KYC

Banking & Cash Management Challenges in South East Asia

Report date: 
10 Jul 2025

Commentary

ASEAN (The Association of South East Asian Nations) has a population of over 600 million. This is more than the EU (450m) or the United States (340m). Its ten member states provide an impressive level of diversity, for history and culture, but also in politics, economic development and prosperity. The broad range of rules and approaches make it a challenge to manage treasury operations. But the population, economic dynamism and key role in global supply chains make it a crucial player in world trade.

The pattern on this call is not a surprise: Singapore is the most advanced and open economy in ASEAN. For most companies, it is part of their international cash pooling and sweeping mechanisms, along with Hong Kong, Australia and, to some extent, China. The Philippines, Indonesia, Malaysia and Thailand are open economies, but they generally require FX to be executed onshore, and cash pooling is usually via intercompany loans: automated sweeping is not allowed. Vietnam remains more difficult. Myanmar, Cambodia and Laos, continue to be highly regulated and short of hard currency. 

Despite their FX restrictions, several countries have incentives for MNCs to set up Regional Treasury Centres (RTCs). These are usually able to transact outside the exchange controls – usually excluding domestic transactions.

Cash pooling: Singapore is the only country in ASEAN where cross-border cash pooling does not present any issues. Regional cash pools are usually based there or in Hong Kong. Most of the other countries allow domestic pooling and sweeping, though experiences vary. They typically do not allow automated cross border pooling, which is instead achieved by making intercompany loans, usually manually, and subject to various approvals. 

Exchange controls: most ASEAN currencies are convertible, at least for goods imports. However, in many cases (again, excluding Singapore), the FX trade has to be executed onshore, with the USD or EUR then transferred outside the country. These trades are usually done from an offshore location. Thai baht can be paid out of Thailand, but the regulation is not ...

 

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Topics covered in this report: 
ASEAN, Bank Relationships, Cash Pooling - cross border, Cash Pooling - domestic, Trapped cash, KYC, Cash Repatriation, FX, Regional Treasury Centre, Regulatory relationships
Service providers discussed in this report: 
JP Morgan, DBS, Standard Chartered, Deutsche Bank, Citi, HSBC, Bank Ayudhya (MUFG), MUFG, Mizuho, Bank of America, Bank of PhilippineIslands, Bank Negara Malaysia, Bangkok Bank, Kyriba, Starfish Digital

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Managing KYC & AML in Corporate Treasury

Report date: 
27 Jan 2025

Commentary

KYC – we all love to hate it, together with its sibling, AML. One participant on the call even joked that KYC really stands for “Kill Your Customer”.

So, after more than ten years, where do we stand? Are things improving? Are we seeing an adoption of standardised data requests and central depositories? Or are banks still coming up with new requirements, and often repeating the same requests within their networks?

If anything, things are getting worse. Increasingly, companies are setting up dedicated internal departments just to handle KYC requests. 

Data

  • Data requirements still have not been standardised
    • Requirements vary by country
    • Banks do not accept that some information does not exist in all countries
    • There is inconsistency. The same bank will insist on an item in some countries, but not others
  • New requirements keep surfacing. For listed companies, banks are increasingly requiring personal data on management and directors. This is an extension of the UBO (Ultimate Beneficial Owner) requirement for private companies.
  • Some countries require,,,,
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Topics covered in this report: 
KYC, AML
Service providers discussed in this report: 
Citi, Société Générale, ING, BNP Paribas, JP Morgan

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Corporate Treasury KYC & AML Issues and Approaches

Report date: 
29 Nov 2023
Topics covered in this report: 
AML, KYC
Service providers discussed in this report: 
JP Morgan, Citi, Barclays, Standard Chartered, ING, Santander, BNP Paribas, Bank of America, SWIFT, Kyriba, Ethixbase, CoorpID, HSBC, Avallone

Please email Rupert at rupert@complexcountries.com if you have any comments to add, or discussion points you would like to raise on this topic.

Treasury Policies & Processes for Crypto Transactions

Report date: 
26 Jan 2023

Commentary

This call took place five days after FTX filed for bankruptcy. However our discussion did not dwell on crypto as an investment (We haven't found a treasurer who would). The interest for treasurers is to help their companies understand the business opportunities of the metaverse, and that isn’t going away.

