1. Popular Background
   In recent years, the Hong Kong Securities and Futures Commission (SFC) has tightened licensing thresholds, yet market demand for Type 1, 4, and 9 licenses remains strong. Many entrepreneurs use BVI companies as holding platforms because incorporation is fast, maintenance is inexpensive, the tax regime is simple, and privacy protection is available. But how do we balance BVI’s “veil of secrecy” with Hong Kong’s compliance disclosure requirements?
2. Privacy Myths: Directors vs. Shareholders

Item	Can be searched online with payment?	Who can access?	Risk Alert
Director List	✅ Yes	Anyone	If seeking a low profile, consider professional or corporate directors, but note Economic Substance rules
Shareholder List	❌ No	Only BVI-licensed attorneys	UBO must still be disclosed to banks, tax authorities, and the SFC

🔍 Key Point: BVI “anonymity” applies only to the public—not to financial institutions or regulators.

3. Bank Account-Opening Challenges

• Prepare KYC/CDD documents early: passport, notarized documents, proof of funds
• Demonstrate Economic Substance: current BVI ES law requires “mind & management” or “sufficient activities”
• Consider dual structure: use a BVI holding company, then set up a Hong Kong or Singapore operating company for local banking
• Budget timeline: six to nine months from application submission to a usable account is not uncommon

4. How Does This Align with SFC Disclosure Rules?

• Must report UBO (natural persons) to the SFC, together with audited accounts and an organizational chart
• Public SFC records list only:
  • Responsible Officers
  • Individual licensed persons
  • Licensing status, business address
  • Any disciplinary actions
• They do not disclose shareholder or BVI-level information

🧩 Tip: Many applicants think “reporting = public disclosure.” In reality, reporting to regulators is a confidential due-diligence process.

5. Timeline & Document Checklist

Period	Main Actions	Key Documents
Week 1–2	BVI Incorporation	Certificate of Incorporation, M&A, Board Resolutions
Week 2–6	Document Notarization & Apostille	Notarized certificates, Legal opinions
Week 4–12	Bank Due Diligence	KYC, Business plan, Proof of funds
Week 8–20	HK Company Registration + SFC Online Application	Group chart, Bank certificates, Financial projections
Month 6–9	SFC Supplementary Docs & Site Visit	Internal controls, Compliance manual, IT solutions

6. Alternative Options Overview

• Cayman: Favoured by international funds; higher cost, strict audits
• Delaware LLC: Recognisable to US clients; but complex US tax filing
• Hong Kong local shareholding: Most transparent disclosure; fastest banking; lacks offshore tax benefits

7. Conclusion: Three Key Points
8. BVI anonymity applies only at the public level—it offers no help with regulators or banks
9. The SFC must see the ultimate natural persons, but will not publish them
10. Prepare KYC documents early and stay aligned with banks, auditors, and lawyers to avoid licensing delays