Hong Kong Region Specific Terms

With respect to Services provided by Thunes HK, the following provisions shall apply and are included as part of the legally binding Agreement between you and Thunes:

1.      The following definitions shall be included in the Definitions to the Terms and shall have the following meaning in these Hong Kong Region Specific Terms unless the context requires otherwise:

AMLO means the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).

Deposit has the meaning given to that term in the Banking Ordinance (Cap. 155).

PSSVFO means the Payment Systems and Stored Value Facilities Ordinance (Cap. 584).

Relevant Money means any money received by Thunes HK from or on behalf of a Customer in the course of its provision of the Services.

Stored Value has the meaning given to that term in the PSSVFO.

Stored Value Facility has the meaning given to that term in the PSSVFO.

2.      A new Section 3(g) is included as follows:

3(g). Thunes HK is licensed under the AMLO as a “money service operator” by the Hong Kong Customs and Excise Department for the provision of “remittance services” (as such terms are defined under the AMLO) with licence number 22-02-03095. Thunes HK is not licensed in Hong Kong to provide, and does not provide, any other regulated services, including (without limitation) “money changing services” as defined under the AMLO, services regulated under the Banking Ordinance (Cap. 155) or services regulated under the PSSVFO (including issuing Stored Value Facilities).

Apart from Thunes HK, no other Thunes entity or Affiliate carries on the provision of regulated services in Hong Kong, or offers, promotes or advertises any such services provided by any Thunes entity or Affiliate in Hong Kong or to Hong Kong persons.

3.      The following shall be included at the end of Section 7(b):

You further acknowledge and agree that any interest earned from the maintenance of your Relevant Money in a relevant banking or safeguarding account (“Safeguarding Account”) will not accrue to you and will instead be retained by Thunes. Such interest will not constitute Relevant Money and you will not be entitled to such interest.

4.      The following shall be added to Section 7 as a new subparagraph (h):

7(h). You acknowledge, understand and agree that: 

a.      The Relevant Money that we receive or hold on your behalf from time to time may be commingled with the Relevant Money that we receive from or on behalf of our other Customers in Safeguarding Accounts. Such commingling of your Relevant Money with the Relevant Money of other Customers in Safeguarding Accounts may give rise to some risks. While we will take steps to ensure that there are clear records kept and robust periodic reconciliation, some risks of such commingling may include: 

1.  In the event of insolvency of Thunes or any of its relevant banking or safeguarding partners, there is a risk that you may not be able to recover your Relevant Money fully;
2. There may be challenges in asserting your claims over the amount of Relevant Money owed to you and there may be a risk of dispute among Customers; and
3. There may be delays in making a claim to recover your Relevant Money, for example if a liquidator freezes a relevant Safeguarding Account.

b.      You acknowledge and agree that Thunes may, notwithstanding any provision in the Agreement, withdraw your Relevant Money from a relevant Safeguarding Account for any purpose permitted under Applicable Law.

c.      You acknowledge and agree that neither any Relevant Money that we receive or hold on your behalf (whether held in a relevant Safeguarding Account or otherwise) nor any amounts standing to the credit of your Thunes Account from time to time are Deposits or Stored Value and that your Thunes Account is not a Stored Value Facility.

5.      A new Section 16(a)(xix) is included as follows:

16(a)(xix). you are not “dealing as a consumer” (for the purposes of, amongst other things, the Supply of Services (Implied Terms) Ordinance (Cap. 457), the Control of Exemption Clauses Ordinance (Cap. 71) or the Unconscionable Contracts Ordinance (Cap. 458)) and you hereby acknowledge and agree that you may not continue to use the Services if you deal as a consumer at any time.

Last modified: July 21, 2026