Banking due diligence

The bank is assessing a continuing relationship

Banks operate within domestic anti-money-laundering, sanctions and other regulatory requirements, informed by international standards such as the FATF Recommendations. The current FATF framework was amended in June 2026. Each jurisdiction and institution implements its own procedures and risk appetite.

An application therefore involves more than proving that a company exists. The bank may need to understand beneficial owners and controllers, the purpose of the relationship, tax residence, source of funds and expected activity. The depth of enquiries depends on the facts and applicable requirements; there is no universal checklist that guarantees acceptance.

How the analysis fits together

Bank selection should start with the account’s actual use. A personal account receiving savings, an operating business accepting customer settlements and a holding company receiving dividends have different transaction narratives. Identify currencies, expected volumes, counterparties, countries and the reason for using the chosen bank. A generic claim of international business gives an underwriter little basis for assessing the application.

The application should reconcile the legal entity with the people controlling it and the activity that generates its funds. Inconsistencies between ownership charts, contracts, website descriptions and bank statements often create follow-up questions. If the activity is regulated or restricted, describe it directly and establish the relevant permissions. Acceptance is also a commercial decision: a complete file can still fall outside a bank’s appetite.

Assessment sequence

This is a review framework. The applicable domestic provisions and any relevant treaty determine the result in a particular case.

Explain the commercial story first

Prepare a short description of what the business sells, who buys it, where work occurs and how money moves. Link that account to contracts, invoices, financial statements, websites and ownership records. If the legal structure has several entities, explain why each one exists and which account receives which payments.

For an online business, distinguish customer payments, marketplace settlement, payment-processor reserves, refunds and intercompany transfers. Identify actual counterparties where available. Saying that all deposits come from a payment platform may describe the last transfer while leaving the underlying business unexplained.

Choose a bank that fits the use case

Match the institution to the industry, owner residence, entity jurisdiction, currencies, payment volumes and need for cards or merchant services. A private-banking account designed for custody may not suit daily operating payments. An electronic-money or payment account can have different protections from a bank deposit.

Confirm the contracting entity, fees, service limitations and treatment of funds. FINMA’s guidance illustrates the distinction between eligible deposit protection and segregated custody assets in Switzerland. Equivalent labels in another jurisdiction can operate differently, so inspect the actual institution and product.

Keep the file useful after opening

Assign responsibility for updates to ownership, addresses, activities and tax status. Retain transaction evidence in a form that makes a later request straightforward. Unexpected large transfers are easier to explain when the underlying sale, distribution or contract documentation is already organised.

We can assess banking fit, prepare the application narrative and coordinate suitable introductions as part of a wider implementation or individual banking engagement. The objective is a durable account relationship that supports the business’s real activity, with an appropriate backup for payments the business cannot afford to interrupt.

Common misunderstandings

• An introduction does not constitute account approval.
• A payment institution and a bank may provide different protections and products.
• The quality of a bank match includes usability, fees, currencies, custody and continuity—not just opening the account.