Before a bank opens an account for a foreign-owned company it must identify the company, its directors and the individuals who own or control it, and verify them from independent sources. The 25% ownership test for beneficial owners is common to the UK, US and UAE, and Singapore requires the bank to walk away if it cannot complete due diligence. Some countries add local steps, such as France's blocked capital account before registration or India's integrated incorporation form that includes the bank account.
What every bank will ask for
Anti-money-laundering rules require the bank to know who the customer is, who acts for it and who ultimately owns or controls it. In the UK a bank must identify and verify a corporate customer's name, company number, registered office, directors and senior managers, and understand its ownership and control structure. It must also take reasonable measures to verify the beneficial owners and cannot rely only on the Companies House register.
Singapore's MAS Notice 626 sets out the same elements: identify and verify the customer, each person acting for it and its beneficial owners, and understand the purpose of the relationship. If the bank cannot complete these measures it must not open the relationship. For a group with layered holding companies, the practical work is preparing a clear ownership chart down to the individuals, with identity documents for each.123
The 25% test and recent US relief
In the US, covered financial institutions identify each individual owning 25% or more of a legal entity customer's equity and one individual with significant control. The UAE uses the same 25% threshold for controlling ownership and falls back to the individual who exercises control only where no one meets it.
Since FinCEN ruling FIN-2026-R001 of 13 February 2026, a US bank may choose to collect and verify beneficial-owner information when a customer first opens an account rather than at every new account, provided the customer certifies that earlier information is still accurate. This is optional for each bank, so a group opening several US accounts should still expect repeat requests.456
Local steps that depend on the bank account
In some countries the account is part of company formation. In France the cash share capital of an SAS, SARL or SA must be deposited in a blocked account with a bank or notary before the articles are signed, and payment institutions are not accepted for this. In India the SPICe+ incorporation form includes opening a bank account alongside tax and social security registrations, and commercial banks apply the RBI's Know Your Customer Directions, 2025.
Banks can refuse. In France a bank that refuses a business account must issue a written refusal certificate within 15 days, and silence beyond 15 days counts as a refusal, which opens the right-to-an-account procedure through the Banque de France.78910
| Market | Rule | Figure or condition | Source |
|---|---|---|---|
| United Kingdom | Identify and verify company, directors, ownership; verify beneficial owners | Cannot rely only on Companies House | Money Laundering Regulations 2017, reg. 28 |
| United States (federal) | Beneficial owners of legal entity customers | 25% equity plus one controller; 2026 option to verify once | 31 CFR 1010.230; FinCEN FIN-2026-R001 |
| United Arab Emirates | Controlling ownership interest | 25% or more; else person exercising control | CBUAE CDD guidance |
| Singapore | Customer due diligence before business relations | No relationship if CDD cannot be completed | MAS Notice 626 |
| France | Refusal to open business account | Written certificate within 15 days | service-public.fr |
| India | Commercial bank KYC | RBI KYC Directions, 2025 | RBI Master Directions |
Decisions to make
- Can the group show every individual who owns or controls 25% or more of the account-holding company?246UK, US and UAE banks identify beneficial owners at this level, and incomplete charts are the main cause of delay.
- Does the country require a bank account before the company can be registered?78In France the capital deposit certificate is needed for registration; in India the account is opened through the incorporation form.
- Will the bank rely on earlier beneficial-ownership information for later US accounts?5The 2026 FinCEN relief is optional, so timelines depend on each bank's policy.
- What happens if a bank refuses?103France gives a formal refusal certificate and a route to a designated bank; elsewhere the business must find another bank.
Documents usually needed
- Certified constitutional documents and certificate of incorporation of the account-holding company
- Group ownership chart down to individual beneficial owners, with percentage holdings
- Identity and address evidence for directors, authorised signatories and beneficial owners
- Board resolution authorising the account and naming signatories
- Description of expected activity, counterparties, countries and transaction volumes
- For France, the certificate of deposit of share capital; for the UK, an extract of the PSC register
Common mistakes
- Submitting an ownership chart that stops at a holding company rather than the individuals behind it
- Assuming a registry filing will satisfy the bank; UK banks cannot rely on Companies House alone
- Leaving the bank account until after incorporation where it is part of formation, as in France and India
- Not explaining the purpose and expected flows of the account, which banks must understand under MAS and UK rules
- Expecting the US 2026 beneficial-ownership relief to apply at every bank
Questions businesses ask
Why does the bank want details of the parent company's shareholders?
Because it must identify the individuals who ultimately own or control the customer, usually at a 25% threshold in the UK, US and UAE, not just the immediate shareholder.246
Can a payment institution hold share capital for a new French company?
No. The deposit must be made with a bank or a notary; payment institutions are not accepted.7
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- Saudi Arabian and German bank onboarding requirements for corporate customers were not researched in this module.
