Corporate account opening at Hong Kong banks

Hong Kong banks verify corporate customers, their beneficial owners and account operators under AMLO and HKMA requirements. For overseas companies, obtain company records from the country of incorporation. The bank's CDD requirements remain those of Hong Kong.

Establish the customer and the proposed account

The application supplies the legal name, registration details, addresses and business description. Independent company records support verification of identity, legal form, current existence and governing powers. HKMA paragraphs 4.3.6–4.3.7 describe those enquiries.

The Hong Kong registry guide explains Company Particulars and filings; the Kenya guide explains BRS records. For a branch, obtain the local registration and home-company records.

Ask which payments the company expects to make and receive: counterparties, amounts, frequency and countries. Request contracts or invoices to support details that need checking, such as another company collecting customer payments on its behalf.

Identify the owners and account operators

Under HKMA paragraphs 4.4.6 and 4.4.9, the corporate beneficial-owner test covers more than 25% of shares or voting rights and ultimate management control. The bank identifies the relevant individuals and takes reasonable measures to verify them. If nobody meets the definition, it identifies and takes reasonable measures to verify the relevant senior managing officials.

For corporate shareholders, obtain each intermediate company's ownership records until the relevant individuals are identified. Use a dated ownership chart to record the chain and nominee or voting agreements to establish rights absent from the shareholder records.

Under paragraph 4.5, verify account operators' identity and authority. Request the board resolution or delegation naming who may issue instructions and any joint-signature requirements.

Resolve risk findings before approval

Screening results need enough detail to distinguish the applicant from a namesake. A possible sanctions match, a politically exposed person and adverse reporting raise different questions. Record how each material finding was resolved and any escalation required.

High-risk relationships require enhanced due diligence. For a non-Hong Kong PEP customer or beneficial owner, paragraph 4.9.10 requires senior-management approval and reasonable measures to establish source of wealth and funds. Other PEP categories and former officeholders have their own risk-based provisions.

Verification normally happens before or during establishment of the relationship. Paragraph 4.7 permits delayed verification only under specified conditions: effective risk management, avoiding interruption of normal business and completion as soon as reasonably practicable. The approval file should identify any permitted exception and the controls attached to it. Where required CDD cannot be completed, paragraph 4.13.1 requires refusal or termination as applicable, with reporting to the JFIU where there is relevant knowledge or suspicion.

Ongoing review and records

Keep the evidence, risk assessment, mandate and approval decision together. The expected-activity profile becomes the reference for transaction monitoring; changes in ownership or operators prompt an update to the relevant part of the file. High-risk customers receive at least annual CDD reviews under paragraph 5.3. Chapter 8 sets the retention requirements.

The bank's application also handles product terms and tax declarations. HKMA's account-opening FAQs (opens in a new tab) explain why banks may ask different questions and collect FATCA or tax-residency information.