At Horizons, we encounter numerous queries about opening a company bank account in China, especially during the COVID-19 pandemic. For practical purposes, a company bank account should be opened upon the receipt of the business license.
For foreign companies operating in China, two accounts should be opened in order for a business to commence with transactions. Firstly, you’ll need to open Renminbi (RMB) currency account for daily operations in China, in which only RMB can be deposited, withdrawn and transferred; secondly, a foreign currency account shall be opened to receive capital injections from abroad. Below, we highlight five best practices in opening your company’s China bank account.
1. ‘Know Your Client’ procedures
When making an application for a business bank account, the bank is subject to perform a “Know Your Client” procedure (“KYC”). The KYC guidelines in financial services require that professionals try to verify the account holder’s identity, the nature of the company account, as well as the suitability and risks involved with maintaining a business relationship. Similar to other global jurisdictions, banks in China are required under the People’s Bank of China and Anti-Money Laundering Law to execute a KYC. It is important to check with the bank to inquire (1) which supporting documents are required and (2) which of these supporting documents are required to be translated, notarised and legalised for the KYC to be completed.
2. Physical operating business address
On 1 July 2020, the People’s Bank of China issued the Notice on Strengthening the Supervision of Opening Bank Account Requirements (“Notice”). Under the Notice, enterprises opening bank accounts are subject to stricter requirements, specifically relating to an enterprises business address. To this end, enterprises shall provide an operating business address, either the business’s registered address or a shared working space address for enterprises with a virtual address. Enterprises are subject to an on-site inspection to ensure the address provided is an authentic real operating address.
3. Legal representative presence
Under the Notice, the legal representative of a company (a natural person appointed to act on the company’s behalf) is required to be present in order to open a bank account. Where the legal representative cannot be present due to issues related to the COVID-19 pandemic, a video conference may be acceptable. However, in our experience, only international banks such as HSBC and Standard Charter Bank permit video conferencing, and that most banks require the original passport of the legal representative for the opening of a business account.
4. Multiple e-banking access
A China business account may have different levels of e-banking access in form of a security token, such as a USB key. In this manner, the payment procedure can be verified by relevant bank personnel before the payment is finally transferred. For instance, a company’s finance assistant may only have access and data input rights, while its finance manager may have only approval rights, and the finance director may only have payment rights. As a result, there are several measures established to safeguard against payment errors.
5. Transaction limits
A bank may investigate the actual business operations of a company and establish daily payment limitations based on such findings. Where an enterprise has violated laws or regulations after the bank account is opened, the account may be suspended. Therefore, companies should ensure its business operations are fully compliant in order to minimise transaction disruptions.
If you would like more information about banking procedures or other related corporate matters, send us an email at talktous@horizons-advisory.com, and we’ll have a Horizons professional contact you.
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