D of the Annex) to demonstrate compliance in practice; and
• Suspicious transaction reports (“STRs”): Whether systems or procedures are in place for submitting STRs to the JFIU as required under the Organized and Serious Crimes Ordinance (Cap. 455), the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405), and the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575). Renewal applicants are also expected to explain how they plan to enhance the effectiveness of STR reporting during the new registration period.

Part B of the Proforma further requires the Catgory B registrant to confirm whether AML/CFT training has been provided to staff with records maintained, and to set out how it proposes to enhance its AML/CFT training programme during the new registration period.

5.  What Should Category B Registrants Expect at the C&ED Interview and AML/CFT Competence Assessment?

Upon receipt of all requisite supporting documents, the C&ED will issue the Category B registrant with a payment notification and a notice requiring an interview at the Precious Metals and Stones Supervision Bureau. The interview serves to verify original documents, enable the C&ED to seek clarification or elaboration on information submitted, and assess the applicant’s AML/CFT capability.

Prior to the interview, the senior management staff and the CO must jointly complete an AML/CFT Competence Assessment. This assessment comprises a mix of multiple-choice and true/false questions and takes approximately 20 minutes. Reference materials may be consulted during the assessment (ie. an open book assessment). The result of the Competence Assessment will serve as one of the important factors in the C&ED’s consideration of the renewal application.

Registrants should ensure that both the designated senior management staff and the CO have reviewed the C&ED’s AML/CFT Guideline for Category B registrants and all relevant circulars in advance of the AML/CFT Competence Assessment.

6. How Much Does It Cost to Renew a DPMS Category B Registration in Hong Kong?

The following fees are payable upon receipt of the C&ED’s payment notification:

No refund will be made in respect of fees collected, irrespective of whether the renewal application is approved or refused.

7.  What Are the Possible Outcomes of a Category B Registration Renewal Application?

Approval

Purusuant to section 53ZUQ of the AMLO, where the C&ED approves the renewal, the Category B registration will be extended for a further three-year period commencing on the date immediately following the expiry of the previous registration (i.e. not the date the C&ED grants renewal). Registrants should note this distinction when planning future renewal timelines.

Refusal

Where the renewal application is refused, the registrant must immediately cease carrying out specified transactions and specified cash transactions upon notification of the refusal.

A registrant that receives a notice of refusal may appeal to the Anti-Money Laundering and Counter-Terrorist Financing Review Tribunal within 21 days of the date the notice of refusal is sent. Category B registrant in this position should seek legal advice promptly on available appeal grounds and on the steps necessary to rectify their position.

Should I Consider Downgrading from Category B to Category A Registration?

The Renewal Circular also highlights that a Category B registrant which, based on its current business situation, has not conducted any specified cash transactions in the past three years may consider applying for a Category A registration rather than renewing Category B. Category A carries a lighter regulatory burden but does not permit cash transactions of HK$120,000 or above. Upon granting of Category A registration, the existing Category B registration will lapse accordingly. Registrants contemplating this option should plan carefully, as operating after the expiry of a Category B registration without any valid registration would expose them to criminal liability.

8.  Category B Registration Renewal Checklist: Key Compliance Considerations

The renewal of a Category B DPMS registration requires thorough preparation and should not be left to the last minute. In summary:

• Submit the renewal application at least 60 days before expiry – Category B registrants should not wait for the 90-day reminder email.
• Ensure all requisite forms are completed correctly: Form 2(BR) or 2(H), Form 3A (with Appendices I & II) or Form 3B, and the Proforma.
• Confirm that the CO and MLRO are properly appointed and based in Hong Kong, and that both the senior management staff and CO are prepared for the AML/CFT Competence Assessment prior to the interview.
• Budget for the renewal fees: HK$1,060 for the application, plus HK$650 per person subject to the fit and proper test. These fees are non-refundable.
• Disclose all material changes in corporate structure, ownership, management, and business activities, and verify that C&ED prior approval was obtained for any new partners, directors, or ultimate owners.
• Treat the Proforma as a substantive compliance document: it must accurately reflect the firm’s actual AML/CFT programme, and renewal applicants are expected to include enhancement plans for the new registration period.
• If renewal is refused, appeal to the AML/CFT Review Tribunal within 21 days of the notice of refusal.

