- Sleek is a licensed TCSP, so KYC checks must be done before any work starts.
- Every director and shareholder sends ID, proof of address and personal details.
- A request for more documents is a further check, not a rejection.
- You can verify from overseas; tell us whenever your details change.
Sleek’s KYC checks are the first thing you meet after signing up. Passport and proof-of-address requests can feel like a lot before any real work starts, but each one has a legal reason.
We’re a licensed trust or company service provider (TCSP), so we must check every new client before we start work. That applies whether you set up your Hong Kong company with us or move one across. We verify you, your company’s owners and anyone acting for you, and we check what the relationship is for.
In this guide, you’ll learn:
- Why we check who you are, and what we ask individuals and companies for
- Who counts as a beneficial owner
- When we may ask for more, how remote verification works and who can certify a copy
- How long the checks take and how to clear them quickly
Why does Sleek need to check who you are?
Because the law requires it. Sleek is a licensed TCSP (licence TC006483, issued by the Companies Registry). The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) requires every licensed TCSP to complete client due diligence before starting work.
These TCSP KYC requirements are like the checks you go through when you open a bank account: someone has to confirm who you are and keep a record of it. Our checks cover three things:
- You: your identity, and that of anyone acting for you.
- Your company: who owns it and who controls it. This is the “know your business” part of the checks.
- What you need from us: what your business does, where it operates and which services you want, such as set-up, company secretary, accounting or visa support. This helps us recommend a suitable structure.
What do we ask from individual clients?
Every director, shareholder and beneficial owner sends personal details, an identity document and a proof of residential address.
- Personal details: full name, date of birth and nationality.
- Identity document: the type and number, plus a clear copy of your HKID card or a valid passport or other photo travel document.
- Residential address: your current home address and a proof of residential address.
When you create your profile, you choose one of three types: Foreigner, HKID Holder or Hong Kong Citizen. That tells us which identity document to expect, so pick the one that matches the ID you’ll upload.
Make sure the name and address on your documents match what you enter in your profile. Differences such as a missing middle name can lead to follow-up questions.
What do we ask when the client is a company?
If a shareholder is itself a company, we check that company too: its details, its constitutional documents and who owns and controls it. These are the KYC documents your company secretary needs for a corporate client:
- Company details: full name, date and place of incorporation, registration number, and registered office or business address.
- Constitutional documents: certificate of incorporation and articles of association.
- Ownership and control: an ownership chart and a list of directors.
The KYC documents Sleek needs before work starts, for individuals and for corporate shareholders.
| Client type | Details we need | Documents to send |
|---|---|---|
| Individual (director, shareholder or beneficial owner) | Full name, date of birth, nationality, ID type and number, residential address | HKID card or valid photo travel document; proof of residential address |
| Company (corporate shareholder) | Name, date and place of incorporation, registration number, registered or business address | Certificate of incorporation, articles of association, ownership chart, list of directors |
| Any client where extra checks apply | Additional information we request | Decided case by case |
Who counts as a beneficial owner?
A beneficial owner is the individual who ultimately owns or controls a client. For a company, Cap. 615 sets out three tests, explained in the Companies Registry’s guideline for TCSPs. Anyone who meets one or more of them, directly or indirectly, is a beneficial owner:
- Shares: owns or controls more than 25% of the issued share capital.
- Votes: can exercise or control more than 25% of the voting rights at general meetings.
- Control: has ultimate control over how the company is managed.
Some clients, such as regulated financial institutions and listed companies, may qualify for simplified due diligence, which can mean fewer ownership checks.
What if your company is owned through another company or a trust?
We’ll ask for an ownership chart and follow each layer up to the individuals at the top. Each of those individuals then goes through the same checks as a director or shareholder.
Is this the same as the significant controllers register?
Not quite. Your significant controllers register is a record most Hong Kong companies must keep at their registered office or another place in Hong Kong. Our beneficial owner check is part of KYC. The tests overlap, so the same people often appear in both, but one doesn’t replace the other.
When might we ask for more?
Standard checks cover most new clients, but the rules require enhanced due diligence in four situations. The Companies Registry‘s pamphlet for TCSPs lists them:
- Politically exposed persons: the client or its beneficial owner is a politically exposed person.
