Stricter compliance is not a trend — it is the new reality. For banks, non-resident clients are more likely to fall into the
heightened risk category: it is more difficult to assess tax status, source of funds, jurisdictional exposure, and sanctions-related risks.
In practice, this often leads to a standard scenario:
document request → transaction restrictions → termination of the banking relationship (sometimes without room for “discussion”).
Below is a practical breakdown of the main reasons and what should be prepared in advance.
1) Why Banks Have Become Stricter with Non-Residents
Key drivers include:
- AML/KYC requirements (anti-money laundering, client identification, and source of funds verification)
- CRS / automatic exchange of information and increased responsibility for proper tax classification
- Sanctions regimes and the risk of exposure through beneficiaries, counterparties, or correspondent banks
- Regulatory fines for insufficient oversight and weak internal procedures
The conclusion is straightforward: a bank protects not only itself, but its licensed operations. If a risk appears unmanageable, the bank will prefer to terminate the relationship.
2) The Most Common Reasons for Closing a Non-Resident Account
A. Inconsistent Source of Funds
The expected narrative is clear: funds are received → the origin is understandable → the reason for using this specific bank is logical → the purpose of funds is transparent.
If instead the bank sees mixed sources, intermediaries, or transit patterns, the probability of issues increases significantly.
B. Profile Mismatch
In the onboarding questionnaire — “consulting/freelance.”
In reality — trading-level turnover, mass payments, currency operations, multiple counterparties.
For compliance, this signals either inaccurate disclosure or incomplete transparency.
C. Transit Transactions Without Clear Economic Logic
The “money in – money out” pattern, especially across different currencies or involving third parties, is one of the primary triggers for review.
D. High-Risk Jurisdictions and Sensitive Connections
Importantly, the connection does not need to be direct. Counterparties, beneficial owners, or payment routes through certain banks or countries may be sufficient for elevated risk classification.
E. Communication with the Bank
An underestimated factor.
Ignoring requests or providing overly generic responses is often interpreted as reluctance to disclose information. This frequently results in termination, regardless of the client’s actual background.
3) A Document Checklist to Have Before the First Request
Many clients begin gathering documents only after an account restriction. At that stage, time is limited and the bank may already have formed a negative risk view.
Personal / Status
- Proof of residential address (utility bill / bank statement)
- Tax residency confirmation (certificate / tax status documentation)
- Tax declarations (where relevant) and explanation of the tax model
Source of Funds / Source of Wealth
- Employment contracts or service agreements and proof of income
- Documentation of dividends or interest income
- Sale agreements for assets (real estate, shares, securities) + proof of proceeds
- Evidence of accumulated savings (where applicable) with a logical capital formation history
If You Operate Through a Business
- Ownership structure (ownership chart) and UBO details
- Corporate documents and licenses (where applicable)
- Financial statements / management accounts
- Key contracts with counterparties
- Evidence of substance (office, employees, operational infrastructure — where relevant)
Transaction-Level Support
- Clear explanation of large or unusual transactions
- Invoices, acceptance acts, specifications, logistics documents (for trading activities)
- Margin or commission calculations (for agency/intermediary models)
The key point: banks are not interested in isolated “files.” They assess a coherent narrative — a unified and logical picture of the activity.
4) Red Flags That Most Often Lead to Account Closure
Based on practical experience:
- Using the account primarily as a transit account
- Repeated “loan” payments without economic justification or proper servicing
- Agency schemes without transparent margins or documentation
- “Structure for the sake of structure” — multiple entities without business purpose
- Turnover significantly exceeding declared income or business scale
- Business without infrastructure (zero substance) but with substantial cross-border flows
- Frequent switching of banks or attempts to “move on” after a compliance incident
- Vague payment descriptions and template-style explanations
Important: sometimes a single red flag is sufficient — especially if the bank is conservative or under increased regulatory supervision.
5) What Actually Works (and Reduces Risk)Accurate description of your profile and business model at onboarding
- A prepared source of funds / source of wealth package
- Transparent payment references and clear economic rationale
- Disciplined communication: prompt and precise responses
- Preliminary risk assessment before opening or changing a bank
Practical Conclusion
Today, a non-resident bank account is not merely a “banking product” — it is an ongoing relationship with compliance.
Those who manage transparency proactively — rather than reactively — are at a clear advantage.