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The Hong Kong bank review letter: what it means, and the response that shortens it

Current to 26 August 2026 · updates land in the changelog.

A review letter (or RFI — request for information) is the routine, answerable version of Hong Kong bank trouble. The bank is running periodic customer due diligence: it names documents and a deadline. Non-response is how a manageable review becomes service restrictions and, eventually, closure — so the letter itself is the work order.

The six categories banks request

Compiled from bank CDD pages and Hong Kong accountants' published experience, requests fall into six buckets:

• Identity & ownership — directors' and beneficial owners' ID, organisation chart, Articles of Association, BR, latest NAR1 (周年申報表).
• Business substance — audited financial statements (the single most-demanded item for company accounts), contracts, premises evidence, website and marketing materials.
• Source of funds / wealth (資金來源證明) — covered in its own guide.
• Transaction explanations — per-transaction document sets.
• Counterparty information — who they are, jurisdiction, relationship, documents held.
• Account purpose & expected activity — measured against what you declared at onboarding.

The protocol that shortens reviews

The published professional consensus is a four-step discipline: contact the bank promptly; get the reason (where available) and the full document list in writing; then submit once, complete, within the deadline. Piecemeal submissions restart review queues — every partial answer sends the file to the back of the line. The corollary: spend the deadline period assembling, not negotiating.

Genuine records, only

Everything above assumes one non-negotiable: the documents are real. Hong Kong regulators run zero tolerance on questionable or forged documents — the SFC said exactly that of intermediaries in its 22 May 2026 circular — and a gap explained honestly (“no audited statements yet; management accounts attached”) is a survivable answer. A fabricated document is not. If you cannot evidence something, say so and show what exists.

When it isn't a review letter

If the account is already blocked with no letter and no deadline, you may be looking at a different event entirely — triage the three scenarios before drafting anything, because the right response differs sharply.

Quick answers

What documents do Hong Kong banks ask for in a review?

Six recurring categories: identity and ownership, business substance (audited financials lead for companies), source of funds, per-transaction explanations, counterparty information, and account purpose versus declared expected activity.

Should I send documents to the bank as I find them?

No — the professional consensus is submit once, complete, within the deadline, with the full list obtained in writing first. Piecemeal submissions restart the review queue.

What happens if I ignore a bank review letter?

Non-response leads to service restrictions and eventually closure. The letter with a deadline is the answerable scenario — answering it well is what keeps it that way.

General information and document templates only — not legal advice. Organise genuine records only: never alter, backdate or fabricate a document — regulators apply zero tolerance and an honest gap explained is survivable where a fabricated paper is not. Anything involving police, the JFIU, a Letter of No Consent, restraint orders, personal suspicion or a sanctions nexus belongs with counsel, not templates. Sources are the HKMA, the Code of Banking Practice, SFC circulars, FDRC terms and case law as cited, plus our audited kit research. © 2026 Kilde.

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