For payment institutions, e-money institutions, crypto exchanges and other businesses that banks see as higher risk, opening a corporate account can take longer than obtaining the licence itself. The good news is that most refusals are predictable, and a well-prepared file changes the conversation.
This checklist is based on the questions banks and EMIs typically ask during onboarding.
Why banks are cautious
Banks carry the regulatory risk of the clients they serve. Payment and crypto businesses move third-party money, often across borders and at high volumes, so the bank must be confident that your controls are at least as strong as its own. When a bank cannot see how risks are managed, the easiest answer is no.
Your task is to make your business easy to understand and easy to monitor.
What banks look at
- Regulatory status: your licence or registration, the regulator and any conditions attached to it.
- Ownership and control: a clear structure chart down to the ultimate beneficial owners, with identification for each of them.
- Source of funds and wealth: where the company’s capital came from and how the owners built their wealth.
- Business model and flow of funds: who your customers are, which countries you serve and how money moves through your accounts.
- Compliance framework: AML/CFT policies, a business-wide risk assessment, transaction monitoring, sanctions screening and a named compliance officer.
- Expected activity: monthly volumes, number of transactions, currencies and main counterparties.
Documents to prepare
- Corporate documents: certificate of incorporation, articles, registers of directors and shareholders.
- Licence or registration and correspondence with the regulator.
- Identification and proof of address for directors and beneficial owners.
- CVs of directors, the MLRO or compliance officer and key managers.
- A business plan with financial projections and expected account activity.
- AML/CFT policy, risk assessment and customer due diligence procedures.
- A flow of funds diagram for every product.
- Contracts with key partners: acquirers, liquidity providers, technology vendors.
- Financial statements or management accounts, if the company already trades.
Keep the numbers consistent across all documents. Different volumes in the business plan and in the application form are one of the most common reasons for follow-up questions.
Which accounts you may need
| Account | Purpose |
|---|---|
| Corporate operating account | Salaries, rent, suppliers and the company’s own money |
| Safeguarding account | Segregated client funds of a payment or e-money institution |
| Omnibus account for client funds | Pooled client money with clear internal records |
| Multi-currency accounts and virtual IBANs | Collecting and paying out in several currencies |
| Correspondent accounts | Access to payment schemes and settlement for regulated institutions |
Many businesses combine a bank with one or more EMIs or banking-as-a-service providers. Having more than one partner also protects you if a single relationship is closed.
Common reasons for rejection
- Unclear ownership or missing information about beneficial owners.
- A business model that is hard to explain or changes during onboarding.
- High-risk countries or customer types without matching controls.
- Template AML policies that do not reflect the actual business.
- Slow or incomplete answers to the bank’s questions.
Practical tips
- Prepare a short cover memo that explains your business in one page.
- Name one person who answers the bank’s questions quickly and consistently.
- Apply to partners whose risk appetite matches your business; not every bank serves crypto or remittance.
- Plan for onboarding to take weeks or months, and keep your launch plan realistic.
If you need corporate, safeguarding or multi-currency accounts, see our services for financial institutions and services for crypto exchanges, or contact our team.
This article is for general information only and is not legal or financial advice. Bank and EMI requirements differ and can change without notice.
