offshore banking regulation reform
TRANSCRIPT
Hong Kong Offshore Banking Regulation ReformGroup 8Interim Deliverable II• Year 3 Surveying Studio • 30 November 2009
HK as Asia’s Offshore Financial Center • URL: http://hkofc.blogspot.com/ !
PART I: Current Banking Regulations in Hong KongBanking services is the most essential element of an OFC to provide financing and funding for
investment. The banking sector of Hong Kong is basically regulated by the Banking Ordinance.
O!shore business investors appreciate the current business environment mainly due to the low tax
policy as discussed in the previous deliverable. However, doing banking business in Hong Kong is
not as easy as operating other types of trading activities. A series of requirements have to be fulfilled
before a new bank can be register in Hong Kong.
1.1 Cap. 155 - Banking Ordinance
It is important for a jurisdiction to regulate the banking sector mainly for the confidence of general
public. Under the ordinance, there are 3 types of Authorized Institutions (AIs) allowed in Hong
Kong, namely the licensed banks, restricted licensed banks (RLBs) and deposit taking companies
(DTCs). Their minimum of registration, hence the entry barrier is shown in the below table:
We can see that it is di"cult for foreign banks to be licensed in Hong Kong. The entry barrier is
high which requires a very strong capital base. The ordinance aims at protect the banking sector
and the depositor by setting entry, product line and ratio controls.
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Licensed Banks Licensed Banks RLBs DTCs
Min. Deposit N/AN/A HKD 0.5m HKD 0.1mMin. Deposit Maturity N/AN/A 24-hour 3 months
Min. paid-up Capital Local banks:HKD 150m
Foreign banks:USD 16 billion
HKD 100m HKD 25m
Min. shares of AI HKD 3 billionHKD 3 billion N/A N/A
Min. Assets HKD 4 billionHKD 4 billion N/A N/A
Domestic Banking YesYes No No
The entry control can be explained by the table above while the product line control mainly deals
with the amount loan allowed to lend. For example, the maximum amount of mortgage that is
permitted under the Banking Ordinance is 70%. This is important when considering the potential
investments by o!shore companies as they may need financing for purchasing properties and
investments.
The ratio control focuses on the capital base of the AIs. It is required that any AIs should have a
minimum liquidity ratio (Liquefiable assets/ Qualifying Liabilities) of 25% and capital adequacy
ratio (Capital base/ Risky Assets) of 8%.
• Abolishment of Estate Tax: Nevertheless, the abolishment of estate tax in 2005 induced an
incentive for new foreign investor. The Revenue (Abolition of Estate Duty) Ordinance 2005 is
not just simply a kind of tax structure reform but also a reformulation of business policy for
future development. The tax reform in 2005 is relatively not that e!ective since the mainland
China also has no estate tax. The competitiveness of Hong Kong is not much enhance when
compared to Shanghai as the financial centre of PRC. Although it sounds frustrating, the
change in attitude shows a sign of aggression for a better future development.
1.2 The Regulatory AuthoritiesIn Hong Kong, currently, many di!erent financial institutions appear in the fund market. For
example, licensed banks, which escape the banking regulation for strict supervisory by setting up
Special Investment Vehicles(SPVs) to make investment in fund market. Like licensed banks, other
types of financial institutions which are not originally players in fund market may seek profitable
opportunities here. Because in Hong Kong, the market monitoring system is not based on a single
root, di!erent types of institutions are regulated by di!erent authorities, the fund investment
industry is currently monitored by a number of regulators due to the background of di!erent
players. The institutions that involve in the regulation of fund investment are listed below:
• Hong Kong Monetary Authority (HKMA)
• Securities and Futures Commission (SFC)
• Hong Kong Association of Banks (HKAB)
• O"ce of Commissioner of Insurance
From the lesson we learnt from the sub-prime mortgage crisis in 2008, or rather, from the lesson we
learnt from the fact that HKMA and SFC blamed and shifted the responsibilities to each other for
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the seriously impacted mini-bond issue, we could find out that the financial regulation framework in
Hong Kong has its defects as commonly the same situations all over the world, and when there is a
severe financial crisis, the current regulation framework will not help to resolve the outstanding
problems but to make the situation even worse. It seems that the regulation bodies are quite
complete, but actually it shows a problem of over-bureaucracy, however, lack of detailed regulations.
