The HKMA has told banks not to reject applications outright because of a company's sector and not to de-risk whole groups of customers. This page sets out what the circular and its annex actually say.
The HKMA's published expectations of banks when they handle corporate account applications.
The HKMA has said it reiterated to banks in a September 2016 circular that they should apply a risk-based approach to account opening and treat applicants fairly, including being transparent about required information and giving feedback or reasons for rejection where appropriate.
The HKMA page says banks should explain the rationale for information requested, help customers satisfy due diligence, and introduce review mechanisms for unsuccessful applicants.
HKMA-stated position: difficulties of overseas SMEs and start-ups in opening accounts were described as not industry-wide but concentrated in one or two international banks, with some improvement after the 2016 circular. This is a dated regulator statement, not current market data.
The HKMA wrote to all authorized institutions on 27 April 2023 (Access to banking services for corporate customers), restating that they must use a risk-based AML/CFT approach consistent with treating customers fairly and financial inclusion, noting feedback from corporates trying to open accounts mostly concerns execution.
The same circular tells banks to avoid wholesale de-risking, meaning excluding whole groups of customers by nationality or new industry, and to review account-opening and customer due diligence procedures and staff training so legitimate businesses get fair access to basic banking.
The circular's annex sets the expected standard that a bank should not reject an application outright just because of the applicant's industry sector, but assess individual risk proportionately and train frontline staff to apply that consistently.
On FATF grey-list links, the annex records that FATF does not call for automatic enhanced due diligence; a bank should treat a connection to such a jurisdiction as one input to the customer risk profile and apply proportionate measures.
HKMA's 'Banks should not' page (revised March 2023) lists disproportionate requests: all documents of an overseas corporate certified by a Hong Kong certifier, decades-deep source-of-wealth detail, unreasonably high turnover benchmarks, or tying account opening to buying wealth or insurance products or a large initial deposit.
Account Opening and Maintenance - Role of the HKMA — Hong Kong Monetary Authority
HKMA circular: Access to banking services for corporate customers (27 Apr 2023) — HKMA
HKMA circular 27 Apr 2023 - Annex: key observations and good practices — HKMA
Banks should not ... — HKMA
Fact sheet last reviewed 2026-09-26. Jurisdiction rules are confirmed against the sources above; a provider's own requirements differ and are confirmed by the provider.
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The same circular tells banks to avoid wholesale de-risking, meaning excluding whole groups of customers by nationality or new industry, and to review account-opening and customer due diligence procedures and staff training so legitimate businesses get fair access to basic banking.
The circular's annex sets the expected standard that a bank should not reject an application outright just because of the applicant's industry sector, but assess individual risk proportionately and train frontline staff to apply that consistently.
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