SFC's Fund Manager Code of Conduct

SFC's Fund Manager Code of Conduct
Post-Implementation Services

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The updated terms to the Securities and Futures Commission’s (SFC) Fund Manager Code of Conduct (FMCC) came into effect on November 17, 2018. It applies to anyone licensed by or registered with the SFC to carry out asset management activities in Hong Kong.

How We Help


ACA’s post-implementation services are designed to help firms by simplifying the FMCC’s requirements and exploring the optimum way to satisfy them. Our services, which offer a risk-based approach, include:

  • Post-implementation review: to help your firm review your process against the FMCC’s requirements, identify gaps in your existing process and provide solutions appropriate to your business model.
  • Governance infrastructure: a review of your firm’s policies and governance programme to provide a report and recommendations on how to bring key stakeholders into the compliance process.
  • Risk management infrastructure: provides your firm with a framework of policies, procedures, manuals and related documentation to allow your firm to adopt an appropriate internal control structure to facilitate adherence to the updated FMCC terms.
  • Training: to help your firm maintain an environment of compliance required by the SFC, with topics including various aspects of risk management (risk identification, monitoring and mitigation), oversight of third parties and conflicts of interest management.
  • Technology: provides your firm with the support to navigate through complex compliance and operational tasks and processes, and assistance with managing your firm’s regulatory requirements.
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