When Traditional Banking Was Difficult: EMI Solution for a Hong Kong Company

Opening a corporate bank account is often one of the first priorities after incorporating a Hong Kong company. But incorporation does not automatically mean that a traditional bank will open an account.

Banks perform their own due diligence and assess each company based on its ownership, business activity, countries of operation, expected transactions, source of funds, counterparties and overall risk profile.

For some newly incorporated foreign-owned companies, traditional banking can therefore take time — or may simply not be the most practical solution at the beginning.

In this case study, we show how INTER.GROUP helped a foreign-owned Hong Kong company find a practical alternative through a regulated EMI/payment institution when traditional banking proved difficult.

Client Background

The client was an overseas entrepreneur who had established a Hong Kong private limited company for international B2B services.

The company had:

• one foreign director and shareholder;
• no Hong Kong resident director;
• no physical office or employees in Hong Kong;
• customers in several international markets;
• suppliers and contractors located outside Hong Kong;
• payments primarily in USD and EUR.

The business itself was straightforward and legitimate.

However, because the company was newly incorporated, it had no previous banking history, audited financial statements or significant transaction history.

The founder needed an account to start receiving payments from customers and paying business expenses. His original plan was simple:

The Challenge

The client approached traditional banking options shortly after incorporation.

During the onboarding process, banks requested substantial information about the business, including:

• background of the director and shareholder;
• source of funds;
• expected annual turnover;
• countries involved in transactions;
• major customers and suppliers;
• contracts and invoices;
• reasons for establishing the company in Hong Kong;
• expected account activity;
• evidence of actual business operations.

This was not unusual. The difficulty was that the company had only recently been established.

Some customer negotiations were still in progress. The company did not yet have a long transaction history, audited financial statements or several months of bank statements demonstrating established operations.

The founder found himself in a common situation:

Waiting indefinitely was not practical. Customers were ready to sign contracts, and the company needed a professional way to receive payments.

Our Assessment

When the client approached INTER.GROUP, our first step was not to immediately submit another bank application. Instead, we reviewed the business.

We looked at:

• the company’s activity;
• ownership structure;
• director’s professional background;
• expected customers;
• suppliers and contractors;
• geographical exposure;
• expected currencies;
• average transaction size;
• expected monthly turnover;
• source of initial company funding;
• available contracts and commercial correspondence.

The objective was to understand what type of payment solution the company actually needed. In this case, the immediate requirement was not lending, trade finance or complex banking products.

The company primarily needed to:

• receive international customer payments;
• hold several major currencies;
• convert currencies where necessary;
• pay suppliers and contractors;
• maintain transaction records;
• operate through an online business account.

This meant that a regulated EMI or payment institution could potentially satisfy the company’s immediate operational needs.

A Different Approach: EMI Instead of Waiting for a Bank

We explained to the client that a traditional bank account and an EMI/payment account are not necessarily the same product.

A bank may provide a much broader range of services, such as lending, credit facilities, trade finance and other banking products. An EMI or regulated payment institution generally focuses more specifically on payments and money movement.

Depending on the provider and jurisdiction, a business payment account may offer features such as:

• multi-currency balances;
• local or international payment details;
• incoming international transfers;
• outgoing business payments;
• foreign exchange;
• online account management;
• payment cards or expense tools;
• integration with business platforms.

For a company whose immediate objective was to collect customer payments and pay suppliers internationally, these features could be sufficient.

The client therefore decided not to make traditional banking approval a prerequisite for starting the business. Instead, we explored suitable regulated payment providers.

Step 1: Selecting an Appropriate Provider

Not every EMI or payment institution is suitable for every business.

Providers have different acceptance policies regarding:

• jurisdictions;
• industries;
• ownership structures;
• transaction volumes;
• countries of incoming and outgoing payments;
• currencies;
• business models.

We therefore did not simply recommend the provider with the fastest online application. We considered whether the client’s expected activity matched the provider’s onboarding profile.

This is important because opening an account with a provider that does not properly understand or support the company’s business can create problems later.

Step 2: Preparing the KYC Package

The next stage was preparing the application.

The client already had the standard Hong Kong corporate documents, including:

• Certificate of Incorporation;
• Business Registration Certificate;
• Articles of Association;
• shareholder information;
• director information;
• registered office details;
• company secretary information.

However, these documents only established the legal existence of the company. The payment provider also needed to understand the business behind it.

We therefore helped the client prepare additional information explaining:

• what the company actually does;
• who its customers are;
• how customers are acquired;
• what services are provided;
• which countries are involved;
• expected monthly turnover;
• expected number and size of transactions;
• currencies required;
• source of initial funding;
• purpose of the account.

We also collected available supporting evidence. This included customer correspondence, draft agreements and other commercial documents demonstrating that the company was preparing to conduct genuine business.

