01 / Scope
Who Hong Kong KYC rules cover
Financial institutions and designated non-financial businesses and professions covered by the AMLO. This summary focuses on HKMA-supervised authorized institutions.
02 / Start the check
When Hong Kong customer due diligence starts
- Before establishing a business relationship, subject to the limited timing treatment in Schedule 2.
- Before specified occasional transactions, wire transfers, or linked transactions at the statutory thresholds.
- When money laundering or terrorist-financing is suspected or prior identity information is doubtful.
- When a trigger event or risk review requires updated CDD for an existing customer.
03 / Evidence
Identity data required for Hong Kong KYC
- Customer identity information and, where relevant, the identity and authority of a person acting for the customer.
- Beneficial-owner identity and ownership or control information.
- Purpose and intended nature of the business relationship.
- Risk information needed to determine whether simplified, standard, or enhanced measures are appropriate.
Verification methods and evidence
- Verify identity using documents, data, or information from a reliable and independent source.
- Use additional or enhanced measures for higher-risk customers and specified circumstances.
- Where non-face-to-face controls or technology are used, meet the AMLO and current supervisory-guideline expectations rather than assuming a selfie alone is sufficient.
04 / Entity customers
Beneficial-owner and representative checks
Take reasonable measures to verify a beneficial owner so the institution is satisfied it knows who the beneficial owner is, including understanding ownership and control for legal-person customers.
05 / After onboarding
Ongoing KYC monitoring in Hong Kong
Continuously monitor the business relationship and keep CDD information up to date and relevant, with review frequency driven by risk.
Record retention
Schedule 2 generally requires CDD records for at least five years after the business relationship ends and transaction records for at least five years after completion, subject to a regulator’s extension power.
06 / Build notes
How to implement Hong Kong KYC requirements
- Attach each workflow to the exact Schedule 2 trigger and the customer’s risk class.
- Keep the reliable independent source and the matching result alongside extracted fields.
- Design entity onboarding to show the ownership chain and the reasoning behind the identified beneficial owner.
- Test remote and non-face-to-face journeys against the latest HKMA guideline revision.
07 / Related answers
Questions behind international KYC implementation
08 / Source ledger
Primary sources for Hong Kong KYC rules
We use regulator and legislation publishers here, not vendor explainers. Pinpoint citations show where to begin; the linked instrument controls.
Schedule 2 Statutory customer due diligence and record-keeping requirements.
revised 28 November 2025 Current gateway to the guideline for authorized institutions.
Cap. 615 Official text and amendment status for the Ordinance.
Source review completed 18 July 2026. This page is a structured research summary, not a legal opinion or a substitute for sector-specific advice.