Home / Resources / Licensing and AML

Licensing and AML ยท FAQ

Why we ask for KYC documents

What Hong Kong anti-money laundering law requires of a licensed service provider, and how to make onboarding quick and straightforward.

By DBMS GlobalLast reviewed: 18 October 2026

The answer first

Before we can act for you, Hong Kong law requires us to know who you are, who ultimately owns and controls your company, and what you intend to do. As a licensed Trust or Company Service Provider (TCSP), we must carry out customer due diligence (CDD), often called KYC ("know your customer"), under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). We are supervised on this by the Companies Registry.

KYC is a legal requirement for us, not a choice: we cannot start work, or continue it, until it is complete. Your information is kept confidentially, and the same information is usually needed by banks, so preparing it well once saves time later.

What the law requires us to do

RequirementWhat it means for you
Identify and verify the customerWe need identity documents for individuals, and incorporation documents for companies
Identify the beneficial ownersWe must identify the individuals who ultimately own or control the client (for a company, normally anyone with more than 25%) and take reasonable steps to verify them
Understand the purpose of the relationshipWe ask what the company will do, where and with whom
Screen for sanctions and politically exposed personsWe check names against sanctions lists and identify politically exposed persons and their close associates
Apply enhanced measures where risk is higherFor example, source of funds and source of wealth evidence, and senior management approval
Monitor on an ongoing basisWe periodically refresh documents and ask about changes in ownership or activity
Keep recordsWe keep CDD records throughout the relationship and for at least 5 years after it ends
Key takeawayIf CDD cannot be completed, the law does not allow us to start the relationship or continue it. This is why we ask for documents before any filing is made.

Why we sometimes ask for more

The level of checks depends on risk. We may ask for more information where, for example:

  • the ownership structure has several layers, trusts or nominee arrangements;
  • a shareholder, director or beneficial owner is a politically exposed person, or closely associated with one;
  • the business involves higher-risk sectors, cash-intensive activity or jurisdictions identified as higher risk;
  • the expected transactions are large or unusual for the business described;
  • documents are inconsistent, or information changes without explanation.

Asking for more is not an accusation. It is how the law expects a licensed provider to manage risk, and the same questions are usually asked by banks.

Certified copies

Where you cannot show us original documents in person, we ask for copies certified as true copies by a suitable certifier, for example a lawyer, notary public or certified public accountant. The certification should show the certifier's name, profession, contact details, signature and date. Documents not in English or Chinese need a certified translation.

Common causes of delayProof of address older than 3 months, or showing a different address from the one given. Expired or partly illegible identity documents. Missing documents for a corporate shareholder's own owners. Certification without the certifier's details or date.

Your information and confidentiality

  • We use your information to meet our legal obligations and to provide the services you engage us for.
  • We handle personal data in line with the Personal Data (Privacy) Ordinance (Cap. 486) and our privacy policy.
  • We may be required by law to report suspicious transactions to the authorities, and the law prohibits us from disclosing that such a report has been made.
  • You must tell us promptly about changes in ownership, control, directors or the nature of the business.
How DBMS Global can help
  • A clear, tailored document checklist at the start, so you know exactly what is needed.
  • Review of draft documents before you arrange certification, to avoid repeat requests.
  • One named point of contact for all KYC questions.
  • Periodic refreshes kept simple and scheduled in advance.

Our KYC document checklist sets out the standard documents for individuals and companies.

Official references

  • Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), Schedule 2
  • Companies Registry: Guideline on Compliance of AML/CTF Requirements for TCSP Licensees, www.cr.gov.hk
  • Personal Data (Privacy) Ordinance (Cap. 486)