16 March 2026

Updated 7 October 2026Vivien Chung

Preparing a Hong Kong group structure for bank onboarding and reviews.

A bank application should explain the purpose of each entity, who owns and controls it, and the expected flow of funds. Consistent corporate and financial records also support later account reviews.

A bank application should explain the purpose of each entity, who owns and controls it, and the expected flow of funds. Consistent corporate and financial records also support later account reviews.

Build a clear application pack

Start with a structure chart showing the holding company, operating companies, special-purpose vehicles and any fund vehicles. Record their jurisdictions, ownership percentages, directors and relevant controllers. Show the underlying ownership with supporting company records rather than relying on the chart alone.

Explain why each entity exists: the assets it holds, its activities, the counterparties involved and the anticipated payments between entities. A bank may ask questions beyond the Significant Controllers Register; obtain its actual beneficial-owner and verification requirements.

Separate funds, wealth and authority

Source of funds explains the origin of the particular money entering the account. Source of wealth explains how a relevant person's broader wealth was accumulated. Prepare evidence appropriate to each question; one bank statement may not answer both.

A signing and approval matrix should say who can instruct payments, which decisions require board or other approval, and how the decisions are recorded. Keep the resolutions, mandates and underlying agreements consistent.

Prepare for account reviews

Reviews may be periodic or triggered by events. Confirm that the request is genuine, note its deadline and identify the information required. Common areas include current ownership, directors, identity information, business activity, financial records and transactions.

Collect the requested evidence and explain changes accurately. Ask for an extension if needed, without assuming one will be granted. Document age, certifiers and overseas certificates must meet the particular bank's requirements. IMSG can assist with the company records and coordinate the response within an agreed scope; the bank decides whether the response is sufficient.

Maintain records after opening

Record and reconcile transactions regularly, retain supporting contracts and invoices, and prepare management information appropriate to the business. Plan year-end schedules, independent audit and tax work as separate responsibilities with their own deadlines.

Document director and ownership changes, keep registers current and retain approvals for material transactions. These practices help explain the business; they do not guarantee uninterrupted banking or remove the provider's discretion.

Agree the work required

IMSG can coordinate company-secretarial records, accounting and separately scoped tax or bank-review support. Legal structuring and disputes require appropriately instructed solicitors; investment management and other regulated functions require the relevant providers.

A free 20-minute introductory call helps identify needs and next steps. A full structure or document review is separately scoped professional work. The bank application guide contains the detailed checklist.

Start with a free 20-minute call.

The call is free and covers general questions: how Hong Kong companies work, what we do and what it costs.Advice on your own company is a paid consultation at HK$2,500 an hour. First-hour fee credited towards IMSG service fees if you engage us within 30 days. No cash refund. Government fees and third-party charges are excluded from the credit.

Your privacy choices

With your permission, we use analytics and advertising cookies to understand site use and measure enquiries from ads. Search and enquiries work without them.

You can change your choice in Cookie preferences in the footer. Withdrawing consent refreshes this page to stop loaded tracking. Copy any unfinished enquiry first. Privacy Policy · Cookies Policy