- Typical account-opening times and minimum balances are not stated by official sources and are not given.
- The text of India's KYC Directions, 2025 could not yet be checked; only their title and update date are confirmed.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Banks and other regulated firms must identify and verify a corporate customer, including its name, company number, registered office, directors and senior managers, and understand its ownership and control structure. Money Laundering Regulations 2017 regulation 28. Listed companies on a regulated market are exempt from some of these requirements.
Reused from market guide claim gb-banking-001.
Regulated firms must identify and take reasonable measures to verify a customer's beneficial owners, and cannot rely solely on information filed at Companies House to do so. Money Laundering Regulations 2017 regulation 28(4) and (9).
Reused from market guide claim gb-banking-002.
Under MAS Notice 626, a bank must perform customer due diligence when it establishes business relations, including identifying the customer and verifying its identity from reliable, independent sources, identifying each person who acts on the customer's behalf, identifying beneficial owners and taking reasonable measures to verify them, and obtaining the purpose and intended nature of the relationship. For a company, the bank also identifies the legal form, constitution and powers that bind it, and its connected parties. The June 2025 amendments, effective 1 July 2025, extended the rules to digital token transfers and refined requirements for legal persons, trusts and beneficial owners.
The amendment notes reproduce the current Notice 626 text with the June 2025 changes marked; MAS says the published version prevails. The Notice 626 web page shows last revision 30 June 2025, effective 1 July 2025; the current consolidated PDF could not yet be checked. Wording also matches the 28 March 2024 version. Reused from market guide claim sg-banking-g01.
Covered financial institutions must identify and verify the beneficial owners of a legal entity customer when it opens an account: each individual who owns 25 percent or more of the equity interests, and a single individual with significant responsibility to control, manage or direct the entity. Federal customer due diligence rule, 31 CFR 1010.230(b) and (d). Separate from, and not replaced by, the narrowed FinCEN beneficial ownership information reporting regime. See us-banking-g03 for 2026 relief on repeat account openings.
The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register. eCFR text up to date as of 15 October 2026; no 2026 amendment to this section was shown. Reused from market guide claim us-banking-g02.
Under FinCEN ruling FIN-2026-R001 of 13 February 2026, covered financial institutions may identify and verify a legal entity customer's beneficial owners only when it first opens an account, when they have information calling earlier data into question, and as needed under their risk-based procedures, instead of at every new account. Federal. Optional for each institution. Where an institution relies on earlier information in a risk-based review, the customer must certify that it is up to date and accurate. Other Bank Secrecy Act obligations, including suspicious activity monitoring, continue.
Linked from FinCEN's CDD Final Rule page. Reused from market guide claim us-banking-g03.
For a corporate customer, CBUAE-licensed financial institutions should identify and verify every individual who alone or jointly holds a controlling ownership interest of 25% or more, and only where none exists fall back on the individual who exercises control. CBUAE-licensed financial institutions (banks, exchange houses, finance companies and others). Sections 3.2.2 and 3.2.5 of the guidance; customers should generally be identified and verified before the relationship is established.
The Rulebook shows the guidance as in force with an effective date of 7/11/2025, but its legal-basis section still cites the 2018 AML law and its 2019 executive decision, which have been replaced. Confirm the current version with the bank. Reused from market guide claim ae-banking-g10.
For an SAS, SARL or SA, cash share capital must be deposited in a blocked account with a bank or a notary before the articles are signed and before registration; payment institutions are not accepted and the Caisse des dépôts has not taken deposits since 1 June 2021. Commercial companies. The deposit is optional for civil companies. The depositary issues a certificate of deposit required for registration.
Reused from market guide claim fr-establish-007.
SPICe+ is the Ministry of Corporate Affairs' integrated web form for incorporating a company, with Part A for name reservation and Part B covering incorporation, director identification numbers, PAN and TAN, EPFO and ESIC registration, GSTIN and opening a bank account, filed with linked eMoA, eAoA and AGILE-PRO-S forms. Professional tax registration through the form applies to new companies in Maharashtra and Karnataka only (a state-level registration). Central filing.
Reused from market guide claim in-establish-009.
Commercial banks apply the Reserve Bank of India (Commercial Banks – Know Your Customer) Directions, 2025, shown as updated as on 1 October 2026. Separate KYC directions apply to small finance, payments, local area, regional rural and co-operative banks. Central rule (RBI).
The listing was opened; the directions' content was not reviewed. Reused from market guide claim in-banking-008.
A French bank may refuse to open a business account, but it must issue a written refusal certificate within 15 days of receiving the request, and silence for more than 15 days counts as a refusal. The certificate must give the reason and mention the right to an account through the Banque de France.
Reused from market guide claim fr-banking-001.
Questions on this topic
10 statements on opening corporate bank accounts and kyc
