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Bank Account for a Foreign Company: How an Offshore Company Passes the Bank Review

Opening a bank account for a foreign company: how to pass a bank or EMI review, beneficial owners, source of funds and wealth, activity profile, plan B.

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Offshora · Practical guides

A bank account for a foreign or offshore company is opened by a bank or payment institution after its own review of the company (KYB) and its owners. Registering a company and opening an account are two independent procedures, and a certificate of incorporation does not guarantee an account. The bank assesses the combination of owners, industry, payment countries, turnover and documents, so preparation starts before registration.

The basis for this review is the international FATF standard: Recommendation 10 requires financial institutions to identify the customer and its beneficial owner, understand the purpose and intended nature of the business relationship and then monitor transactions. That is where the bank's questions about owners, money and deals come from.

Step 1. Define which transactions you need

There are four different needs. The first is receiving international transfers to the company's account details. The second is holding balances and managing funding. The third is accepting customers' cards, including recurring subscriptions. The fourth is paying many contractors and suppliers in different countries.

A bank, an EMI, a PSP and a merchant of record each cover different parts of this chain. The protection of funds also differs between them. Deposits in EU banks are protected by deposit guarantee schemes up to EUR 100,000. Payment and electronic money institutions must protect customer funds through safeguarding: in the UK, under FCA rules, by segregating them from their own funds or by insurance or a guarantee. An EMI IBAN looks like a bank IBAN, but the account is subject to a different legal regime. The comparison is in the article EMI vs bank account.

Describe one real payment: a client in Germany pays the company EUR 8,000 for services, part of the amount goes to a contractor in Poland and part to a supplier in the US. Which documents accompany each transfer, where is the currency converted, who signs? An example like this is more useful to the bank than a general phrase such as "international services".

Step 2. Check the country and industry

Before registration, confirm three levels of acceptance with the bank or EMI: the company's country of registration, the residency and citizenship of the beneficial owners, and the business model. Being able to register a company in the BVI or Belize says nothing about whether a particular EMI will serve it. Terms differ for IT, imports, investment projects, financial intermediation, crypto-assets and other regulated activities.

The list of currencies in a provider's advertising gives no answer. Ask directly: will a company with this owner, in this industry and with these counterparties pass the review? A positive preliminary answer does not guarantee a decision, though it does filter out obvious mismatches. A payment service usually publishes the list of countries where it operates on its website; for SaaS, separately check card acquiring and recurring payments.

Step 3. Show the chain of beneficial owners

Show the whole chain of shareholdings down to individuals: names, shares and control, country of residence, intermediate companies and the basis of the directors' authority. If control runs through an agreement, it is also disclosed to the extent the bank requests.

You usually need the passports of authorized persons, proof of address, recent registry extracts, constitutional documents and resolutions on signing authority. The bank sets how recent the documents must be and how they must be certified.

A common cause of delay is that the applicant sent the subsidiary's documents but has no recent extracts for two foreign shareholders higher up the chain. Fixing the ownership structure before applying is easier than during the review.

Step 4. Separate source of funds and source of wealth

Source of funds explains the origin of the specific money that will come into the company's account: the owner's capital, the sale of an asset, revenue, an investment or a loan. Source of wealth describes how the owner built their wealth: a business, salary, real estate deals, inheritance and other verifiable sources.

Personal documents are sent at the bank's request, but it is worth knowing in advance which evidence will be needed. For an initial contribution from the sale of a business you will need the transaction documents and the bank route of the money; for trading revenue, the contract, invoice, delivery documents and counterparty details.

A complex investment deal is better described as it is: trying to present it as "consulting services" creates a far greater risk. Prepare a short account of the origin of funds and a list of supporting documents.

Step 5. Describe the future transactions

The KYB questionnaire will ask for a forecast of incoming and outgoing payments per month, the average payment, the main countries and currencies, the five largest counterparties and the reasons for international money flows. The bank then compares the declared profile with actual transactions.

A trading company needs purchase contracts, transport documents and a description of each intermediary's role. An agency needs a website, portfolio, master agreements and statements of work (MSA/SOW), invoices and information about the team. A holding company needs documents for its shareholdings, an investment policy, expected dividends and loans.

If the business changes noticeably after the account is opened, update the profile in advance. Otherwise even lawful transactions look like a deviation from the declared model.

Step 6. Work out the real cost of the payment route

Free account opening says nothing about the cost of the service. Look at the fees for incoming SWIFT and outgoing transfers, currency conversion, third-party payments, account maintenance, the minimum balance, responses to document requests, refunds and crediting times.

A trading company with a dozen large transfers and a SaaS business with thousands of small card payments need different calculations. Calculate on the forecast turnover, and at the same time assess the risk of a temporary block, transfer limits and how fast payments are confirmed to suppliers.

Step 7. Prepare a plan in case of refusal

A bank may refuse without a detailed explanation. That is why you need a fallback: a second suitable bank or EMI, a different payment product or an adjustment to the corporate model. Dozens of simultaneous applications with different descriptions of the business do more harm than good.

After a refusal, keep a list of the information submitted, check for inconsistencies in the documents and the business profile and decide whether to change provider. A refusal from one bank does not yet mean that no one will serve the company.

A package worth preparing in advance

Constitutional documents and a registry extract, an ownership chart down to individuals, passports and proof of address, resolutions on signatories, a website or a short product presentation, a sample contract and invoice, a list of countries and a payment forecast, documents on the source of the initial funds. For complex groups, add financial statements and a chart of intra-group payments.

Appoint one person who answers the bank's questions and makes sure the information matches everywhere. The signatory in the corporate resolution must be the same person who goes through the review, and the website, business activities and expected payments must tell one story.

Frequently asked questions

Can an account be opened remotely? Sometimes it can. It depends on the identification rules of the specific financial institution and its assessment of the client's risk; the registered agent does not set these conditions.

Is one US LLC with an EIN enough? For a bank, that is not enough. The questions about beneficial owners, address, clients' activities and the chosen banking product remain in any case.

Can all the money be kept with one EMI? This is a question of how the funds are safeguarded, the service terms and concentration of risk. For a company with significant working capital a backup route is especially important.

The full list of KYB documents is collected in the guide to KYC and KYB for a company. How to choose a bank for the planned payments is covered in how to choose a bank for a foreign company, and which payment models more often lead to a refusal in the review of banking risks.

What Offshora delivers is a coordinated sequence: a suitable corporate form → KYB package → choice of payment product → bank review → support during the first months of operations. Details are on the service page bank account for an offshore company, and the choice of country is in the offshore jurisdictions section. Describe the company's country and money flows to get an assessment of a realistic route.

Tell us about your task, and we will propose a jurisdiction, the scope of services and the order of work.

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Describe the business, the owners’ residency and your clients’ countries. We will suggest a suitable jurisdiction and prepare a proposal for registration, ongoing support and banking.

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