Every month we file corporate account applications across roughly two dozen banks and EMI (electronic money institution)A licensed firm that can issue e-money and run payment accounts, such as many app-based business accounts. on behalf of clients. (An EMI is an electronic money institution, a payments company that isn't a full bank.) Banking isn't simply hard. Each bank's appetite is specific, dated, and uneven. A profile a Swiss private bank won't look at is routine for a Dubai commercial bank. A structure that closed in Singapore in February is being onboarded in Luxembourg in August. This is our read of the market as it stands this month.
What has tightened since the spring
Banks are asking tougher questions in three areas.
1. Proof of where your money came from. Source-of-wealth documentation for Beneficial owner (UBO)The real person who ultimately owns or controls a company or trust, behind any chain of companies. (the people who ultimately own the company) has gone from filling in a form to producing evidence. Banks want the chain: how the wealth was created, who paid it, what the tax position was, and what the paper trail looks like. At most top-tier institutions, a one-page story signed by the client no longer cuts it on its own.
2. Directors who are just a service provider. Nominee and formation-agent directors are now a red flag at a growing number of correspondent-facing banks (banks that deal with other banks abroad), rather than a neutral fact. If your only director is a service provider in the same country as your registered office, expect questions you can't answer without changing the board.
3. Crypto-linked revenue. Banks now ask about it explicitly, even if you don't run a crypto business. A software company with 8% of revenue from a digital-asset exchange client is now a different file from one with none.
Where is bank appetite open?
Some doors are open, but each has conditions. Here's the picture side by side.
| Where | Who it suits | What they want to see |
|---|---|---|
| UAE (Dubai and Abu Dhabi commercial banks) | Trading, consultancy, logistics and holding structures with real local presence | A genuine office, a resident director or manager with a visa, and a business explanation that matches the licence activity |
| Luxembourg and Ireland | Fund and holding vehicles | A fund administrator, an auditor and an identifiable regulatory perimeter |
| Switzerland and Liechtenstein | Private wealth, above the threshold | Roughly CHF 2m or more of investable assets |
| UK | Trading businesses with UK substance | A UK-resident director, a UK address that isn't a mail-forwarding service, and UK customers or suppliers |
| Mauritius and Georgia | Groups that want a backup | Not first-choice banking, but useful as a backup rail so you don't depend on one account |
A few notes on the detail.
UAE. It's still the most reliable route. What's required hasn't softened. What has improved is speed: files that took twelve weeks in 2024 are closing in five to seven when the pack is complete on day one.
Luxembourg and Ireland. Institutional appetite for regulated and regulated-adjacent structures remains strong. This isn't a route for operating small and medium businesses.
Switzerland and Liechtenstein. Appetite exists, but the bar has moved. Relationships below roughly CHF 2m of investable assets are no longer commercially interesting to most private banks. Several have exited the sub-CHF 5m segment entirely for non-resident clients, with little announcement.
UK. Challenger and mid-tier banks are onboarding again, but almost exclusively where the UK substance above is in place.
- You run a trading, consultancy, logistics or holding business with real local presence
- You can have a genuine office and a resident director or manager with a visa
- Your business explanation matches your licence activity
- You want a shell company with no operations and no local director
- You're a small operating business looking at Luxembourg or Ireland
Where has bank appetite closed?
Four profiles are being turned away or, worse, closed down.
- Shell Holding companyA company whose main job is to own shares in other companies. with no operations, no local director and no clear reason to bank in the chosen country. Relationship managers decline these before compliance even sees them.
- Money-services and payment-adjacent businesses that ask for a general commercial account without saying what they do. The bank usually finds out, and the account gets closed, not just declined.
- High-risk-jurisdiction beneficial owners without a documented economic link to the country where they want to bank.
- Personal accounts for non-residents with no local tie, at almost every European bank.
How should you sequence an application?
Order of operations is the biggest single factor in whether you get an account. We work backwards, in four steps.
- 1FirstPick where you'll bankdecide the banking jurisdiction before the incorporation jurisdiction, not after
- 2SecondBuild the packcorporate documents, ownership chart, source-of-wealth evidence, twelve-month cash-flow projection, sample contracts and named counterparties
- 3ThirdApproach one bank at a timeapply properly to a single bank rather than several at once
- 4Soon after the first approvalOpen a backup accountdo it while the first account is healthy
1. Decide the banking jurisdiction before the incorporation jurisdiction. A company is easy to form and hard to bank. Form first and ask where it can bank later, and you end up with a company you can't use.
2. Build the pack before you approach anyone. An incomplete first submission sets the tone for the whole file.
3. Approach one bank at a time, properly. Five parallel applications generate five declines faster than one well-prepared application generates one approval. Declines are also increasingly visible to other institutions in the same market.
4. Open the backup account within ninety days of the first approval. The time to open a second account is while the first is healthy.
What does this mean for a structure you're designing now?
If you're designing a structure in the second half of 2026, assume the bank is the binding constraint, meaning the thing that limits what you can do, and design around it.
That usually means one more layer of substance than the tax analysis strictly requires. Think a resident director, a real address, and an operating rationale a compliance officer can repeat back in one sentence. (Yes, one sentence. Compliance officers are busy people.)
FAQs
How long should a corporate account realistically take?
Five to seven weeks in the UAE with a complete pack. Eight to sixteen weeks in Europe. Anyone promising two weeks is quoting an EMI, not a bank.
Is an EMI an acceptable substitute for a bank account?
For payments, often yes. For holding balances, taking merchant settlement or supporting a lending relationship, no. Treat EMIs as rails, not as treasury.
Does a declined application harm future applications?
Sometimes. Declines aren't centrally recorded, but relationship managers in the same market talk, and some application forms ask directly whether you've been refused.
Can you guarantee an account?
No, and nobody honest can. What can be engineered is a materially higher probability, by matching profile to institution before applying.
