Customer due diligence is the legal term behind KYC. Schedule 2 of the AMLO (Cap. 615) sets the measures in section 2: identify the customer and verify the identity from a reliable and independent source; identify any beneficial owner and take reasonable measures to verify that identity; obtain information on the purpose and intended nature of the business relationship; and identify and verify anyone who purports to act for the customer.
Section 3 says when. CDD is carried out before a business relationship is established, before an occasional transaction of HK$120,000 or more, when money laundering or terrorist financing is suspected, and when the firm doubts the information it holds. Section 5 adds ongoing monitoring, and section 20 requires the records to be kept for at least five years after the relationship ends.
Who it applies to
Financial institutions supervised by the HKMA, the SFC, the Insurance Authority and the Customs and Excise Department, and since 2018 the designated non-financial businesses: solicitors, accountants, estate agents and trust or company service providers. Each regulator publishes a guideline that says which documents and sources it accepts.
How Fill Easy relates to it
Fill Easy supplies the evidence for each element: government-confirmed identity for the individual through GovVerify, and the registry record for the company through CorpVerify. Every result records its source and retrieval time, which is what the five-year record needs to show.