- Not physically present: the client isn’t present for identification, unless their identity has been verified through a digital identification system the Registrar of Companies recognises.
- Higher-risk situations: any situation that by its nature may present a higher risk of money laundering or terrorist financing.
- Registrar-specified situations: any situation the Registrar of Companies specifies by written notice.
For a politically exposed person outside Hong Kong, the rules require our senior management’s approval before the relationship starts. We also have to establish where their wealth and funds come from.
A request for more information is a further check, not a rejection. We'll tell you exactly what we need, and each request is decided case by case.
Setting up from outside Hong Kong: how does remote verification work?
You can become a client without flying to Hong Kong. The only difference is that remote clients usually go through one extra verification step.
How remote KYC works
- Invitation: each director and shareholder gets their own email invitation to complete KYC.
- Profile: they choose the profile type that matches their ID.
- Upload: they upload a passport or HKID and a proof of address through the secure client portal.
Why remote clients may need an extra step
Under Cap. 615, a client who isn’t present for identification is an enhanced due diligence situation. The exception is identity verified through a digital identification system the Registrar recognises. For individuals, that’s iAM Smart, the Government’s digital identity app.
Otherwise, the rules ask us to take at least one of these measures:
- A further ID check: verifying your identity against a document we haven’t already used.
- Supplementary checks: other steps to confirm the information you’ve given us.
- A first payment from your own account: making sure your first payment comes from a bank account in your name.
If you plan to incorporate from overseas, start the checks early so follow-up questions don’t hold up your set-up.
Who can certify a copy?
If we ask for a certified copy, the certifier must:
- See the original: compare your original document with the copy.
- Sign and date it: sign and date the copy itself.
- Identify themselves: print their name underneath and state their position.
The Companies Registry’s guideline gives these examples of who can certify:
- A Justice of the Peace
- An officer of the embassy or consulate of the country that issued the document
- A certified public accountant, lawyer or notary public
- A professional company secretary
What happens after you’re onboarded?
KYC doesn’t end once you’re onboarded. Here’s what happens after that:
- Ongoing reviews: we monitor each client relationship and review it regularly, more often if it’s higher risk.
- Your updates: when your details change, such as a new director, shareholder or address, tell us within a reasonable time. Send updated information when we ask for it, too. This also keeps your company records accurate.
- Record keeping: the rules require us to keep due diligence records for at least five years after the business relationship ends. Our trust and security page explains how we protect your data.
How long do the checks take?
KYC is the first stage of a new company set-up, which usually takes 3 to 5 working days from sign-up to Certificate of Incorporation. The incorporation documents are prepared only after KYC is complete, and our step-by-step sign-up and timeline walks through each stage.
Missing or unclear documents, or a request for extra checks, can add time.
How can you get through Sleek’s KYC quickly?
Send complete, clear documents for every director and shareholder at the start, and tell us early if anything is missing.
With Sleek, you can:
- Upload online: send your passport or HKID and proof of address through the secure client portal.
- Verify from anywhere: complete the checks from overseas, without flying to Hong Kong.
- Track each person separately: every director and shareholder gets their own KYC invitation.
- Ask before you upload: if you’re not sure which document to send, talk to our onboarding team first.
Already have a company? Our company secretary services start with the same checks, so the same documents get you moving there too.
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FAQs for new Sleek clients
I'm moving my company secretary to Sleek. Do I go through the same checks?
Yes. Due diligence has to be completed before any new business relationship starts, so the directors, shareholders and beneficial owners of an existing company are checked just as they would be for a new one. The rest of the handover is covered in moving your company secretary to Sleek.
Does a director who isn't a shareholder go through KYC too?
Yes. Each director and each shareholder receives their own KYC invitation, whether or not they own shares. The checks also cover anyone who acts on the company’s behalf, so we can confirm both their identity and their authority to act.
What counts as proof of address?
A document from a reliable, independent source that shows your full name and current residential address. Hong Kong’s rules require us to collect your residential address, and to verify your identity using documents that are current. If a document you have doesn’t show your address, or is out of date, tell us and we’ll confirm what else we can accept.
What happens if I can't provide a document you ask for?
Tell us as early as you can and explain why. The Companies Registry’s guideline says that if due diligence can’t be completed, a TCSP should not establish the business relationship, so we can’t start work until the checks are finished.
