The Bank and EMI Onboarding Evidence Pack for Family Holding Structures

Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.

ownership/control chart

ownership/control chart must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. The board should identify a named owner, the authority under which that person acts, the evidence relied upon and the point at which specialist advice is required. A control is not complete merely because a policy exists: the record must show how the control operated, who challenged it and how exceptions were closed. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

ownership/control chart must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. A practical file should distinguish source documents from management assertions, record the date and provenance of each item, and preserve the reasoning that connects evidence to a decision. This makes the position reviewable by a successor, counterparty or adviser without reconstructing events from fragmented correspondence. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

ownership/control chart must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. Implementation should be proportionate to the structure. Smaller offices may combine roles, but they should not combine incompatible approvals without a documented compensating review. Larger arrangements need a controlled register, review calendar, escalation thresholds and evidence of closure. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

business and purpose narrative

business and purpose narrative must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. A practical file should distinguish source documents from management assertions, record the date and provenance of each item, and preserve the reasoning that connects evidence to a decision. This makes the position reviewable by a successor, counterparty or adviser without reconstructing events from fragmented correspondence. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

business and purpose narrative must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. Implementation should be proportionate to the structure. Smaller offices may combine roles, but they should not combine incompatible approvals without a documented compensating review. Larger arrangements need a controlled register, review calendar, escalation thresholds and evidence of closure. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

business and purpose narrative must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. The board should identify a named owner, the authority under which that person acts, the evidence relied upon and the point at which specialist advice is required. A control is not complete merely because a policy exists: the record must show how the control operated, who challenged it and how exceptions were closed. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

The value of governance evidence lies not in document volume, but in whether the next decision-maker can understand, review and carry it forward.

source-of-wealth/source-of-funds coordination

source-of-wealth/source-of-funds coordination must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. Implementation should be proportionate to the structure. Smaller offices may combine roles, but they should not combine incompatible approvals without a documented compensating review. Larger arrangements need a controlled register, review calendar, escalation thresholds and evidence of closure. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

source-of-wealth/source-of-funds coordination must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. The board should identify a named owner, the authority under which that person acts, the evidence relied upon and the point at which specialist advice is required. A control is not complete merely because a policy exists: the record must show how the control operated, who challenged it and how exceptions were closed. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

source-of-wealth/source-of-funds coordination must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. A practical file should distinguish source documents from management assertions, record the date and provenance of each item, and preserve the reasoning that connects evidence to a decision. This makes the position reviewable by a successor, counterparty or adviser without reconstructing events from fragmented correspondence. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

expected activity and response register

expected activity and response register must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. The board should identify a named owner, the authority under which that person acts, the evidence relied upon and the point at which specialist advice is required. A control is not complete merely because a policy exists: the record must show how the control operated, who challenged it and how exceptions were closed. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

expected activity and response register must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. A practical file should distinguish source documents from management assertions, record the date and provenance of each item, and preserve the reasoning that connects evidence to a decision. This makes the position reviewable by a successor, counterparty or adviser without reconstructing events from fragmented correspondence. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

expected activity and response register must be addressed within the full governance context of “The Bank and EMI Onboarding Evidence Pack for Family Holding Structures”. Implementation should be proportionate to the structure. Smaller offices may combine roles, but they should not combine incompatible approvals without a documented compensating review. Larger arrangements need a controlled register, review calendar, escalation thresholds and evidence of closure. For this topic, the working file should answer the control proposition—Align ownership, control, activity, source of wealth and funds, expected transactions and governance narrative.—and separately record ownership, timing, evidence, exceptions and review outcomes.

Limitations

This article provides general governance information only. It is not legal, tax, accounting, investment, regulatory or fiduciary advice. Facts, jurisdictions, documents and professional duties alter the analysis; qualified relevant advisers should confirm the position before action is taken.

Primary-source register

Hong Kong Monetary Authority — account opening FAQs and business account information
HKMA customer due diligence guidance