Confirm the recipient’s requirements first
This is a preparation framework rather than a universal bank account-opening checklist. Banks request evidence according to their risk assessment and the case. Confirm document versions, dates, certification and additional evidence with the recipient before retrieval.
Organise evidence into three groups
Corporate identity: prepare incorporation, business registration and constitutional documents as requested. Filed records: date each NNC1, NAR1 or relevant change filing. Ownership and control: separately collect and verify member records, structure charts and any personal or control evidence required by the recipient.
HKMA: account opening and maintenance ↗Companies Registry: specified forms and completion notes ↗
Public filings alone do not verify beneficial ownership
Registered holders can differ from ultimate beneficial owners. The Significant Controllers Register is not a general public search product. Do not mark extracted NAR1 data as verified beneficial ownership. Record missing evidence, its owner and review status.
A KYC preparation handover table
Use the table to confirm the recipient’s requirements. The download adds owner, status, missing material and confirmation-date fields. Record document references rather than identity-document numbers. This worksheet does not determine customer risk or replace the recipient’s complete requirements.
Scroll sideways to see all columns; focus the table and use arrow keys on a keyboard.
| Question to resolve | Material to organise | Confirm with recipient | Check before marking ready |
|---|---|---|---|
| Which legal entity is applying? | Available incorporation, business-registration and constitutional documents | Required version, validity and certification | List name or identifier discrepancies before acceptance |
| What date do the filed records describe? | NAR1, NNC1 and available relevant change filings | Relevant date and whether later filings are needed | Check page completeness; separate record and retrieval dates |
| Is ownership and control evidence sufficient? | Member information, structure chart and requested supporting evidence | Which layers and individuals need separate evidence and verification | Keep unknown layers and incomplete checks open |
HKMA: account opening and maintenance ↗Companies Registry: Significant Controllers Register ↗
Worked request: turn one recipient email into four tasks
This institution, email and all material statuses are fictional, not a bank’s actual requirements. Suppose the email asks for corporate identity documents, ownership as of a specified date, certified copies and an explanation of a name discrepancy. Split it into four tasks because each has a different source, owner and completion condition.
Preserve the original wording, then translate it into actions. Identity work lists available documents and identifier matches; ownership work records the required date, available filing dates and missing layers. Receiving one NAR1 does not automatically complete both tasks.
If certification, validity or “recent” is unclear, ask instead of inventing a three-month rule. A useful question is: “Please confirm the required as-of date, acceptable version and certification. We hold D-01 dated [date]; does it satisfy this request?” Attach the answer to the original requirement.
Scroll sideways to see all columns; focus the table and use arrow keys on a keyboard.
| Task | Available material (fictional) | Gap or clarification | Next action |
|---|---|---|---|
| Corporate identity | D-01 incorporation record; D-02 business registration | English names differ | Transcribe names and identifiers; request explanation |
| Dated ownership structure | D-03 NAR1; undated chart D-04 | Chart and filing dates do not align | Confirm the date and source for each layer |
| Certified copies | Ordinary scans | Certification method unconfirmed | Obtain the recipient’s clarification first |
| Name discrepancy explanation | Source text in D-01 and D-02 | Reason and supporting evidence unknown | Record the question, owner and response reference |
When a complete-looking pack contains conflicting records
Map each chart edge to evidence, not just the company names on the page. Record holder, held entity, class, date and source. An unsupported entity or percentage is a gap; a documented holder missing from the chart needs explanation too.
In the fictional pack, D-03 describes August while D-04 claims to be current without a date. Do not decide which is wrong or merge them into a verified version. Ask for the chart’s date, the source for the edge and any intervening changes; retain the answer and supporting material.
For a returned item, retain the reason, submitted version and replacement link. A request for a clearer scan is not permission to rewrite ownership values. A date objection requires a scope correction. Distinguish readability, version and substantive changes in the revision log.
HKMA: account opening and maintenance ↗Companies Registry: specified forms and completion notes ↗
Keep preparation, submission and receipt as separate states
“Ready” means prepared against confirmed requirements; “submitted” means a particular version was sent; “receipt confirmed” means received. It does not mean accepted or KYC passed. Preserve a simple acknowledgement as an acknowledgement, not a stronger internal conclusion.
A fictional handover might say: “Pack V2 submits R1, R2 and R4. R1 and R2 follow your 3 October clarification. R3 is not submitted yet, pending confirmation of certification requirements. I-01 explains the R4 name discrepancy. Please confirm the received version and outstanding items.” The references identify exactly what was submitted and what remains open.
Hand over material locations, providers, clarifications, last submitted version and outstanding items. Keep references and workflow states in the register, with personal evidence held under your organisation’s access arrangements. Future updates can then build on existing work instead of requesting the same documents again.
- Requirements to confirm: a clarification is still outstanding.
- Missing / awaiting check: distinguish absent material from received but unchecked evidence.
- Ready / submitted: retain the prepared and actually sent versions.
- Awaiting reply / receipt confirmed: retain the recipient’s actual wording and date.
Frequently asked questions
Does obtaining a NAR1 guarantee account approval?
No. Document preparation supports your application; the recipient separately assesses the case and required evidence.
References
- HKMA: account opening and maintenance ↗
- Companies Registry: specified forms and completion notes ↗
- Companies Registry: Significant Controllers Register ↗
Use the checklists and examples to prepare your documents. When checking an official form, note which version the guide refers to.