Hong Kong · Managed KYC services
Managed KYC for Hong Kong funds, asset managers, brokerages, administrators and banks. We complete onboarding, remediation and periodic reviews under your AML policy, with human-reviewed evidence for your team’s decision.
Your AML policy · Qualified human review · Your team keeps approval
Hong Kong KYC outsourcing
Engage us for a remediation project or recurring KYC work. We agree which cases to review, the evidence standard and who handles exceptions before work begins.
01 · Customer onboarding
We review customer and investor documents, trace beneficial ownership and assess screening results. Your team receives the evidence, risk assessment and unresolved questions needed to decide whether to accept the relationship.
02 · KYC remediation
An ownership chart without source documents or an unexplained source of wealth can keep a case open. We review the agreed population, document gaps and work each file through your remediation and escalation process.
03 · Periodic reviews
We refresh customer information, screening and risk assessments under your policy. We agree the review population and priorities, including higher-risk customers and cases triggered by ownership changes or new adverse information.
SFC AML/CFT · Outsourcing and oversight
For SFC-licensed corporations, we scope customer due diligence work against the applicable AMLO requirements, SFC AML/CFT Guideline and your approved policy. We document the checks and escalate exceptions. Your firm remains responsible for compliance.
Outsourcing under your procedures differs from relying on an intermediary’s CDD. Paragraph 4.15 of the SFC guideline explains the distinction. For banks, fund vehicles and other entities, we confirm the applicable framework separately before reusing a checklist.
SFC AML requirements guideThe SFC’s AML/CFT framework covers more than customer files. Our Hong Kong SFC AML and KYC guide explains CDD, beneficial ownership, review frequency and record keeping for licensed firms.
What you receive
Each file records what we checked and why. An unresolved evidence gap stays visible in the handover so your team can act on it.
Included in the file
Identity evidence, authority to act and an ownership-and-control record linked to the documents used to verify it.
Included in the file
Sanctions, PEP and adverse-media results, with the reasons a potential match was cleared or escalated.
Included in the file
The proposed risk rating, source of funds and wealth evidence where required, and an exception log that keeps missing information visible.
Included in the file
Review notes and a traceable record of the work, ready for your authorised team to accept, reject or return for further evidence.
The process
01 · Scope
Share the entity type, backlog size and target date. We agree the policy, evidence requirements, access and price before you send case documents.
02 · Work & review
Agents organise documents and run the first pass. Qualified compliance reviewers check the evidence and reasoning, then escalate unresolved or higher-risk cases.
03 · Handover
Receive reviewed files and an exception log. Your authorised team makes acceptance and escalation decisions. Recurring reviews follow the schedule you approve.
If an administrator already holds your files, Shadow KYC can provide a separately scoped review. Hong Kong managers of Cayman funds can also use our Cayman KYC services, with the fund’s obligations assessed separately.
Questions
Scope, pricing and the decisions your Hong Kong team keeps.
Scope your KYC backlogCustomer, investor and counterparty onboarding, KYC remediation and periodic or trigger-event reviews for funds, asset managers, brokerages, administrators and banks. We agree the legal entity, applicable framework, policy and case population before starting. The engagement covers the operational work specified in that scope.
The SFC AML/CFT Guideline distinguishes outsourcing under the firm’s procedures and control from reliance on an intermediary’s CDD. We scope our work around your approved procedures, reporting and oversight. Your firm retains responsibility for compliance, and your authorised team keeps customer acceptance, high-risk approvals and suspicious transaction reporting decisions.
No. Banks should start with the HKMA framework for authorised institutions. Registered institutions also need to consider the relevant securities-sector provisions of the SFC guideline. We confirm the applicable requirements separately; our SFC guide is not a substitute for a bank’s regulatory assessment.
Yes. We can separately scope a Shadow KYC review of administrator-held files, assess independence and report evidence gaps. For a Hong Kong manager of a Cayman fund, we assess the manager’s and fund’s obligations separately. File testing does not replace a programme-wide independent AML audit.
No. We provide KYC and AML operational support, not regulatory approval or legal advice. Our service is not endorsed by the SFC. Compliance depends on your firm’s obligations, controls and decisions, including activities outside the engagement.
We quote against the case count, ownership complexity, available evidence and review scope. Share your target date and we confirm the price, delivery schedule and responsibility for missing documents in writing. Data access, hosting region and retention terms are agreed before file transfer.
Discuss your files
Bring the case count, entity type and target date. We’ll confirm the scope, price and delivery schedule in writing.
Or send the case list to [email protected]