Verifying an overseas company: documents, owners and authority
Start with the legal customer and the rules governing your firm. Use the customer's home-country records to establish the relevant facts, then investigate what those records leave unanswered.
By Matthew Lee
A Hong Kong bank receives an application from a Kenyan company. The applicant supplies an incorporation certificate and an official search, but the search names a Singapore company as a shareholder. The person completing the application says a recent transfer has changed the ownership. The records identify a legal entity and an ownership layer, while the reported transfer explains why the review needs more evidence.
The customer’s incorporation jurisdiction determines its corporate records. The bank’s applicable Hong Kong requirements determine which facts it needs to establish and how to assess them. Kenyan evidence can therefore support a Hong Kong review without being named in Hong Kong legislation. A Singapore or Kenyan institution assesses the same records under its own rules and sector.
Establish which company is the customer
Match the name and identifier on the application, contract and registry evidence. A group brand, registered business name and incorporated company can refer to different persons. Incorporation evidence establishes a formation event; a record describing the relevant current position helps the reviewer assess continued existence, registered particulars and relevant changes. Keep the information’s effective date alongside its issue or retrieval date.
For Hong Kong authorised institutions, the HKMA guideline’s paragraphs 4.3.6–4.3.7 address legal-person particulars and verification using reliable, independent evidence. The country-to-document map helps identify source records for the Kenyan customer. It shows potential contributions and remaining gaps; document availability alone does not settle their sufficiency for a particular file.
Connect the documents to the evidence question
Different records answer different questions. Collect evidence that establishes the relevant facts and supports investigating discrepancies under the reviewer’s rules.
| Evidence question | Records that can contribute | What still needs assessment |
|---|---|---|
| Legal identity and recorded existence | Incorporation evidence and relevant current registry record | Correct legal person, source reliability, legal form and effective dates |
| Direct shareholders or members | Holder-bearing profile, filed return or current member register | Whether the product covers all relevant holders and later changes |
| Natural-person ownership and control | Evidence for each corporate layer, ownership chart and relevant control records | The reviewing regime’s test, non-share control and required verification |
| Person acting and their authority | Representation particulars, mandate or resolution and individual identity evidence | Powers for this relationship, execution and any joint-signature conditions |
| Purpose and expected activity | Customer explanation and relevant licences or commercial evidence | Whether the proposed relationship and transactions fit the explanation |
| Risk and ongoing review | Relevant screening, risk enquiries, updates and transaction records | Match decisions, additional measures, monitoring and retention |
Follow the ownership enquiry
In the example, the Singapore shareholder is another company rather than the final individual. Its ownership evidence becomes the next enquiry. The customer’s chart explains the proposed chain, while relevant records corroborate the holdings and control rights. HKMA paragraph 4.4.14 addresses understanding intermediate ownership layers; the reviewer also assesses voting arrangements, nominees and other means of control under the applicable beneficial-owner criteria.
The reported transfer creates a separate timing problem. Compare the search’s underlying position with the current member register and relevant transfer evidence. A newly downloaded document can still describe an earlier filing. Once the relevant individuals have been identified, apply the required identity-verification measures. A shareholder’s name or partial identifier in a corporate record does not complete that verification.
Resolve authority, purpose and risk separately
The applicant may be a director, an employee or an external representative. Their position helps explain the application, but the reviewer needs to establish their authority for this relationship. HKMA paragraph 4.5.2 separately addresses the identity and authority of a person acting for the customer. A mandate, relevant governance provisions and representation conditions connect the proposed instruction to the company.
The business explanation then gives the expected activity against which the relationship can be assessed. Relevant licences and contracts can corroborate it, while screening and risk enquiries address different concerns. Obtain further funding or wealth evidence when the applicable rule and risk require it. Record unresolved issues and the onboarding decision, and keep the relationship under the required ongoing review.
Request the source records
For the corporate-registry email workflow, an approved organisational sender can email agent@fill-easy.com with the exact company, jurisdiction, identifier, named records and case reference. Request availability, price and expected turnaround. Company-held or restricted records may require client cooperation and an authorised route; describe them separately from the registry order.
Please confirm availability and obtain the Kenyan company record for [legal name], registration number [number], and the relevant ownership filings for [Singapore shareholder], UEN [number]. Case reference: [reference]. Please include source references and effective dates where supplied.
The CorpVerify documentation (opens in a new tab) explains API delivery; country coverage (opens in a new tab) lists products. The separate KYC email agent (opens in a new tab) concerns China individual checks. Regional verification guides explain the evidence issues that remain after the records arrive.