Disclaimer: This publication is provided for general information and guidance only. The views and comments expressed herein do not constitute, and should not be relied upon as, legal advice or a legal opinion.

How KYC Management Can Help

AML Screening and Compliance Tools for Precious Metals and Stones Dealers (DPMS)  

The renewal of Category B registration places significant emphasis on the robustness and effectiveness of a registrant’s AML/CTF framework. As part of this process, Part B of the Proforma requires firms to clearly demonstrate the implementation of comprehensive AML/CFT controls across key areas, including customer due diligence, sanctions & PEPs screening, record-keeping, and suspicious transaction reporting.

Given the heightened regulatory expectations around AML/CFT compliance, Category B registrants should view the renewal process as a strategic opportunity to proactively identify gaps and strengthen their compliance infrastructure. Taking early action can help firms mitigate the risk of regulatory scrutiny, or potential refusal of renewal.

KYC Management offers a comprehensive suite of tools designed specifically to support Category B DPMS registrants in meeting these requirements with confidence.

What KYC Management Offers

1. AML Screening Tools for DPMS

DPMS are required to identify politically exposed persons and the persons designated on the terrorist financing and proliferation financing sanctions list during their customer due diligence procedures.

KYC Management simplifies this process with a comprehensive AML screening tool that allows DPMS to screen both individuals and businesses against a wide range of global datasets, including sanctions, PEP, financial regulatory, law enforcement, and adverse media lists covering real-time data from 230+ jurisdictions and 43,000 global sources.

2. Ongoing Monitoring

Minimise your risk exposure and keep your team up-to-date with any new developments of your clients and their associates. Screened Profiles can be added to your Watchlist and monitored on a daily basis. New updates are immediately consolidated on KYC Management and emailed to you, ensuring you always have the most updated information.

3. Customer Due Diligence and Onboarding

KYC Management enables a seamless digital onboarding experience through its CDD Portal, supporting the efficient collection, verification, and ongoing management of customer due diligence information for both individuals and legal entities. The platform facilitates the identification and verification of customers, beneficial owners, and authorized representatives, ensuring compliance with Schedule 2 AMLO requirements.

By leveraging a structured CDD workflow, DPMS can streamline data and document collection, improving efficiency and ensuring all necessary checks are completed prior to conducting specified cash transactions.

4. Assisted Risk Assessment and Risk Scoring

KYC Management supports Category B registrants in adopting a risk-based approach to AML/CFT compliance through its assisted risk assessment and scoring capabilities. Tailored specifically for DPMS Category B requirements, the platform offers a comprehensive framework to evaluate money laundering and terrorist financing risks, with recommended risk ratings and corresponding levels of due diligence aligned with AML/CFT Guidelines issued by the C&ED. In addition, auditable risk assessment reports are automatically generated, ensuring transparency and readiness for regulatory inspections.

5. Record keeping and audit readiness

Under the AMLO, Category B registrants must retain CDD records for at least five years. KYC Management provides a centralised document management system that stores CDD records, screening results, risk assessments, and related documentations in a secure environment.

Seamlessly integrated with the CDD Portal, the platform enables users to generate client due diligence, screening, and risk assessment reports. This structured and centralised approach ensures DPMS Category B registrants are well-prepared to respond efficiently to regulatory enquiries and inspections by the C&ED..

6. Managing ongoing compliance obligations

KYC Management helps registrants stay on top of ongoing compliance obligations through automated reminders for expiring identification documents and key deadlines. These proactive alerts help maintain accurate, up-to-date records and reduce the risk of compliance gaps.

References

For more information about TCSP licensing, compliance obligations, and AML guidelines in Hong Kong, please refer to the following official resources:

1. Circular “Category B Registration - Renewal Application” (“Renewal Circular”) issued by the Dealers in Precious Metals and Stones Supervision Bureau of the Hong Kong Customs and Excise Department on 25 March 2026
2. Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615 of the Laws of Hong Kong)
3. Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Category B Registrants Dealing in Precious Metals and Stones) issued by the Hong Kong Customs and Excise Department in June 2023
4. Registration Regime for Dealers in Precious Metals and Stones
   issued by the Hong Kong Customs and Excise Department in March 2026

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