Client onboarding in the financial services sector is like a first date: good impressions count, but it’s also the first opportunity to taint a relationship forever. 

Onboarding needs to go smoothly and efficiently to build on the opportunity. Just like dating has been affected by COVID-19, the pandemic has forced financial institutions, especially retail banks, to re-assess their account-opening/client-onboarding processes.

Consistent with the statement from the Financial Action Task Force on 1 April on digital onboarding, the Hong Kong Monetary Authority (HKMA) issued circulars to banks (PDF) and stored value facility (SVF) licensees (PDF) on remote client onboarding in light of COVID-19. These encourage the use of technology to enable remote onboarding and account-opening services, while also drawing attention to COVID-19-related financial crime risks (see our blog post on cybersecurity in the time of COVID-19).

The HKMA’s circulars provide a new trigger point for banks and SVF licensees to refocus on developing functional remote onboarding/account-opening services. 

Below we look at two key aspects of an effective remote onboarding system.


Having an electronic system to, for example, verify the identity of and conduct background checks on a client is critical to making the remote onboarding process a success. 

Against the backdrop of COVID-19, digitising some or all of the onboarding process also helps to maintain social-distancing measures as it reduces the number of 'touch points', ie the number of people and teams that need to be involved in onboarding a client. 

As we move towards the fintech era, banks have a wide range of tech options they can employ, eg using electronic signatures to ensure a contract is duly signed by the client, and bank and digital credentials to authenticate a client’s identity for accessing the bank’s mobile applications. 

In this respect, the FATF guidance on digital identity issued in March 2020 provides helpful guidance to the industry on how digital ID systems can be used to conduct customer due diligence (CDD).


Centralising the collection of client data and documents via different channels is also key, as the various stages of client onboarding may require the use of multiple technologies/systems. 

Centralisation also prevents client information gathered in different ways from being created and stored in disparate data stores. Ideally, one single (virtual, of course) location in a bank’s system should provide for a holistic view of and access to a client’s CDD information. 

The need for smooth access to a client’s information is becoming more apparent as many bank employees are working from home. This also reduces the need to ask the client for the same information multiple times for different purposes.

We have been working with many of our clients who are reviewing their onboarding workflows to find efficiencies in a risk-neutral way.