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Banks should not…

When conducting CDD measures, banks should not make unreasonable requests to their customers that are disproportionate or irrelevant to risk assessment.  These may include, for example:

  • requiring all directors and beneficial owners of an overseas corporate to be present at account opening;
  • mandating that all documents of an overseas corporate are certified by a certifier in Hong Kong;
  • requesting a start-up to provide the same degree of detail on its track record, business plan and revenue projections as a long-established company;
  • expecting a Hong Kong business registration certificate for all applicants or evidence of a Hong Kong office for all overseas corporates, irrespective of business model or mode of operation;
  • requiring voluminous or very detailed information on source of wealth sometimes going back decades irrespective of the risks presented by the relationship or type of service offered (e.g. MPF account, basic banking services with small balances) which is difficult or impossible for the customer to provide; and
  • rejecting account opening based on unreasonably high benchmarks such as expected or actual sales turnover.
Last revision date: 23 March 2017
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