AML and KYC Policy
The due diligence we carry out before accepting an engagement, and what we will ask you for.
Version 1.0 · Last updated August 16, 2026
Purpose
Corporate formation, entity administration and capital-routing services are attractive to anyone seeking to disguise the origin or ownership of funds. That is precisely why they are regulated, and why we carry out due diligence before accepting work rather than after.
This policy explains what we do and what we will ask of you. It applies to every client and to every engagement, without exception and regardless of the size of the fee.
Client due diligence
Before we begin work, we identify the client and verify that identity from reliable, independent documentation. We also establish who ultimately owns or controls the client, and the purpose and intended nature of the relationship.
For a corporate client
We will generally ask for:
- Certificate of incorporation or equivalent registration document
- Constitutional documents, such as articles of association
- Register of directors and register of shareholders, or equivalent
- Identification of the individuals who ultimately own or control the entity
- Evidence of the registered and, where different, operating address
- Confirmation of who is authorised to instruct us, and evidence of that authority
- An outline of the business, its source of funds and its expected activity in Hainan
For an individual client or a beneficial owner
We will generally ask for:
- A current government-issued photographic identity document
- Evidence of residential address dated within the last three months
- An explanation, with evidence, of the source of the wealth and the source of the funds involved
Ownership and control
We look through corporate layers to the natural persons behind them. Where ownership is held through intermediate entities, trusts or nominee arrangements, we ask for the structure to be explained and evidenced up to the individuals who ultimately benefit or control.
An ownership structure that cannot be explained is itself a reason to decline. Complexity without a commercial rationale is a risk indicator, not a formality.
Risk assessment
We assess each relationship for risk and set the depth of our due diligence accordingly. The factors we weigh include:
- The jurisdictions connected to the client, its owners and its counterparties
- Whether the client, an owner or a close associate is a politically exposed person
- The sector the client operates in and its exposure to cash or to sanctioned trade
- The complexity of the ownership structure and whether it has a clear commercial rationale
- The nature, scale and expected pattern of the transactions involved
- Whether the relationship is conducted entirely remotely
Enhanced due diligence
Where the assessment indicates higher risk, we apply enhanced measures before proceeding: additional verification, more detailed evidence of source of funds and source of wealth, senior approval to accept the relationship, and more frequent review once it is live.
Screening
We screen clients, their beneficial owners and, where relevant, their counterparties against applicable sanctions lists and against adverse media, both at onboarding and periodically afterwards.
A screening match does not automatically end a relationship — false positives are common and are resolved. A confirmed match against a list that applies to us does.
Ongoing monitoring
Due diligence is not a one-off gate. We keep client information current for the life of the relationship and review it on a schedule set by the risk rating, and additionally whenever something changes.
- A change in ownership, control or authorised signatories
- A change in the nature or scale of the client's activity
- A transaction inconsistent with what we understood the business to be
- A new connection to a higher-risk jurisdiction
- Adverse media or a new screening match
- Documentation reaching the end of its validity
When we decline or withdraw
We will not accept, and will withdraw from, an engagement where required documentation is not provided, where the ownership structure or source of funds cannot be satisfactorily explained, where a confirmed sanctions match applies, or where we have reason to believe the engagement would further a financial crime.
We may not always be able to tell you our reason. Where the law restricts what we may disclose, we will say only that we are unable to proceed. This is not evasiveness; it is a legal constraint, and it applies to every firm in this sector.
Reporting
Where we identify grounds for suspicion, we report to the competent authority in accordance with the law applying to us, and we act on any consequent restriction on proceeding.
Where the law prohibits us from disclosing that a report has been made, we will comply with that prohibition. You should not infer from anything we say, or decline to say, that a report has or has not been made.
Records
We retain due diligence records and the supporting documentation for the period the applicable law requires after the relationship ends, and no longer than we are permitted to. These records are held under the same protections as other client information — see our Privacy Policy and Data Protection Policy.
Responsibility
Responsibility for this policy sits with the firm's partners. Everyone who works on client engagements receives training on it on joining and periodically afterwards, and is required to escalate a concern rather than resolve it alone.
Contact
Questions about this policy may be sent to enquiries@hainaninc.com.