<aside>
⚠️
Fictional case for portfolio training only. No real person, company, or jurisdiction. Not a real STR. Not legal advice. Not investment advice.
</aside>
Snapshot
| Field |
Value |
| Case ID |
KYC-003 |
| Type |
KYC / CDD (EDD completed) |
| Risk rating |
High |
| Conclusion |
Pass |
| Controls |
Onboarding; Screening; CDD; EDD; Escalation; Ongoing monitoring; SOF/SOW |
| Project |
Simulated VATP KYC/AML Onboarding Pack |
Facts (fictional)
- Applicant: Marcus Veld (fictional), national of fictional Jurisdiction Q, applying as a non-resident retail client for a simulated SFC-licensed VATP account.
- PEP status (scenario design): Serving Deputy Minister of Commerce of Jurisdiction Q — a foreign senior government official → treated as a non-Hong Kong politically exposed person under Guideline ¶ 4.11.7(a). No real country or real official is named.
- Stated profile: Diversifying personal savings into VA tokens listed on the licensed platform; expected first-year funding about HKD 1.2 million; no leverage products sought in year one.
- Claimed SOF/SOW: (1) civil-service salary over the past 24 months; (2) proceeds from sale of a residential property in Q’s capital four months earlier.
- Channel: Remote non-face-to-face onboarding; passport + liveness selfie match; address verified via utility bill.
- Screening (fictional): Commercial PEP database clear hit (title + name + DOB match); no sanctions / terrorism / corruption-allegation / unexplained-wealth adverse-media hit.
- Documents initially provided: Passport; proof of address; selfie; PEP self-declaration questionnaire (answered “Yes — Deputy Minister”); 12 months of payslips; 6 months of bank statements showing salary credits; notarised sale-and-purchase agreement plus counsel confirmation that sale proceeds credited to the same bank account.
- EDD: Written SOW/SOF pack; cross-check against Q’s public ministerial biography (title/tenure consistent); senior-management approval pack prepared before account activation.
Regulatory requirement (primary)
Where the FI knows that a customer (or beneficial owner) is a non-Hong Kong PEP, before establishing the relationship it should (Guideline ¶ 4.11.12 / AMLO Sch. 2 as restated in the Guideline):
(a) obtain senior management approval;
(b) take reasonable measures to establish the customer’s source of wealth (SOW) and source of funds (SOF); and
(c) conduct enhanced ongoing monitoring of the relationship (Chapter 5).
¶¶ 4.11.13–14: SOW = how overall wealth was generated; SOF = the activity that produces the funds for this relationship — information should be substantive.
¶¶ 4.11.15–17: depth of measures is risk-based.
¶ 4.9 / high-risk situations: senior-management approval + SOW/SOF or other mitigating measures.
¶¶ 5.1–5.3: ongoing monitoring; for high-risk customers, CDD review at least annually (or more frequently).
FAQ Q13: SOW is required in high-risk situations (including non-Hong Kong PEPs), not for every customer.