Write the requirements document first; do not start by looking for a bank that is 'easy to open an account with'
Before opening an account, you should at least explain the company's incorporation and licensing, which customers it serves, what role stablecoins play in the process, and where fiat currency comes from and to whom it is paid. Describe the company's own funds separately from customer-related funds, and list the expected currencies, transaction volumes and main payment countries. A bank's acceptance of ordinary software companies does not mean it is willing to take on equivalent transactions for payment platforms or crypto businesses.
'Supporting an industry' does not mean agreeing to your every pathway
The 2023 HKMA circular requires banks to adopt a risk-based approach and encourages them to support the reasonable account-opening needs of licensed virtual asset service providers regulated by the Hong Kong Securities and Futures Commission; this is not a guarantee of account opening for any company, nor an approval of all transaction channels. You must still explain product and customer risks to the specific bank, and cannot substitute regulatory encouragement or peers' successful account opening for your own due diligence.
Test product fit with real fund flows
Assume the bank allows the company to collect service fees paid by overseas institutions, but does not allow it to collect large amounts of funds from unidentified merchants. Even if this account has already been opened, it is not suitable for directly launching merchant collection. It is advisable to submit the payer, account name, ultimate beneficial owner, refund path and intermediary institutions to the bank one by one for confirmation, and to verify whether third-party payments are accepted, whether the required clearing networks are supported, and whether further manual review may occur after funds arrive.
Beyond fees, compare how matters can be handled after an interruption
As a commercial due diligence recommendation, you should also compare transaction inquiries, returned remittances, reconciliation files, emergency contacts, return of funds after account closure and available backup arrangements. If customer funds need to be safeguarded, you should ascertain whether the bank provides the corresponding accounts and confirmation documents, rather than merely saying that 'funds are very safe in the bank'. Backup accounts must also disclose the same genuine business, and must not be used to continue operations under a concealed purpose after the main account is restricted.
Recommended actions
- Prepare a business description, licences, beneficial owners, anti-money laundering framework and sample fund flows.
- Confirm separately the applicable account conditions for own funds, fees and customer funds.
- Include currencies/countries/customer types/refund and service-discontinuation arrangements in the bank comparison checklist.
Information note: This article provides general information and does not replace legal advice based on specific facts.
References
- Access to banking services for corporate customers (circular dated 27 April 2023) — Hong Kong Monetary Authority
- Safeguarding requirements for payment institutions and electronic money institutions — UK Financial Conduct Authority (FCA)
