BVI CO with HK bank - sudden questions into registered address

Hito

New Member
Aug 19, 2021
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Hi guys,

Insights and help would be much appreciated!

B.V.I. company with a clean history (holding company with documented source of funds, with a few residential real estate transactions) and verified UBO has been successfully banking with a HK bank for close to 10 years. Yearly compliance checks were never an issue until last week(?): after sending in all the usual updated documentation, this was the first time they showed so much attention to the BVI co's HK address on file.

FYI: I opened the account while living in Hong Kong many years ago and initially used my own address. After leaving, I switched to a paid HK virtual office (yearly fee for address and secretarial services) and had the bank use this address - this was roughly 5 years ago.

Current compliance driven questions from account manager in italics
1. Am I right in understanding that you share the HK address with the law firm / accountancy firm handling your matters in HK?

(I mention that my law / accountancy firm is in the BVI (as supported by the yearly documentation I've been sending them) and that my HK address is that of the secretary to handle mail etc.)
2. Am I right in understanding that the office in HK is not your office, but the accountant's office? If this isn't the case, please send us the lease agreement for your office location.
(Again, I repeat the information from my initial reply and mention being able to send over invoices for the yearly fees I paid for the HK office & services to one of Hong Kong's business servicing companies)
3. Please send us all the lease agreements for your current office along with the stamp certificate
??? I don't have lease agreements, let alone with stamp certificates on them


””-
Q1: Is a BVI co. not able to bank with HK banks using an address from a local business servicing company?

My gut feeling is telling me that once compliance ascertains that my BVI co doesn't lease its own office in HK, they'll come back with a “sorry, but we can only have accounts with companies with a physical presence in HK” and close the account.

What do you guys think & what would you recommend my next steps to be to satisfy compliance?
 
This are KYC procedures tightening up. But you don't need to have your own space. That is the reason why secretarial companies exist in a quantity of 5 figures in Hong Kong. In fact you can state that that is your address in Hong Kong (local office of your BVI company).
 
Happy to confirm that after checking the invoices for the virtual office, KYC was satisfied.

@uplana No experience & communication with him. I just saw him in the list of recommended people for Hong Kong and decided tag him, hoping to hear his feedback.
 

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