Attorney, Family Office
Overview
Bank of China (BoC) — one of the four largest state-owned commercial banks in the PRC,"Big Four"(alongside ICBC, CCB and Agricultural Bank of China). Total assets exceed $4 trillion. For Hong Kong trading companies, BoC has historically been the primary channel for settlements into mainland China: high reputation, direct correspondent relationships with European and American banks, transparent fees.
After 2022, BoC tightened compliance criteria for foreign beneficiaries — the bank stopped opening accounts for HK companies whose UBO holds Russian citizenship. For other profiles, the channel remains operational: companies with UBOs from the EU, UK, UAE, Turkey, Singapore follow standard openment flow.
Permitted beneficiary jurisdictions
- Hong Kong, Singapore, Malaysia, Japan, South Korea
- UAE, Turkey, Saudi Arabia (subject to approval)
- EU, UK, Switzerland
- USA, Canada, Australia
For beneficiaries from other jurisdictions, we offer alternative options — seeCorporate account at ZCCB.
Available currencies
- CNY (primary)
- USD, EUR, GBP, JPY, HKD
- Additional currencies upon request
A separate sub-account with its own number is opened for each currency.
Documents required for opening
- Passport of director and shareholder (all pages)
- Articles of Association of HK company
- Certificate of Incorporation
- Business Registration Certificate
- Annual Return (NNC1 / NAR1)
- Audited financial statements (if company is over one year old)
- Business model description, one page
Opening stages
- Preliminary approval.We coordinate the project profile and cash flows with the bank.5–7 business days.
- Document submission and video interview.KYC review + interview with bank manager in English.3–5 business days.
- Original passport.After approval, director and shareholder must present original — in person at Shanghai office or via courier delivery.
- Activation and test deposit. 2–3 business daysafter receiving hardware tokens.
Total timeline —15–20 business dayswith clean KYC.
Fee
Our fee for full service —€7,000. The fee includes:
- Preparation of KYC package and business description
- Services of local associate in Shanghai
- Support during video interview with bank manager
- Delivery of hardware tokens to specified jurisdiction
- Activation and first deposit
Not included — bank fees listed below.
BoC fees
- Account maintenance:$150/month minimum.
- Payments within China:0.1% (cap CNY 1,000).
- International payments:0.1% (cap CNY 2,000).
- High-risk destinations:0.2%–0.4% (e.g., transfers to Belarus).
- Currency exchange:Bank of China rate, 0.2–0.6% to interbank.
- Fee reduction — upon reaching $5M annual turnover.
Permitted transactions
- Trade transactions (B2B)
- Consulting, service provision
- Cross-border settlements with European and Asian counterparties
Not permitted: crypto transactions, FX brokerage, gambling, precious metals without special license.
The rest of the Big Four: ICBC, CCB and ABC
Full profiles of ICBC, China Construction Bank and Agricultural Bank of China used to live on separate pages; their practical takeaways now live here. For a foreign trading company the working choice within the Big Four almost always comes down to Bank of China — the other three are either closed to non-standard profiles or unpredictable on timelines. Niche and regional alternatives are collected in the China banks map.
ICBC — the world's largest bank, and why we no longer file applications there
ICBC (Industrial and Commercial Bank of China) is the world's largest bank by assets ($5.7T+ in 2024, approaching $7T by end-2025), with 16,000+ branches in China, 400+ overseas offices in 47 countries and founding direct participation in CIPS. Since October 2022 it has stopped accepting applications from HK companies with Russian or Belarusian UBOs — applications simply stall at compliance review without stated reason; the policy also covers Kazakh beneficiaries without a European or Middle Eastern residence permit. In June 2024 the bank formally joined sanctions compliance against designated Russian banks. For other profiles two constraints apply: physical presence of the director or shareholder in Shanghai for 5–7 days (a video interview is not accepted, unlike BoC) and manual compliance review of up to 60 business days with source-of-funds queries.
Our track record 2021–2024: 69 applications through ICBC (each HK company opening three currency accounts, USD/EUR/CNY) — 42 accounts approved and active (all non-RU UBOs with a physical visit), 15 closed by the bank within the first year after the compliance shift, 12 rejected at review, some after pre-approval. A ~40% approval rate even for clean profiles is why we stopped actively supporting ICBC in 2024. If a mandate specifically requires it — SOE counterparties, top-tier trade finance — we can file, but Bank of China is the predictable first-tier alternative with a video interview instead of a visit.
China Construction Bank — infrastructure profile, unstable channel
CCB (founded 1954; ~RMB 45.6 trillion in assets by end-2025) grew out of financing construction and capital projects, and that heritage still defines its appetite: infrastructure, real estate, energy, settlements with state-owned enterprises. In our 2023–2025 practice the approval rate was roughly 25–30%: applications are blocked at compliance review without stated reasons, the bank is highly sensitive to unusual sources of funds, and a physical visit of the director to Shanghai is required — video does not replace it. CCB is not in our active catalogue; opening is possible but with no guarantee of timeline or outcome. Consider it only with a genuine Chinese infrastructure or SOE nexus (tenders, guarantees, letters of credit, long supply chains). For trading operations — Everbright; for large credit lines — Ping An; for RU profiles — regional banks from the map.
Agricultural Bank of China — agro profile, closed list
ABC (roots from 1951; the Big Four's largest branch network at ~24,000 outlets; ~RMB 48.8 trillion in assets by end-2025; FSB G-SIB bucket 2) runs the most conservative compliance of the four toward foreign beneficiaries. Since 2022 it has effectively worked from a closed client list: new applications from HK companies with RU/BY/KZ UBOs are rejected almost automatically, and other profiles need an agricultural nexus (grain, oils, fertilizers, agri-machinery) plus an introduction through an existing Chinese counterparty. We have not opened ABC accounts since 2023 and do not plan active support. Pre-2022 ABC account holders should focus on maintenance: annual-review documentation, sanctions screening, and keeping the legacy account separate from new contested structures. Agro traders without RU ties are better off starting with BoC; CIS beneficiaries with real Chinese goods flow — see Harbin and Dalian in the China banks map.
Related services
- 🇨🇳 Corporate account at ZCCB— alternative for beneficiaries not accepted by BoC
- 🇨🇳 China banks map — niches, pricing and timelines across mainland banks
- 🇭🇰 Hong Kong company— corporate structure for account
- 🐉 Financing in China— credit products from Chinese banks