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All we need to know about YOU - As a new client

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Nowadays, whether you’re opening a new account in a bank, a financial institution, a club membership or for setting up of a new company, it is inevitable that some form of your identification has to be produced and copy retained for their records.

If you come across any institution that does not require such proof while you are new to them, you should be alerted and think twice why it’s so easy – is internal control of the institution badly managed or just that the best practice is not followed.  In any case,

Requirements of client due diligence (CDD)

Sleek as a Trust or Company Service Provider (“TCSP”) licensee in Hong Kong, to provide corporate services and among other licensee, is under the requirements of Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (“AMLO”) to conduct CDD to know the true identity of each client and the type of business and transactions the client is likely to undertake, to a satisfactory level to mitigate the risk of money laundering/terrorist financing.  CDD should be performed before establishing a business relationship with the client. 

 

Exceptional cases are clients which are – financial institutions supervised for compliance by an authority in the jurisdiction, listed company, government body, where Simplified Due Diligence can be applied in which case other than identification and verification of client’s identity and have knowledge of the purpose of business relationship, identification and verification of beneficial owner (“BO”) is not required.

A. Identify and verify client's and the BO's identity

A BO is an individual who ultimately holds or controls (directly or indirectly) more than 25% of the shares, voting rights, profits or capital, as the case may be.

Collection of Details and Documents: Individual

  • Full name, date of birth, nationality, identity document type and number, residential address
  • HKID card / valid travel documents bearing the person’s photograph

Collection of Details and Documents: Corporation

  • Full name, date and place of incorporation, registration number and registered office/business address
  • Certificate of Incorporation, articles of association, ownership chart, list of directors

B. Obtain information on the purpose and nature of business relationship

Sleek welcome clients to share with us the business nature and location of the company that would engage our services so we can suggest the suitable form and structure tailored to the needs.  It should also be clear what services are required, from setting up to restructuring, ongoing maintenance or accounting, tax, payroll or employment visa service that Sleek provides – a truly one-stop shop!

Enhanced due diligence (EDD)

Sleek has to apply EDD for either one of the following situations:

  • When we cannot meet with a client in person
  • When the client is a politically exposed person
  • When the client is from a jurisdiction that does not adopt or insufficiently adopts the FATS recommendations

Depending on a case by case basis, Sleek would determine the best course of action to take to mitigate the risk that associates with the specific profile, and advise client separately on what further documents or procedures to undertake to complete the EDD exercise.

Ongoing monitoring

A TCSP licensee must continuously monitor the business relationship with a client.  Sleek would conduct review on a regular basis, with higher risk cases more frequently and intensive.  Please ensure up-to-date information is provided to Sleek on request or notify us in reasonable time. You may refer to our article on ‘Important Notice to Clients’ for the timeframe to report different changes to us.

 

Do not panic about all these requirements. Sleek would make it simple and easy for you to comply with all.  We are endeavour to carry out best practices in the industry while yet flexible and client-friendly. Talk to us today to find it out!

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