Moreover, because nowadays, each area of financial market is no longer as separated as it was
before. The interaction and more importantly, interpenetration between each sections(banks,
insurance firms, finance companies, investment banks, funds) is more prosperous than before, it is
also the reason why the market is so active these years. To regulation framework, the traditional
divided one could no longer apply to today`s situation very well, as the response speed to
outstanding issue is not adequate to fulfill the current market requirement, also the responsibility
between each bureau could not be easily defined as before.
In conclusion, the market calls for a converge of di!erent regulatory bodies under a special and
whole-functioned regulation framework to deal with the comprehensiveness of current financial
market. It is the global trend in financial regulation. As Hong Kong is envisaged to be a future
crucial o!shore financial center in Asian region, it is urgent for Hong Kong to take the steps faster
than other competitive zones to revise its regulatory framework and make further improvements.
1.3 The Clearing SystemHKMA established the Real Time Gross Settlement (RTGS) system in December 1996, which
provides smooth and e"cient settlement for interbank payments. The Hong Kong Dollar RTGS
system has a single-tier settlement structure with all banks maintaining settlement accounts with
HKMA. All RTGS payment transactions are settled in real time across the books of HKMA.
HKMA introduced the US dollar RTGS system and euro RTGS system in August 2000 and April
2003 respectively. These allow participants to settle US dollar and euro transactions real time in the
Asian time zone. By making use of the payment versus payment (PvP) linkages between the three
RTGS systems, foreign exchange settlement risk caused by the time gap between the settlement of
Hong Kong dollar, US dollars and the euro can be eliminated. Since their implementation, the US
Dollar and euro Clearing Systems have operated smoothly. The Renminbi Settlement System,
launched in March 2006, was upgraded to Renminbi RTGS system in June 2007 to cater for the
expanded renminbi business in Hong Kong. In November 2006, HKMA and Bank Negara
Malaysia launched a cross-border PvP linkage such that both legs of the foreign exchange
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transactions between the US dollars and Malaysian Ringgit can be settled simultaneously in the
Asian time zone.
Hong Kong follows the British system where checks (‘cheques’) may be used by the bearer
unless the words ‘or bearer’ are crossed out and may be cashed, unless two parallel lines are drawn
on the face of the check - which means they can only be deposited into the named account.
Hong Kong dollar, US dollar or Renminbi checks issued by local banks generally clear overnight.
Foreign checks issued by overseas financial institutions clearing times depend on your relationship
with your banker: Sometimes banks will buy a foreign check immediately, while at other times
overseas checks take three weeks to clear. Many banks now charge a small fee if you deposit a
foreign check into a foreign currency account.1
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1 http://www.amcham.org.hk/hongkong/eohk/20_The_Banking_Sys.pdf
PART II: Current Investment Regulations in Hong KongHong Kong has a well developed fund management sector with a sophisticated regulatory
framework, which is internationally regarded as being of a high standard. According to KPMG`
report2, as at 31 December 2007, 2,123 unit trusts or mutual funds had been authorized by the SFC,
with a net asset value of USD 1,077 billion under management.
2.1 Types of funds in Hong Kong
The collective investment funds which are originated in Hong Kong should take the organization of
either mutual funds or unit trusts. They could choose to be authorized or not authorized by the
Hong Kong Securities and Futures Commission(SFC). However, if they would like to be
marketed to the public and to be listed in the Stock Exchange, they must first be authorized and
subject to a strict regulation control. Authorized funds could be further classified into the following
categories3:
• Equities funds
• Bonds funds
• Unit portfolio management funds(invest in other funds & trusts)
• Money market/cash management funds
• Warrant funds
• Leveraged funds
• Futures and option funds
• Guaranteed funds
• Index funds
• Hedge funds
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2 KPMG(2009), “International funds and fund management survey”, p4, website: http://www.kpmg.com/Global/IssuesAndInsights/ArticlesAndPublications/Pages/Funds-and-fund-management.aspx
3 Hong Kong Securities and Futures Commission website: http://www.sfc.hk/sfc/html/EN/
• Index tracking exchange traded funds
• Real estate investment trusts
Each type of funds will be subject to di!erent regulation controls. Some will be controlled more
strictly by SFC, some will be less controlled according to their characteristics.
