Illustrative scenarioUpdated 2026-10-07
What should a Hong Kong company prepare when its bank requests a compliance review?
Responding to a Hong Kong bank compliance review.
A bank review may require updated ownership, identity, business and financial information. Confirm the request and deadline, then prepare a complete response that is consistent with the company’s records.
The scenario
A company receives a request for an ownership chart, identification documents, business evidence and recent financial information. Some documents are held by its company secretary; others are with an overseas registered agent or the finance team. The company needs to establish what the bank requires and who will prepare each item.
The review may be periodic or prompted by a change in the company or its transactions. The request alone does not establish the reason for the review or whether restrictions will follow. Verify the communication through a known bank contact before sending sensitive records.
What to check
Use the bank’s itemised request. Documents may include the certificate of incorporation, business registration certificate, annual return, register extracts, an ownership chart, identity and address evidence, contracts, invoices and financial statements. The bank determines which people and entities must be covered; its beneficial-owner tests are not automatically the same as the Significant Controllers Register (SCR) tests.
Confirm acceptable certifiers, document dates, translations and any offshore certificates before ordering them. Requirements and delivery times vary. If audited accounts are unavailable, ask whether management accounts and an explanation will be accepted; they are not an automatic substitute.
Preparing the response
Compare the requested information with the company’s registers, filed documents and financial records. Record discrepancies and obtain advice on the proper correction process. Public filings are a useful cross-check but do not replace all private company records.
Prepare an indexed response showing where each requested item can be found and explaining any outstanding documents. Ask for an extension if necessary and obtain the bank’s response in writing. An extension or continued account access is the bank’s decision; neither can be assumed.
Practical next steps
01
Verify the request and record the deadline, bank contact and response channel.
02
Assign one coordinator and list each document, its holder and its expected availability.
03
Confirm certification and offshore-document requirements with the bank before incurring costs.
04
Explain missing items promptly, request an extension where needed and retain the correspondence.
05
Seek solicitors’ advice if restrictions, suspected wrongdoing or a dispute are involved.
IMSG’s role
We can assist with the requested company records and coordinate the response. We first check your engagement: routine record maintenance may already be included, while a bank-review response, certifications, offshore documents or historical reconstruction may require a separate quotation. We confirm scope and any additional fees before work begins.
Where financial information is needed, we can coordinate accounting preparation and liaison with an independent auditor within the agreed scope. The bank decides whether its requirements are met. IMSG does not guarantee the review’s completion or the restoration of banking facilities. Bring the request to our company secretarial team to discuss the next step.
About these scenarios
These illustrative scenarios explain common administrative issues. They do not describe specific clients or guarantee an outcome. Legal and tax questions require advice on the circumstances concerned.
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