HKMA sets investment-account controls for registered institutions

Registered institutions must tighten investment-account onboarding and dormant-account controls

Change
On 2026-05-22, HKMA issued current guidance requiring registered institutions to apply expected controls when opening and maintaining client investment accounts.
Why it matters
The circular turns investment-account onboarding into a specific control surface for registered institutions. Account-opening teams must deal with questionable or forged documents, dormant zero-balance accounts and Mainland-investor funding routes as live account-maintenance risks, not only onboarding defects.
Implications
  • Registered institutions handling investment accounts must align account-opening controls with the HKMA circular and related SFC measures — weak due diligence on questionable or forged account-opening documents creates supervisory exposure.
  • Investment-account operations teams must close accounts opened using questionable or forged documents and zero-balance dormant investment accounts where the measures apply — dormant or document-defective accounts remain misuse channels if left open.
  • Registered institutions opening new investment accounts for Chinese Mainland investors must obtain written investor declarations and route deposits, withdrawals and settlements through bank accounts held in the client's own name — third-party funding routes fall outside the expected control boundary.

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