2.2 Regulations and laws
Regulation body
The authorizing body for unit trusts and mutual funds is SFC under Section 104 of the Securities
and Futures Ordinance. To administer the Unit Trust Code and authorize a trust or fund through
application, a Committee on Unit Trusts is established under SFC. Any matter relevant to a trust
or fund authorization should be through this Committee.
The Unit Trust Code
Code on Unit Trusts and Mutual Funds(a.k.a. Unit Trust Code) applies to authorized funds by
SFC. The Code establishes guidelines for the authorization of collective investment schemes in the
nature of mutual fund corporations or unit trusts, and codifies practices established in relation to the
former Code on Unit Trusts and Mutual Funds published pursuant to the Securities and Futures
Ordinance. However, the Code does not have the force of law4.
Advantages of authorization
In compliance with the Unit Trust Code, a trust or fund could apply for the SFC`s authorization.
According to KPMG`s report, The major advantages resulting from authorization are:
• advertising and marketing to the general public in Hong Kong is permitted;
• exemption is given from Hong Kong profits tax; and
• listing on the Hong Kong Stock Exchange is greatly facilitated.
Money Laundering
The Guideline on Money Laundering issued by the Hong Kong Monetary Authority expects to
minimize the chances to launder money earned from criminal activities and to finance terrorist
activities. In particular institutions should verify the true identity of all customers requesting the
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4 Abstract of Code on Units Trusts and Mutual Funds, first edition pursuant to the Securities and Futures Ordinance (Cap.571), Securities and Futures Commission(2003)
institution’s services. In particular, the following areas should be verified according to the
Guideline:5
• Client identification
• Record keeping
• Period of retention of records
• Recognition and reporting of suspicious transactions
• Procedures for disclosure
• Education and training
Borrowing of funds or trusts
According to the Unit Trust Code, the maximum borrowing of a fund must not exceed 25 percent
of its net asset value, except that for a capital markets scheme, borrowing must not exceed 10
percent of its net asset value.6
Investment Restrictions7
According to KPMG`s report, the principal restriction on the investment powers of authorized
funds in Hong Kong, other than warrant funds, leveraged funds, futures and options funds, real
estate investment trusts are:
• prohibition on investment in real estate except for shares in real estate companies and interests
in real estate investment trusts (REITs);
• holding of securities issued by any single issuer may not exceed 10 percent of fund’s net asset
value, except that this rule is relaxed in the case of government and other public securities;
• the fund may not hold more than 10 percent of any class of security issued by any single issuer,
except that this rule is relaxed in the case of government and other public securities;
• the fund may not have more than 15 percent of net asset value invested in unquoted or unlisted
securities;
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5 Guideline on Money Laundering, Hong Kong Monetary Authority (1997)
6 Code on Units Trusts and Mutual Funds, Securities and Futures Commission(2003)
7 KPMG(2009), “International funds and fund management survey”, p5, website: http://www.kpmg.com/Global/IssuesAndInsights/ArticlesAndPublications/Pages/Funds-and-fund-management.aspx
• options, warrants, and financial futures can be bought for hedging purposes, but the following
restrictions apply to other activities involving these financial instruments:
• no more than 15 percent (options and warrants) or 20 percent (financial futures) of net asset value
can be invested in such instruments for purposes other than hedging;
• writing of call options on portfolio investments may not exceed 25 percent of a fund’s total net
asset value in terms of exercise price;
• holdings of units or shares in other collective investment funds cannot exceed in aggregate 10
percent of net asset value but this is relaxed in the case of a feeder fund or a unit portfolio
management fund;
• there are also restrictions on short selling, investment in nil or partly-paid shares and in securities
in which directors or o"cers of the management company have an interest; and
separate restrictions apply to specialized funds, such as unit portfolio management funds, money
market/cash management funds, warrant funds, leveraged funds, futures and options funds,
guaranteed funds, index funds, hedge funds, index tracking exchange traded funds, and real estate
investment trusts.