According to Gartner,’ [https://www.gartner.com/en/articles/what-is-a-metaverse] by 2026, 25% of people will spend at least one hour per day in a metaverse for work, shopping, education, social media and/or entertainment’, and…’A metaverse is not device-independent, nor owned by a single vendor. It is an independent virtual economy, enabled by digital currencies and non-fungible tokens (NFTs).’

So it's no surprise that many companies are developing strategies to capitalise on what could be a massive business opportunity. Participants in this call comprised treasurers representing companies at different stages of this journey, all facing the challenge that the regulatory and financial infrastructure available is at an early stage of evolution.

  • About half of the participants are still investigating the use of crypto and exploring how it works in case it does evolve within their businesses, but still not necessarily wanting to accept crypto or handle crypto within treasury operations.
  • Risk management to enable safe use in Corporate Treasury remains paramount and it isn’t easy.
  • We are seeing continued evolution around the NFT space and using crypto for settlement. But it continues to be quite limited.
  • Accounting requirements for how crypto currencies are handled are still not clear and not necessarily sustainable for the future. Regulations are going to evolve.
  • It is fascinating to hear, for the first time, crypto working capital
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Topics covered in this report: 
Wallet providers - crypto, NFT, Working Capital, Metaverse, KYC, API, CBDC, Crypto currency
Service providers discussed in this report: 
Coinbase, Mt Pelerin, Bit Panda, Etherium, Anchorage, Decentraland, Somnium Space, Coinfund, Churning Group

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FX & Treasury in Chile

Report date: 
31 Oct 2022

Commentary

For many years, Chile has been the poster child for Latin America: after a very difficult period in the early 1970s, it has become a haven for economic and political stability, with an economy which works well, few or no exchange controls, and an environment which is more business friendly than virtually any other country in the region.

The scenario has been somewhat tarnished since 2019, with violent public protests against rises in the cost if living, and a contentious referendum on changing the constitution – changes which were rejected by a large majority. However, in fairness, it must be said that the current constitution dates from the rule of General Pinochet, and the reaction of all political parties appears to have been that the proposal was too radical, and needs to be modified to reflect the wishes of the electors.

Against this background, all participants in the call confirmed that Chile is business friendly. For one, it has become a major market, while several others have made significant recent investments and acquisitions there. No participant has any serious doubts about the country or its future, and all view the absence of FX controls as greatly simplifying their lives.

However, all is not roses, mostly due to slow progress in administrative areas:

  • There is a lot of bureaucracy. In particular, FX trades must be reported to the central bank, even though they are all allowed.
  • The country seems to be slower than most in adopting digitalised banking. Wet signatures are required for virtually every payment and transaction, with no exceptions, even during COVID. This adds a layer of cost and inefficiency, which is surprising – Argentina and Brazil score better on this.
  • Most foreign banks seem to have a weak presence. Citi operates through a partnership with a local bank, Banco de Chile. This works quite well, but you have to ask, for example, to get the benefit of group pricing or to access Citi’s banking platforms. These are available through Banco de Chile, but they do not necessarily advertise the fact.
  • Many other foreign banks are present, notably Santander and HSBC. But it does not seem to be a focus market for them. 
  • The regulations are onerous, and
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Topics covered in this report: 
Hedging FX, FX, Bank Relationships, KYC, Cash Pooling - cross border, Cash Pooling - domestic
Service providers discussed in this report: 
HSBC, Citi, Santander, BBVA, Bank of America, JP Morgan, Scotia, Banco de Chile, Banco BCI, BancoEstado, BancoSecurity, 360T, FXall, Deloittes

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Treasury & FX in China

Report date: 
14 Mar 2019

Included in this report: Entrustment pools, cross-border pooling, electronic BADs

Topics covered in this report: 
Entrustment loans, Bankers Acceptance Drafts, KYC, Invoicing, Cash Pooling - cross border, Cash Pooling - domestic, Bank Relationships, Supply Chain Finance, Funding
Service providers discussed in this report: 
SWIFT, ICBC, Bank of China

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