How we check who our clients are, as a Hong Kong licensed TCSP: identity and ownership checks, PEP and sanctions screening, record keeping and reporting.
Applies to: HK, EU/EEA, UK, SG, VN, US, Other
In plain language
- As a Hong Kong licensed TCSP (TC001305), the AMLO requires us to check who you are before we act.
- We identify you, every beneficial owner above 25% or with control, and anyone acting for you.
- You upload documents in our client portal after you order, not on this website.
- We screen everyone against sanctions lists and check for PEPs.
- Higher-risk files need source of funds and wealth information and senior approval.
- We keep records for at least 5 years after the relationship ends.
- We must report suspicions to the JFIU and cannot tell you if we have.
- You can pay before our checks are complete. We file nothing until we approve them. If we decline, our Refund policy applies.
This summary helps you read the document. If it differs from the full text below, the full text applies.
1. Why we check who you are
One IBC Limited holds Hong Kong Trust or Company Service Provider (TCSP) licence TC001305. As a licensee, we must follow the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), known as the AMLO.
The Companies Registry supervises us. Its Guideline on Anti-Money Laundering and Counter-Financing of Terrorism for TCSP licensees sets out how we meet the law.
We apply the Hong Kong standard described on this page to every client as a minimum, wherever the company is formed. Section 15 explains what applies in addition when work is done in another country.
This page summarises our policy for clients. It does not create contractual rights, and our internal procedures may go further than this summary. These checks protect you too. A company formed with clean, complete records is easier to bank and less likely to be struck off or frozen.
2. We use a risk-based approach
We assess the risk of each client before we start work. We look at who you are, where you and your owners live, what the company will do, where its money comes from and which countries it deals with.
Lower-risk files need standard checks. Higher-risk files need more information and approval from our senior management. A file is higher risk when one or more risk factors are present, for example a politically exposed person, a complex or opaque ownership structure, a higher-risk business activity, a connection with a listed country, or information we cannot verify. We review the risk again when something changes.
3. Customer due diligence
Before we act for you, the AMLO requires us to do four things.
- Identify you and verify your identity from reliable, independent documents.
- Identify every beneficial owner and take reasonable steps to verify their identity. For a company, this includes anyone who owns or controls more than 25% of the shares or votes, or who otherwise controls the company.
- Understand the purpose and intended nature of the business relationship.
- If someone acts on your behalf, identify them, verify their identity and check their authority to act.
4. What you will be asked to provide
We do not collect identity documents on this website. After you order, you upload them in our secure client portal.
The usual list is below. For higher-risk files we may ask for more, and for some documents we may need certified copies.
- For each individual (director, shareholder, beneficial owner, authorised person): passport, proof of residential address dated within the last 3 months, and date of birth and nationality as shown on the passport.
- For a corporate shareholder: certificate of incorporation, registers of directors and members, and an ownership chart up to the individuals who own or control it.
- For a trust in the structure: the trust deed or a trustee declaration identifying the settlor, trustees, protector and beneficiaries.
- A short description of the business, the countries it will trade with, and expected activity.
- Where needed: information on source of funds and source of wealth, with supporting evidence.
5. If we do not meet you in person
Most clients start remotely. When a client is not physically present for identification, we take extra steps to manage the higher risk, as the AMLO and the Companies Registry guideline require. For example, we may ask for certified copies of documents or an additional document, or hold a video call if our checks require it.
We tell you which measure applies before you upload.
For electronic identity checks (eKYC) we use Veriff, an independent identity verification provider. According to Veriff, its service meets the identity verification standards that apply in Hong Kong, the European Union and the United States; the countries and documents it supports are listed at veriff.com/supported-countries. The provider runs its checks under its own terms. We are not responsible for the availability of its service or for a result its technology returns, and we may ask you to verify in another way. The decision to accept a client is always made by our compliance staff.
6. Politically exposed persons
A politically exposed person (PEP) is someone who holds or has held a prominent public function, such as a head of state, minister, senior judge, senior military officer or senior executive of a state-owned company. Their close family and close associates are covered too.
We check every client and beneficial owner for PEP status. If you are a PEP from outside Hong Kong, senior management must approve the relationship, we take reasonable steps to establish your source of wealth and source of funds, and we monitor the relationship more closely.
For Hong Kong PEPs, PEPs of international organisations and former PEPs, we apply the same measures when the risk is higher.
7. Source of funds and source of wealth
Source of funds means where the money for this company or transaction comes from, for example salary, business income or the sale of property.
Source of wealth means how you built your total assets over time.
Our services are company formation and company administration. We do not hold or manage client money. We therefore ask for source of wealth information only where the law requires it, namely for PEPs and other higher-risk files, and we ask about source of funds only as far as we need to understand the business relationship. Where we ask, we may request evidence such as bank statements, sale agreements or audited accounts.
8. Nominee and professional director arrangements
Where a company uses a resident or professional director or a nominee shareholder, we identify the person who gives the instructions and the person on whose behalf the shares are held.
These arrangements are disclosed to the registry, to banks and to authorities as the law requires. They do not hide who owns or controls the company. We will not provide a nominee to conceal a beneficial owner.