Managers, trustees, and custodians
For authorization purpose, every mutual fund or unit trust is required to appoint a management
company (except for self-managed funds). According to Code on Unit Trusts and Mutual Funds
5.2, a management company must:8
1. be engaged primarily in the business of fund management;
2. have su"cient financial resources at its disposal to enable it to conduct its business e!ectively
and meet its liabilities; in particular, it must have a minimum issued and paid-up capital and
capital reserves of HK$1 million or its equivalent in foreign currency;
3. not lend to a material extent; and
4. maintain at all times a positive net asset position.
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8 Chapter 5.2, Code on Units Trusts and Mutual Funds, Securities and Futures Commission(2003)
Also according to Code on Unit Trusts and Mutual Funds 4.1&4.2&4.3, every collective
investment scheme for which authorization is requested must appoint a trustee/custodian
acceptable to the Commission. And a trustee/custodian must be:9
(a) a Hong Kong licensed bank; or
(b) a trust company which is a subsidiary of such a bank; or
(c) a registered trust company; or
(d) a banking institution or trust company incorporated outside Hong Kong which is acceptable to
the Commission.
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9 Chapter 4.1&4.2&4.3, Code on Units Trusts and Mutual Funds, Securities and Futures Commission(2003)
PART III: Reform Proposal2.1 Separation of ACU and DBUIt was recognized that given appropriate support and incentives, a market similar to the Eurodollar
could be developed in Hong Kong. As a site for this o!shore market, Hong Kong o!ers several
advantages including a sound financial infrastructure, an excellent communications network, a
comprehensive legal system, a stable government and a geographical location with a time zone
advantage.
To allow for better domestic monetary control and encourage o!shore finance activities, Asian
Currency Unit (ACU) and Domestic Banking Unit (DBU) should be set up to separate the
booking for Hong Kong Dollar and other currencies such as US Dollar and RMB . Any financial
institution seeking approval to operate in US dollar market or RMB market is required to set up a
separate book-keeping unit for such transactions.
ACU is permitted to accept deposits from, and lend to other banks and non-bank customers in all
currencies other than the Hong Kong dollar.
ACU should be subject to less regulatory rules and requirement so that the o!shore market could
be developed by o!ering more incentive for investors to borrow and lend foreign currencies.
Rationale for allowing banks to operate ACUs
ACUs are designed to facilitate the funds flows denominated in non-HKD currencies. With the
development of China’s economy, there will be plenty of investment opportunities in China, which
provides chances for Hong Kong to be the intermediary between foreign investors and Chinese
fund-seekers. To attract mutual funds as well as special investments such as hedge funds to set up in
Hong Kong, incentives to transact in foreign currencies should be provided.
The ACU is subject to fewer regulatory rules and requirements than the DBU. Banks are therefore
able to accept non-HKD deposits and lend out non-HKD funds more freely through the ACU,
paving the way for the creation of the ADM in Hong Kong (the counterpart of the eurodollar
market in London). In addition, unlike in the DBU, statutory reserves need not be maintained for
deposit liabilities in the ACU.
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Funds raised in the ACU from overseas bank and non-bank depositors will be largely re-channelled
out of Hong Kong through placements with banks and loans to non-bank borrowers outside Hong
Kong.
Rationale for allowing banks to operate DBUs
After the 1998 financial crisis in Hong Kong, the importance of maintaining a robust currency to
protect Hong Kong’s economy has been enhanced. In the process of developing into an o!shore
finance center, Hong Kong should be cautious of internationalizing its own currency as Hong
Kong’s own economic fundamentals are not su"cient to resist a speculative attack.
Restriction on DBUs can limit the extension of bank credit in HKD to non-residents except for the
purpose of funding economic activities. In addition, some restrictions should be placed on interbank
HKD derivatives, such as FX, currency and interest rate swaps and options, which could facilitate
the leveraging or hedging of HKD position.
These restrictions can make it harder and more costly for potential speculators to short the HKD.
However there may be drawbacks: the safeguards put in place under the policy might hinder the
development of our capital markets, in particular the bond markets in Hong Kong. In addition,
despite the HKD being freely convertible, some potential foreign investors might be deterred from
investing in Hong Kong as they did not fully understand the policy.
