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 customer due diligence (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(Last update on 24 May 2021).
  • Under the AML Guideline which was revised in October 2018, 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 comments and queries regarding account opening and maintenance, and have developed a dedicated page on the HKMA website for communication with stakeholders.
  • The HKMA engaged a service provider to undertake a mystery shopping programme (MSP) in 2018, focusing on the customer interface aspect of the account opening processes of 20 retail banks for SMEs and ethnic minority customers. The MSP complements the HKMA’s supervisory activities in assessing the effectiveness of banks’ improvement measures and practices on the ground. The HKMA issued a circular on 14 June 2019 to share with the banking industry the observations identified and require further improvements by banks in some areas. The HKMA has commenced the follow-up work with the concerned banks on the observations of the MSP.
  • As part of the follow-up work in relation to the HKMA circular on “De-risking and Financial Inclusion” issued on 8 September 2016, the HKMA conducted a thematic review between late 2017 and 2018 on banks’ application of AML/CFT measures when on-boarding SMEs customers. The HKMA issued a circular on 14 June 2019 to share key observations and good practices identified from the review 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, maintenance or updating of account information, please contact the HKMA.


(852) 2878 1133


Last revision date : 08 March 2023