9. Sanctions screening
We screen every client, director, shareholder, beneficial owner and authorised person against the UN sanctions lists implemented in Hong Kong under the United Nations Sanctions Ordinance (Cap. 537) and the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575), and against the sanctions lists of the United Kingdom (OFSI) and the United States (OFAC) and other lists that matter to our banks and partners abroad. For screening we use recognised commercial databases, including World-Check, provided by LSEG (formerly Refinitiv).
We screen at onboarding, when the lists change and during the relationship. A possible match is reviewed by a member of our compliance staff before any decision. Software does not refuse you on its own.
Our Restricted and sanctioned countries page explains how we treat clients connected with listed countries.
10. Ongoing monitoring
Our duties continue after your company is formed. We keep your information up to date, review higher-risk files more often and watch for activity that does not fit what you told us.
Please tell us when a director, shareholder, beneficial owner, address or business activity changes. At renewal we may ask you to confirm or update your documents.
Many jurisdictions also require a company to keep a register of the people who own or control it, for example the Significant Controllers Register in Hong Kong, the Register of Registrable Controllers in Singapore and the PSC register in the United Kingdom. Where we keep that register for your company, we rely on the information you give us. You are responsible for telling us promptly of any change, so that the register stays accurate. In Hong Kong we can also act as the designated representative for the Significant Controllers Register where you buy that service.
11. Record keeping
We keep identification records, due diligence documents and business correspondence for the whole relationship and for at least 5 years after it ends. The Registrar can require us to keep them longer.
Our Privacy Notice explains how we protect these records and your rights over them.
12. Suspicious transaction reports
Hong Kong law requires anyone who knows or suspects that property is the proceeds of crime or is terrorist property to report it to the Joint Financial Intelligence Unit (JFIU). We have a Money Laundering Reporting Officer who makes these reports.
Tipping off is a criminal offence in Hong Kong. We cannot tell anyone that a report has been made or is being considered, and we may not be able to give reasons for our decisions.
13. Our right to refuse or stop work
You may pay before due diligence is complete. We do not file anything with a registry, pay government fees or act as your company's officer until we approve it. Please send what we need within 30 days after payment. If we still do not have it after that and a reminder, we may cancel the order 14 days after the reminder, and our Refund policy applies.
If you do not provide what we need, or we cannot verify it, we will decline the order or end the relationship, as the AMLO requires. We may also decline or end a relationship where the risk is too high for us to manage, where a bank or local partner will not act, or where we are legally prevented from acting.
If we decide not to act for you, our Refund policy sets out what we refund. If the law requires us to freeze or report funds, we must follow the law first. If you give us false, forged or misleading documents or information, we decline the order, we may report it to the authorities, and the service fee is not refunded.
14. Virtual assets and the travel rule
We do not provide virtual asset services, and we do not accept or send payments in virtual assets. The travel rule for virtual asset transfers therefore does not apply to our services.
If you plan to run a virtual asset business through your company, tell us at the start. The company may need its own licence, and we will apply extra checks.
15. Work done by performing companies and local partners
Where One IBC Pte. Ltd in Singapore, another performing company or a licensed local partner in another country does regulated work for your company, that company must also apply its own country's anti-money laundering rules. It may ask for extra or different documents. Each performing company and licensed local partner is responsible for meeting the rules of its own country. We coordinate so that you upload once where the rules allow.
In Singapore, One IBC Pte. Ltd is subject to the Corporate Service Providers Act 2024 and the rules of the Accounting and Corporate Regulatory Authority (ACRA) for corporate service providers, including customer due diligence and the rules on nominee directors.
When you ask us to introduce you to a bank or payment institution, we introduce you and help with the application. We pass your KYC documents to that institution only at your request or where the law allows, as our Privacy Notice explains. The institution carries out its own checks and makes its own decision.
16. Staff training and review of this policy
Our staff are trained on these duties when they join and regularly after that.
We review this statement at least once a year and when the law or the Companies Registry guideline changes. It was last reviewed on 6 October 2026.
Questions about this policy: write to our Compliance team, for the attention of the Money Laundering Reporting Officer, at customer.success@offshorecompanycorp.com or at our head office.
Sources
- Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), Department of Justice, Hong Kong (e-Legislation)
- Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For TCSP Licensees), Companies Registry, Hong Kong
- Guidelines (AML/CFT and TCSP licensing), Companies Registry, Hong Kong
- Suspicious transaction reporting (STREAMS 2), Joint Financial Intelligence Unit
- Organized and Serious Crimes Ordinance (Cap. 455), Department of Justice, Hong Kong (e-Legislation)
- Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405), Department of Justice, Hong Kong (e-Legislation)
- United Nations Sanctions Ordinance (Cap. 537), Department of Justice, Hong Kong (e-Legislation)
- United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575), Department of Justice, Hong Kong (e-Legislation)
- Companies Ordinance (Cap. 622), Department of Justice, Hong Kong (e-Legislation)
- Regulation (EU) 2016/679 (GDPR), EUR-Lex
Laws and regulator guidance this document follows. They explain our obligations; they are not legal advice for your situation.
One IBC Limited · HK TCSP Licence TC001305 · Unit 1411, 14/F, COSCO Tower, 183 Queen's Road Central, Sheung Wan, Hong Kong
One IBC Limited · HK TCSP Licence TC001305 · Unit 1411, 14/F, COSCO Tower, 183 Queen’s Road Central, Sheung Wan, Hong Kong