2.2 Converge of different regulatory bodies We advice Hong Kong government to establish a new institution called “Financial Services
Authority(FSA)” to be responsible for the overall supervisory work for all legal financial institutions
and markets. Di!erent currently-existed regulatory bodies, for example, HKMA, should be under
its management to promote better cooperation between each supervisory body towards
comprehensive issues. The FSA should be an independent organization responsible for regulating
financial services in Hong Kong.
All around the world, there are many examples could be learned to promote this reform. Although
there are many countries adopting a regulatory mode just as what is in US, which is a separated
supervisory power, such as Hong Kong, China, Canada and Euro-Countries, there are still
countries which only have a overall supervisory power to regulate the financial market, such as the
UK, Japan and Singapore, to be frank, these countries are not as seriously influenced as the
countries using separated regulatory framework by the financial crisis.
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Take Japan for example. The organization chart in the appendix shows how Financial Services
Agency in Japan works10. We could find that all the partial regulatory bodies are under the single
control of FSA. There are no more independent bodies of Monetary Authorities, SFC and
Insurance Commissions. The conflicts aroused from supervisory process between each division
could be coordinated within the FSA. As a result, the whole responsibility for regulating the
financial institutions are taken by the FSA, thus it is very clear.
A more comparable example is the regulatory framework in Singapore as
• Singapore is the biggest Asian o!shore money center, as Hong Kong is moving into an o!shore
fund center, there is much experience that could be learned from a existing successful one.
• Both Hong Kong and Singapore are important financial centers in Asian region, especially in
South Asia zone, and they are competitive from history experience.
Singapore is a well-developed o!shore financial center, the transaction volume is huge in Asia,
according to Monetary Authority of Singapore(MAS),
• The Size of Singapore corporate debt market is about S$ 168 billion in 200811
• The Asset Under Management(AUM) as at the end of 2008 stood at S$864 billion12
In Singapore, there is only one financial supervisory body who take in charge of overall regulatory
work of Singapore financial market, Monetary Authority of Singapore(MAS). Generally, MAS has
the following functions:13
1. To act as the central bank of Singapore, including the conduct of monetary policy, the issuance
of currency, the oversight of payment systems and serving as banker to and financial agent of the
Government
2. To conduct integrated supervision of financial services and financial stability surveillance
3. To manage the o"cial foreign reserves of Singapore
4. To develop Singapore as an international financial centre
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10 The Financial Services Agency Japan website, http://www.fsa.go.jp/en/index.html
11 The Singapore Corporate Debt Market Review 2008, Monetary Authority of Singapore, http://www.mas.gov.sg/resource/eco_research/surveys/Debt08.pdf
12 2008 Singapore Asset Management Industry Survey, Monetary Authority of Singapore, http://www.mas.gov.sg/resource/eco_research/surveys/AssetMgmt08.pdf
13 Monetary Authority of Singapore website, http://www.mas.gov.sg/about_us/Departments_in_MAS.html
One special department within MAS called “Prudential Policy Department”, it takes overall
strategies in the supervisory of each section of the financial market. As the illustration of this
department shown on the website of MAS:14
“The Prudential Policy Department (PPD) is responsible for formulating capital and prudential
policies for banks, insurance companies and securities firms to promote a sound yet dynamic
financial sector.# It works to achieve a more harmonized regulatory framework that will minimize
gaps and arbitrage, and facilitate a more integrated risk-based supervisory approach.”
It is in our consideration to establish a similar department in Hong Kong to carry out the whole
strategies in supervisory work.
2.3 Internationalization of policies and standards
We suggest the regulatory body in Hong Kong adopt more international standards to make the
regulatory framework more global and well recognized. Although it is always the case that local
government should enact the regulation according to local situations, sometimes this kind of
regulation will cause much trouble to be recognized by the international investors and therefore
discourage them to invest in Hong Kong. For example, to deal with di!erent tax regulation
frameworks for entering a potential emerging market will introduce a large transaction cost
(research), which will decline the interest for foreign investors if it is too complicated to be cost-
e!ective.
However, international standards are more recognized by institutional investors around the world.