Step 3: Explaining the Transaction Flow

One of the most important elements of the application was the transaction flow. A weak description might simply say “International consulting business.” That tells the compliance team very little.

Instead, we helped the client explain the expected flow more clearly. For example:

The explanation included:

• where customers were located;
• what customers were paying for;
• typical invoice amounts;
• expected monthly payment volume;
• countries where contractors were located;
• purpose of outgoing payments;
• currencies involved.

The transaction pattern was commercially logical and consistent with the stated business model. This made the application easier for the provider’s compliance team to understand.

Step 4: Source of Funds and Business Background

The provider also requested information about the founder.

We helped organise the explanation of:

• professional background;
• previous business experience;
• source of personal funds;
• source of the initial capital used to fund the Hong Kong company;
• reason for establishing the business in Hong Kong.

This is an important part of financial onboarding. A provider is not only assessing the company. It also needs to understand the individuals who ultimately own and control it.

The founder provided the requested supporting information, and we ensured that the information submitted across different parts of the application remained consistent.

Step 5: Compliance Questions During Onboarding

During the review, the payment provider asked several additional questions. This is normal.

Rather than treating additional questions as a negative sign, we helped the client respond clearly and provide additional supporting documents where necessary.

The questions related primarily to:

• expected customers;
• business geography;
• transaction volumes;
• commercial agreements;
• company activity.

Because the business model had already been properly documented, the client could answer these questions consistently. This avoided contradictory explanations and unnecessary confusion during onboarding.

The Result

Following the provider’s independent compliance review, the Hong Kong company was approved for a business payment account. The solution allowed the company to begin its international operations without waiting for a traditional bank account.

The company was able to:

• receive customer payments;
• make payments to suppliers and contractors;
• hold supported currencies;
• convert currencies;
• manage transactions online;
• maintain proper payment records.

For the founder, this solved the immediate operational problem. The company could start doing business.

Most importantly, the client understood that the EMI account was not necessarily a permanent replacement for every type of banking service. It was a practical solution appropriate for the company’s current stage.

Building a Banking History

Once the account became operational, we advised the client to maintain good transaction discipline. For each significant payment, the company retained appropriate supporting documents, including:

• invoices;
• contracts;
• payment confirmations;
• supplier documents;
• account statements;
• commercial correspondence where relevant.

This documentation served several purposes. It supported the company’s accounting records. It would later assist with audit and tax preparation. It could also demonstrate genuine business activity if the company decided to approach a traditional bank again in the future.

Over time, the company would be able to present something that was not available immediately after incorporation:

EMI and Traditional Bank Accounts Can Coexist

An important lesson from this case was that the decision did not have to be bank or EMI.

Different financial institutions may serve different purposes. A company might use a payment institution for international collections and currency conversion while maintaining a traditional banking relationship for other requirements.

The appropriate structure depends on the individual business. For this client, using an EMI/payment institution allowed operations to begin while traditional banking remained an option for the future.

Why the EMI Application Worked

There was no guaranteed outcome. The provider made its own independent onboarding decision. However, several factors helped make the application understandable:

These are important factors regardless of whether a company applies to a traditional bank, digital bank, EMI or other regulated payment institution.

Important Limitations

An EMI/payment institution is not automatically equivalent to a traditional bank.

The exact legal status of the provider, protection of customer funds, available services and regulatory framework depend on the institution and the jurisdiction in which it is licensed.

Companies should therefore consider:

• who regulates the provider;
• where the provider is licensed;
• how customer funds are safeguarded;
• which currencies are supported;
• payment limits;
• account fees;
• geographical restrictions;
• prohibited or restricted activities;
• whether the solution meets the company’s specific business needs.

The cheapest or fastest provider is not necessarily the most appropriate one.

Key Takeaways for Foreign-Owned Hong Kong Companies

Conclusion

For this client, difficulty opening a traditional bank account did not prevent the Hong Kong company from starting operations. By analysing the company’s actual payment requirements and preparing a clear compliance package, INTER.GROUP helped the founder explore a suitable regulated EMI/payment institution as an alternative route.

After the provider completed its own compliance review, the company obtained the payment functionality it needed to start receiving customer funds and paying business expenses.

The solution was not about bypassing banking requirements. It was about identifying a regulated financial product that better matched the company’s circumstances at that stage of its development.

At INTER.GROUP, we help Hong Kong companies prepare for banking and payment provider onboarding by reviewing corporate documents, ownership structures, KYC information, business descriptions and expected transaction flows.

We cannot guarantee approval by any bank, EMI or payment institution, and the final decision always remains with the financial institution. But when traditional banking is difficult, we can help clients understand the alternatives and prepare a stronger, clearer and more professional application.