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Transaction RFIs: the four-document set that answers 'please explain these transfers'

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

Transaction-level RFIs list specific transfers and ask what they were. The per-transaction evidence set, per the published accountant consensus, is four documents deep: invoice + contract + shipping or customs documents + the email correspondence around the deal. One set per queried transaction, not one pile per year.

Why four, and what each proves

• Invoice — the commercial claim: who owed what for what.
• Contract — the relationship the invoice sits inside.
• Shipping / customs papers — for goods flows, the physical reality: something actually moved.
• Correspondence — the contemporaneous trail proving the deal was negotiated by real people at the time, not papered afterwards.

Service businesses substitute deliverables for shipping papers: the report delivered, the campaign shipped, the code repository, timesheets — evidence the service happened.

Presentation: the table is the answer

Reviewers walk a list. Give them one: each queried transaction as a row — date, amount, counterparty, purpose in one sentence, and which attached documents evidence it. The narrative coherence matters: rows should reconcile with your declared account purpose and your source-of-funds story; a transaction that doesn't fit the declared pattern deserves its own honest paragraph rather than silence.

The edges to respect

Genuine documents only — a reconstructed invoice “to fill the gap” is fabrication, while a genuine gap explained (“counterparty ceased operations; bank statements and correspondence attached”) is an answer. And if any queried transaction connects to funds someone else has reported as fraud, or to parties under sanctions, stop drafting and take counsel — that is no longer a document exercise.

Quick answers

What documents explain a transaction to a Hong Kong bank?

The per-transaction set: invoice, contract, shipping or customs documents (or service deliverables), and the contemporaneous correspondence — assembled per queried transaction with a summary table.

What if one queried transaction has missing paperwork?

Explain the gap honestly and evidence around it. Never reconstruct documents after the fact — an explained gap is survivable; a fabricated document is not.

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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