Address Proof for Personal Customers

In the Customer Due Diligence (CDD) process for personal customers, one of the hurdles is that customers have difficulties in providing proofs of residential or permanent address. The Industry Working Group (IWG) on Prevention of Money Laundering and Terrorist Financing has recently developed a guidance paper to banks on "Address Proof for Personal Customers".

The paper sets out the some common cases where a personal customer is unable to provide acceptable address proof:

• Business people staying in HK for a short
• New immigrants or expatriates who reside in a serviced apartment or the home of a relative
• Individuals living in an overseas country where utility bills are not in English or Chinese
• Individuals (esp. celebrities) who normally use their office address or a PO box as correspondence address
• Individuals living in a village type property with address proof showing the village's lot number only

To handle these situations, banks may consider expanding their list of acceptable address proofs to cover the following documents:

• utility, rates or tax bills
• bank or credit card statements
• management fee bills
• letters issued by government or other public bodies
• correspondence received from banks, MPF providers, insurance companies or professional bodies
• mobile phone or pay TV statements
• rental agreements showing the address of the customer and having the customer as one of the contracting parties
• ID card, passport or driving licence which shows the customer's address in the home country

In cases where the customer is unable to provide the address proof, banks may consider accepting the following documents as address proof:

• correspondence received from the customer's employer which shows the residential address of the customer
• letters issued by a qualified intermediary confirming the address of the customer
• up-to-date annual returns which contain the customer's residential address
• address proof of an immediate family member plus a written confirmation from the immediate family member that the customer is living at that address
• an acknowledgement of receipt duly signed by the customer in response to a letter sent by the bank to the address provided by the customer
• a land search report on the address provided by the customer which confirms that the customer is the owner of the property
• a copy of the statement which is sent by the bank to the address provided by the customer and is returned by the customer during his visit to the bank

The above alternative ways to verify a customer's residential or permanent address sound pragmatic. I suggest SFC acknowledge this guidance paper for reference by licensed intermediaries.