About the bank
ICBC (Industrial and Commercial Bank of China) — the world's largest bank by total assets (about $6.7 trillion at end-2024; over ¥53 trillion, more than $7 trillion, at end-2025 — the first bank in the world to pass the 50-trillion-yuan mark). One of four state-owned commercial banks in the PRC, the "Big Four", listed on the Shanghai and Hong Kong stock exchanges. Has over 16,000 branches throughout China and 400+ overseas offices in 47 countries.
ICBC — primary lender for China's large corporate sector, handles a significant share of external trade settlement in the country. For foreign companies, historically a standard choice when opening corporate accounts in mainland China.
Current status for HK companies
Since October 2022, ICBC stopped accepting applications for corporate account opening from HK companies whose UBO holds Russian citizenship. There was no formal public announcement — applications simply stopped progressing after the compliance review stage without stated reason. This policy remains in force as of 2026 and also covers Belarusian and in certain cases Kazakh beneficiaries without European or Middle Eastern residence permits.
For other profiles (beneficiaries from EU, UK, UAE, Singapore, Hong Kong) ICBC formally opens accounts, but with two significant limitations:
- Physical presence of the director or shareholder in Shanghai for 5–7 days during account opening. Video interview is not accepted.
- Manual compliance review at pre-approval stage can take up to 60 business days with additional source of funds queries. The process can terminate in a refusal at any stage.
In June 2024 ICBC formally joined the sanctions-compliance perimeter against sanctioned Russian banks — part of the general tightening across the Big Four.
In private.law practice we stopped actively supporting ICBC account opening in 2024 due to unpredictable timelines and low open rate (~40% even for clean non-RU UBOs).
What we recommend instead of ICBC
For beneficiaries from EU/Asia/UAE without RU/BY ties: 🏛 Bank of China — same scale and reputation, but more predictable process and video interview instead of physical presence.
For Russian and CIS beneficiaries holding another country's residence permit: 🌊 Bank of Dalian or Langfang Bank.
For Russian beneficiaries without a residence permit: 🐻 Harbin Bank — the regional pioneer of Russian-Chinese banking, which accepts an RF passport without requiring foreign residence.
For trade finance in the mid-market: ⚡ Everbright Bank (a joint-stock bank with a Sinosure channel) or Ping An Bank (technology-led supply-chain finance).
Our track record with ICBC
From 2021 to 2024 private.law opened 69 accounts through ICBC (each HK company opened 3 currency accounts — USD/EUR/CNY). Of these:
- 42 accounts — approved and active (all non-RU UBOs with physical visit)
- 15 accounts — closed by the bank in first year of service after compliance policy change
- 12 accounts — rejected at compliance review stage (some of them — after passing video interview and pre-approval)
This track record shows that for our client base (significant portion with RU ties or complex international structures) ICBC ceased to be a viable channel.
Russian clients: a de facto refusal across the Big Four
Q/A
Can an ICBC account be opened at all?
For a UBO with no Russian or Belarusian ties, with a physical visit to Shanghai and a documented business model — yes, given luck and patience. The approval rate in our practice is ~40% even for clean profiles, and opening takes up to 60 business days.
Why is ICBC stricter than Bank of China?
ICBC is the world's largest bank, with the densest exposure to Western correspondent networks. Any sanctions breach creates cascading risk, so the bank optimises for minimising compliance risk — which costs it flexibility on non-standard profiles.
Do you open ICBC accounts for Russian nationals?
No — ICBC has applied an unconditional refusal since October 2022.
What about deposit insurance?
ICBC participates in China Deposit Insurance, covering up to ¥500,000 per depositor.
What about CRS and FATCA?
ICBC participates in both CRS and FATCA, and reports non-resident account information to the tax authorities of the holder's country of residence.
What is the minimum turnover?
For active servicing — around $100,000 a month for a mid-sized business. The large-corporate segment has no explicit minimum and runs on individual pricing.