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Role of the HKMA

The HKMA has taken a number of steps to deal with the account opening issue encountered by some corporate customers. Our aim is to maintain a robust AML/CFT regime in Hong Kong which does not undermine access by legitimate businesses and ordinary citizens to basic banking services.

Is the account opening issue prevalent in Hong Kong?

Based on the comments and information collected by the HKMA, the difficulties faced by overseas small and medium-sized enterprises (SMEs) and start-ups in opening bank accounts do not appear to be an industry-wide issue.  The issue is pertinent amongst one or two international banks which are usually the first port of call for many companies seeking to open a bank account.  There has been some improvement in the situation after the HKMA issued a circular on “De-risking and Financial Inclusion” to all banks in September 2016.

What has the HKMA done to address the account opening issue?

The HKMA attaches great importance to the issue concerning difficulties in opening bank accounts, and has embarked on a series of follow-up work, including:

  • We have engaged various stakeholders including overseas and local chambers of commerce and SME associations to have an in-depth and full understanding of the situation, gathered the details of specific incidents related to difficulties in opening bank accounts, and followed up the cases with banks accordingly.
  • The HKMA issued a circular on “De-risking and Financial Inclusion” to all banks on 8 September 2016, reiterating that banks should adopt a “risk-based” approach in handling account opening applications and conducting ongoing due diligence for existing customers. Banks should also ensure a reasonable and fair treatment of all existing and prospective customers, including:
    • enhancing the transparency of account opening and CDD process by setting out clearly the  information and documentation required for the CDD process, explaining the rationale for the information requested, assisting customers in taking steps or providing alternatives that can help satisfy the CDD process, and introducing review mechanisms for unsuccessful applicants;
    • maintaining effective communication with customers by, for example, providing interim updates about the progress of their applications, timely feedback of the results of their applications, and where an application is rejected, the reason for rejection as appropriate.

    Banks should also provide adequate training to their frontline staff to ensure consistent implementation of the relevant measures.
  • The HKMA further issued “Frequently Asked Questions on CDD” on 29 September 2016 and 25 May 2017 to clarify with banks some commonly misinterpreted CDD requirements. These frequently asked questions documents have been consolidated into “Frequently Asked Questions in relation to AML/CFT”, developed by the Hong Kong Association of Banks with input from the HKMA, issued on 31 October 2018.
  • The HKMA also issued a circular on “Guideline on Anti-Money Laundering and Counter-Terrorist Financing - Address Verification Requirements” on 11 October 2017 to inform banks that the address verification requirements set out in the Guideline on Anti-Money Laundering and Counter-Terrorist Financing (for Authorized Institutions) would be formally removed tentatively in 2018. Subsequently, the Guideline was revised in October 2018 and banks are only required to collect the address information of the customers.
  • With the concerted efforts of the HKMA and the banking industry, tiered account services that aim to enhance customer experience – “Simple Bank Accounts” (or “SBAs”) – have been launched in April 2019 to provide an additional option for business customers which require only basic banking services. With narrower service scope, the risks involved in SBAs would be relatively lower and hence less extensive CDD measures to be carried out at account opening.
  • We have set up a task force to handle public opinions and queries regarding difficulties in account opening and updating account information, and have developed a dedicated page on the HKMA website for communication with stakeholders.
  • The HKMA has commenced a mystery shopping programme relating to banks’ account opening processes at the end of 2017, to assess the effectiveness of measures adopted by banks in enhancing customer experience, and is also conducting a round of thematic reviews to identify issues and good practices for sharing with the industry.

What does it mean by banks applying a “risk-based” approach in account opening?

“Risk-based” means that banks should differentiate the risk levels of individual customers in accordance with their backgrounds and circumstances, and apply proportionate risk-mitigating and CDD measures, rather than simply adopting a “one-size-fits-all” approach to all the customers in the approval process.

Opinions or queries

If you have any opinions or queries about account opening or updating of account information, please contact the HKMA.

Telephone: (852) 2878 1133
Email: accountopening@hkma.gov.hk


Reference materials


  • inSight articles:


12 Apr 2019 Tiered Account Services: A New Initiative on Promoting Financial Inclusion
31 Oct 2016 It’s hard to open a bank account, but is it also hard to maintain it?
8 Sep 2016 Pursuing financial inclusion despite challenges
5 Sep 2016 Follow-up work on issues concerning difficulties in opening bank accounts and obtaining bank loans by small and medium-sized enterprises
14 Jul 2016 From piggy bank to financial inclusion
17 Jun 2016 Bank account opening for small and medium-sized enterprises and start-ups


  • Circulars:
12 Apr 2019 Introduction of Tiered Account Services
31 Oct 2018 Frequently Asked Questions in relation to Anti-Money Laundering and Counter-Financing of Terrorism
19 Oct 2018 Amendments to Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Authorized Institutions)
23 Feb 2018 Amendments to Guideline on Anti-Money Laundering and Counter-Terrorist Financing (For Authorized Institutions)
11 Oct 2017 Guideline on Anti-Money Laundering and Counter-Terrorist Financing – Address Verification Requirements
25 May 2017 Frequently Asked Questions on Customer Due Diligence
29 Sep 2016 Frequently Asked Questions on Customer Due Diligence
8 Sep 2016 De-risking and Financial Inclusion
Last revision date: 17 April 2019
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