Page 62 - 期货和衍生品行业监管动态（2023年11月刊）

期货和衍生品行业监管动态

Counter-Terrorist Financing Ordinance, the Guideline on Anti-Money Laundering and

Counter-Terrorist Financing (AML Guideline) and the Code of Conduct (Notes 5 & 6).

In deciding the disciplinary sanctions against LFL, the SFC has taken into account

that:

 LFL’s failures to diligently monitor its clients’ activities and put in place

adequate and effective AML/CFT systems and controls are serious as they

could undermine public confidence in, and damage the integrity of, the market;

 LFL has taken remedial measures to enhance its internal systems and controls

for continuous monitoring and identifying suspicious transactions;

 a strong deterrent message needs to be sent to the market that such failures are

not acceptable;

 LFL cooperated with the SFC in resolving the SFC’s concerns; and

 LFL has an otherwise clean disciplinary record.

Notes:

1. LFL is licensed under the Securities and Futures Ordinance to carry on Type 2

(dealing in futures contracts) and Type 5 (advising on futures contracts)

regulated activities.

2. CSSs are trading software developed and/or designated by the clients that

enable them to conduct electronic trading through the Internet, mobile phones

and other electronic channels.

3. The CSSs were connected to LFL’s broker supplied system (BSS) through

application programming interface (a set of functions that allows applications

to access data and interact with external software components or operating

systems). BSSs are trading facilities developed by exchange participants or

vendors that enable the exchange participants to provide electronic trading

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