Also, it is commonly accepted by foreign investors. In terms of reducing transaction cost, it is better
for the regulatory body to introduce more internationally-accepted standards into Hong Kong.
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14 Monetary Authority of Singapore website, http://www.mas.gov.sg/about_us/Departments_in_MAS.html
Appendix 1. Lists of Laws and regulations governing authorized funds in Hong
Kong:15
• Securities and Futures Ordinance
• Securities and Futures (Client Money) Rules
• Securities and Futures (Client Securities) Rules
• Securities and Futures (Financial Resources) Rules
• Securities and Futures (Accounts and Audit) Rules
• Securities and Futures (Keeping of Records) Rules
• Code on Unit Trusts and Mutual Funds (the Unit Trust Code)
• Code on Real Estate Investment Trusts
• Code on Conduct for Persons Licensed by or Registered with the Securities and Futures Commission (the General Code)
• Rules Governing the Listing of Securities (Listing Rules) (if listed)
• The Drug Tra"cking (Recovery of Proceeds) Ordinance and the Organized and Serious Crime Ordinance (relevant to the operations of funds as funds might be used to launder money arising from criminal activities as specified in the ordinances)
• Code on Pooled Retirement Funds
• Fund Manager Code of Conduct
• Management Supervision and Internal Control Guidelines for persons licensed by or registered with the SFC
• Guidance Note on Internet Regulation
• Guidance Note on the Application of the Electronic Transactions Ordinance to Contract Notes
• Guidance Notes for Persons Advertising or O!ering Collective Investment Schemes on the Internet
• Guidelines for Registered Persons Using the Internet to Collect Applications for Securities in an Initial Public O!ering
• Mandatory Provident Funds Schemes Ordinance
• Code on MPF Investment Funds
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!"#$%&&'()*+,#-.#/0123455678#9:;<+(;'=>;'?#@%;,A#';,#@%;,#&';'B+&+;<#A%(C+.D8#E+-A)<+F#GHIFJJEEEKLI&BKM>&J2?>-'?J:AA%+AN;,:;A)BG<AJN(=M?+AN;,0%-?)M'=>;AJ0'B+AJO%;,AP';,P@%;,P&';'B+&+;<K'AIQ
• Code on Disclosure for MPF Investment Funds
• SFC Code on Mandatory Provident Fund (MPF) products
• Guidelines for Review of Internal Controls and Systems of trustees/custodians
• Fit and Proper Guidelines
• Guidelines on Competence
• Guidelines on marketing materials for listed structured products
• Registration Guidelines for intermediaries advising on securities incidental to the marketing of MPF schemes only.
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2. Organization chart of Financial Services Agency (Japan)
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Reference• American Chamber of Commerce in Hong Kong , “The Banking System”, website: http://
www.amcham.org.hk/hongkong/eohk/20_The_Banking_Sys.pdf
• KPMG(2009), “International funds and fund management survey”,website: http://www.kpmg.com/Global/IssuesAndInsights/ArticlesAndPublications/Pages/Funds-and-fund-management.aspx
• Hong Kong Securities and Futures Commission website: http://www.sfc.hk/sfc/html/EN/
• Securities and Futures Commission(2003), Code on Units Trusts and Mutual Funds, first edition pursuant to the Securities and Futures Ordinance (Cap.571), Electronic version: http://www.google.cn/search?hl=zh-CN&client=a!-os-maxthon&hs=ZxG&q=Code+on+Units+Trusts+and+Mutual+funds+HK&aq=f&oq
• Hong Kong Monetary Authority (1997), Guideline on Money Laundering, Electronic version: http://www.info.gov.hk/hkma/eng/public/qb200211/supplement.pdf
• The Financial Services Agency Japan website, http://www.fsa.go.jp/en/index.html
• The Singapore Corporate Debt Market Review 2008, Monetary Authority of Singapore, http://www.mas.gov.sg/resource/eco_research/surveys/Debt08.pdf
• 2008 Singapore Asset Management Industry Survey, Monetary Authority of Singapore, http://www.mas.gov.sg/resource/eco_research/surveys/AssetMgmt08.pdf
• Monetary Authority of Singapore website, http://www.mas.gov.sg/
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