HSBC Hong Kong Demands Mainland Investment Clients Submit Fund Source Declarations by September 12

HSBC Hong Kong has recently sent notices to some existing mainland Chinese investment clients, requiring them to submit the "Declaration for Opening/Maintaining Account" through the HSBC Hong Kong app by September 12 and update their contact information. The declaration covers confirmation that funds supporting investment activities come from legal sources outside mainland China, and that the bank may disclose personal data to law enforcement or regulatory authorities upon request. The requirement applies only to investment service clients and does not affect other account types.

The declaration requires mainland investors to confirm at least six items, including that all funds used to support investment activities and related settlement in their HSBC Hong Kong accounts come from legal sources outside mainland China; that account opening documents are true, accurate and complete, and that no account has been closed or suspended by other institutions for use of suspicious or forged documents; a commitment to notify the bank within seven working days of any change in information; confirmation that the bank may disclose personal data to law enforcement or regulatory authorities upon request; a statement that settlement will be conducted through a Hong Kong licensed bank account held in the investor's own name; and confirmation that HSBC may close the account if funds are subsequently determined to be illegal or in violation of mainland China's capital control regulations.

HSBC said in response that it follows relevant regulatory requirements in managing investment client relationships, and has therefore invited the relevant mainland Chinese investors to provide self-declarations and confirm that the information they provided under "know your client" and "client due diligence" procedures is current and valid. The move is intended to enable the bank to continue providing services to clients without interruption. HSBC stressed that the latest declaration requirement applies only to investment service clients.

The action stems from a circular issued by the Hong Kong Monetary Authority to all registered institutions on May 22. The circular requires institutions to conduct immediate internal reviews of account opening records from the past three years, and to identify and close investment accounts opened with suspicious or forged documents. Dormant investment accounts with long-term zero balances and no transactions will also be subject to cleanup. For "zero-balance dormant investment accounts" with a balance of zero as of May 22, 2026 and no client-initiated transactions in the preceding 12 months, the HKMA requires identification to be completed within three months. Institutions must contact clients to reconfirm "know your client" information and obtain written declarations and designated bank account details. If these procedures are not completed within six months, the accounts will also face closure. For mainland investors seeking to open new investment accounts, registered institutions must obtain a written declaration from the client confirming that investment funds come from legal sources outside mainland China and that the client has never had an account closed or suspended by another licensed institution for use of suspicious or forged documents.