2. Notices from the Hong Kong company to its registered shareholder must be sent no earlier than 1 March 2018 in order for such notice to be effective.

3. Responses must only come from the Significant Controller itself.

4. If a Hong Kong company is a direct subsidiary of a listed company, then effectively only the registered shareholder of the relevant Hong Kong company will have to confirm (and not the intermediate companies nor persons above the listed company). See extract from the Companies Registry Guideline which shows an example of which level should file.

5. The Significant Controller should respond to the notice within one month from the date of the notice. If the Hong Kong company does not receive a response by the one month deadline, it should insert the following note in its register:

“The company has given a notice to person(s) whom it knows, or has reasonable cause to believe, to be a registrable person/ registrable legal entity of the company, but the person has not yet complied with the requirements of the notice within 1 month from the date of that notice.”

6. The Hong Kong company should keep a copy of the above notice for record.

Client Alert 2018-048