Customs Issues ISIL Sanctions Updates

Customs Issues ISIL Sanctions Updates

A September 2026 Customs circular mandates MSOs to immediately screen client lists against updated UN sanctions.

 

Throughout the third quarter of 2026, the Hong Kong Customs and Excise Department (C&ED) issued multiple urgent circulars to all licensed Money Service Operators (MSOs) regarding rapid updates to the United Nations Security Council (UNSC) sanctions lists. A critical update was published on September 29, 2026, heavily focusing on individuals and entities associated with ISIL and Al-Qaida.

Hong Kong Customs and Excise Department

Under the United Nations Sanctions Ordinance (UNSO) and the United Nations (Anti-Terrorism Measures) Ordinance (UNATMO), MSOs are legally obligated to conduct continuous and immediate screening of their customer databases.The C&ED emphasized in its circulars that MSOs must check all new designations against their active client lists as soon as the updates are published in the government gazette.

Hong Kong Customs and Excise Department

Failing to flag a designated terrorist associate can result in catastrophic legal consequences, license revocation, and criminal prosecution. Regulators expect MSOs to maintain sophisticated, automated screening solutions rather than relying on manual checks, given the frequency of these global updates.

Furthermore, MSOs are reminded of their strict duty to immediately submit a Suspicious Transaction Report (STR) to the Joint Financial Intelligence Unit (JFIU) if any current or historical relationship with a sanctioned entity is discovered. For compliance officers, maintaining perfectly tuned, zero-delay screening software is an absolute regulatory baseline.