Nium

This article outlines the documents required for organizations registered in Hong Kong to complete business verification.

Verification, commonly referred to as KYC or "Know Your Customer," is a regulatory requirement for offering financial services to businesses and individuals. The process involves collecting, reviewing, and maintaining information about the entities and individuals using our services.

The verification process is divided into two primary components: Business Verification (Verifying the nature and ownership of the business) and Individual Verification.

Topics covered here include:

Verifying the nature of your business
Verifying ownership
Verifying individuals
Additional requirements
Document requirements

1. Verifying the nature of your business.

The nature of your business must be verified to ensure it aligns with regulatory requirements, accurately reflects its stated operations, and complies with industry and legal standards.

Evidence of business activities may include your website. If your company does not have a working website, please provide one of the below:

Contracts.
Business agreements.

Or, a combination of the following:

Company profile or presentation / company brochures or marketing material / detailed business plan.
Invoice (document must be issued within one year, and must clearly showcase business operations).

Prohibited business categories

If your company’s industry falls under any one of the listed categories, the application may be either rejected, or additional documents may be requested.

Prohibited and Restricted Business Categories

2. Verifying the company and ownership.

Documents that are required for different company types are as follows:

Entity Type	Required Document 1	Required Document 2	Required Document 3	Total Documents Submitted
Private Limited	HK Business registration document	HK Certificate of Incorporation	NNC1 (if company is registered within 1 year) or NAR1 (if company is registered more than 1 year ago, must be issued within last 12 months)	3
Partnership	HK Business registration document	HK Certificate of incorporation	Partnership agreement	3
Sole Proprietor	HK Business registration document	-	-	1

See requirements for documents here

Multi-layer ownership structure

A multi-layer ownership structure exists when a company is owned indirectly through one or more intermediate entities, rather than being directly owned by individuals or a single organization.

To determine if your company has a multi-layer ownership structure, please refer to the below questions:

Is your company owned by another entity (e.g., a company, trust, or partnership) rather than directly by individuals? If yes, there is at least one layer of ownership.‍
Does that owning entity itself have owners who are other entities? If yes, this adds another layer to the structure.‍
Can the ultimate beneficial owners (the individuals who control or benefit from the company) only be identified by tracing ownership through multiple entities? If yes, your company has a multi-layer ownership structure.

In simpler terms, if you must navigate through several entities to find the ultimate owners or decision-makers, your company likely has a multi-layer ownership structure.

Providing documents for multi-layer ownership structure

Providing documents for multiple layers of ownership ensures transparency and helps verify the identities of all individuals who ultimately control the company. Nium may request to submit the documents for all layers of the company ownership.

If the holding companies are incorporated in Hong Kong, the same requirements will apply as listed in section Verifying ownership.

For non-Hong Kong incorporated entities, required documents may include:

Business registration document / Certificate of Incorporation.
Register list of Directors and Register list of shareholders (can be same document as number 1 if it holds the same information).

See requirements for documents here

3. Verifying individuals.

Depending on the company type, the individuals below must be verified:

Entity Type	Applicant	Directors	Ultimate Beneficial Owners / Controlling Persons	Additional authorized signatories	All Partners	Sole Owner
Private Limited	✓	✓ Nium will inform when, but under certain circumstances, verification of two Directors may be required. Otherwise, none need to be verified, just identified (i.e. listed).	✓	✓
Partnership	✓			✓	✓
Sole Proprietor	✓			✓		✓

See requirements for documents here

4. Additional requirements.

Letter of Authorization.
Multi-layer ownership structure.
Ultimate Beneficial Owner declaration.
Controlling Person declaration.
Source of Funds / Source of Wealth.

Letter of authorization

If the onboarding application is being prepared or submitted by individuals who are not Directors or UBOs, a Letter of Authorization is required. This form authorizes these individuals to act on behalf of the company.

Below are the requirements based on the company type:

Entity Type	When Required	Who Signs the Document	Document Validity
Private Limited	For any individual who is not a Director	Company Director	Must be dated within 1 year
Partnership	For any individual who is not a Partner	Company Partner	Must be dated within 1 year
Sole Proprietor	For any individual who is not the Sole Owner	Company Sole Owner	Must be dated within 1 year

Download Letter of Authorization here

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Ultimate Beneficial Owner Declaration

Depending on the company structure, Ultimate Beneficial Owner declaration may be requested, but is not applicable to all onboarding cases.

When Nium cannot identify an individual holding 25% of ownership shares, directly or indirectly, UBO declaration will be requested.

Declaration must be signed by company Director only, and the Director must be listed in NNC1 /NAR1 document.

Download Ultimate Beneficial Owner declaration here

Controlling Person Declaration

Depending on the company structure, Controlling Person declaration may be requested, but is not applicable to all onboarding cases.

When there is no single individual holding 25% of ownership shares, directly or indirectly, Controlling Person declaration will be requested.

Declaration must be signed by company Director only, and the Director must be listed in NNC1 / NAR1 document.

Download Controlling Person Declaration here

Source of Funds / Source of Wealth

Nium may request a Source of Funds or Source of Wealth document under certain circumstances. This is not a requirement for all customers and is only requested in specific cases. Factors such as the type of business, the nature or industry of business activities, and any elements affecting Nium’s risk assessment may lead to an Enhanced Due Diligence Questionnaire being issued. Please note, this is not applicable to all onboarding cases and is determined on a case-by-case basis.

Source of Funds‍

The origin of funds that an individual or company uses to finance its operations.

Source of Wealth‍

The origin and means of wealth, reflecting the overall accumulated net worth of entity/individual, used to establish and operate a company.
A written explanation, accompanied by supporting documentation, must be collected to confirm the legitimacy of the customer’s wealth for conducting business.

Examples of supporting documentation for Source of Funds:

Personal or joint savings, collected in the form of bank statements.
Loan agreements.
Contract agreements.
Sale of assets (real estate, shares).
Compensation from legal settlements.
Employment income, including salaries, bonuses, and pensions.

Examples of supporting documentation for Source of Wealth:

Personal or joint savings, collected in the form of bank statements.
Audited financial statements.
Inheritances, including family wealth transfer.
Profits from legitimate business activities or investments.
Ownership of businesses or investments, including returns.
Employment income, including salaries, bonuses, and pensions.

5. Document requirements.

Identity and address verification

Depending on the role individual holds, different requirements apply.

Proof of Identity

Passport.
National ID card, both sides.
- For HKIC (HKID), front side only.
- For Chinese citizens, Chinese Resident Identity Card is acceptable, both sides.

Document quality requirements:

Document should be with valid expiry date, good quality, colored copy, all four corners must be visible.
Copy of a copy is not accepted.
Black & white documents are not accepted