Opening a bank account in Hong Kong

An account here is opened under one ordinance and one supervisory guideline, and the pair decides both what the bank must find out and what it may not demand. One line matters more than the rest: a business relationship always exists whenever an account is booked in the territory, so the full set of checks applies from the first day.

What else we handle in the territory sits on the Hong Kong page; the account in other jurisdictions is under bank account opening.

What the bank has to establish

• Corporate records: the certificate of incorporation, a registry report, the constitutional document, and evidence of good standing for a company registered abroad.
• The address on the register and the place the business is actually run from, where those are two different addresses.
• The beneficial owners, with identification for each and the ownership and control structure behind them.
• The purpose and intended nature of the account: expected activity, business model, and the way the company earns.
• The person acting for the customer, with identification and the document that authorises them.

The clock on verification

Identity is verified before or while the relationship is opened. Where a bank exceptionally allows it afterwards, the guideline names the outer edges: verification no later than 30 working days after the relationship starts, suspension if it is still unfinished at that point, and termination if it is unfinished at 120 working days.

Where the ordinance puts its thresholds

What a bank should not ask of you

Everyone in the room

Requiring all directors and beneficial owners of an overseas company to be present at opening is named by the supervisor as a request out of proportion to risk.

A local certifier for every page

Nor should a bank insist that every document of an overseas company be certified by a certifier inside the territory, or expect a local office from every applicant.

A start-up's ten-year record

A young company should not be asked for the same depth of track record, business plan and revenue projection as a long-established one, or refused on a turnover benchmark set unreasonably high.

A deposit as the price of entry

Buying an investment or insurance product and placing a large opening balance may not be made a condition of an account, or linked to how fast the application moves.

A narrower account for a narrower need

The supervisor encourages banks to offer simple business accounts for customers who need only basic services. The scope is smaller, the risk is lower, and less extensive checking is carried out at opening. A company that collects payments and pays suppliers is describing exactly that need.

When an application is turned down

A bank should in general give reasons for refusing, and each bank runs a mechanism for re-examining an unsuccessful application, so a refusal can be taken back to the same institution. The regulator also keeps a dedicated address and hotline for enquiries about account opening.

Sources: when checks are required, the thresholds and the 30 and 120 working-day limits — chapter 4 of the supervisory guideline and schedule 2 to the ordinance; the information collected, the requests named disproportionate and the simple accounts — the regulator's account opening pages.