The HKMA has noted that some authorised institutions have started to on-board individual customers remotely through electronic channels and others are exploring such options, the circular says. While “the HKMA supports technology and innovation”, it warns that remote on-boarding may present greater risks to authorised institutions – particularly impersonation risks – compared to traditional on-boarding models.

“There are also factors which aggravate the risks, such as the speed of electronic transactions, the ease of making multiple fictitious account applications and the use of stolen identities which, when made remotely, may be more challenging to be deterred and detected,” the circular says.

Authorised institutions should employ technology solutions “at least as robust as those performed when the customer is in front of the staff” to mitigate the risks when identifying and verifying the identity of an individual customer, it says.

Remote onboarding technology solutions should be able to authenticate customer identities, such as through acquiring a document image via a mobile app, with appropriate measures to ensure the reliability of documents, data and information obtained.

The technology should also be able to link customers “incontrovertibly” to the identity provided in the document image, such as through biometric solutions like facial recognition and liveness detection.

The circular notes the ongoing development of an eID (electronic identity) for Hong Kong residents, which it says would be “an acceptable technology solution for remote on-boarding.”

Under the government’s plan, Hong Kong residents will be able to use eIDs free of charge for access to government and commercial electronic services, including online banking, payments, e-commerce and digital signatures.