How to open an account in a foreign bank?

Just a few years ago, opening an account with a foreign bank seemed extremely complicated. Today, it is a practical tool: settlements with EU counterparties, salary payments from a foreign employer, business relocation. The problem is different: a foreign bank does not “sell” accounts — it selects its clients. Let us examine the procedure step by step.

Can a Ukrainian open a foreign bank account?

There are no formal prohibitions: accounts abroad can be opened by individuals, sole proprietors and companies. Ukrainian citizenship is not in itself a ground for refusal, and there are no sanctions against Ukrainian clients as such.

The issue is not the legal right to open an account, but the review process. The bank expects answers to three “why” questions: why you need an account specifically in this country, where the funds come from, and what transactions you plan to carry out.

Personal and corporate accounts

These are two different products: in the first case, the bank assesses the individual; in the second, it assesses the business model and the structure behind it.

How should you choose a country and a bank?

The choice should not begin with a ranking of institutions, but with the question of what the account is needed for. The jurisdiction should be connected with your activities: an account in a country where you have no counterparties, assets or tax connections raises the most difficult compliance question.

The next issue is the type of institution. A traditional bank offers reliability, lending and deposit protection. A payment institution is usually faster, but does not provide state-backed deposit guarantees.

What documents are required?

The list depends on the jurisdiction, but the basic set is predictable.

Documents for an individual

• an international passport and, as a rule, a second identity document;
• proof of residential address;
• proof of source of funds: an income certificate, an asset sale agreement, inheritance documents;
• a tax identification number and proof of tax residence;
• a questionnaire describing expected turnover and payment flows.

Documents for a company

For a company, constitutional documents, an extract from the register, the ownership structure down to the beneficial owner and key contracts are additionally required. Ukrainian documents almost always require an apostille and a sworn translation.

How can you prove your address and tax residence?

Proof of address must be provided as a separate document, not merely stated in the questionnaire. Banks usually accept a utility bill, a statement from another bank or a certificate issued by a public authority, generally no more than three months old. A tenancy agreement is not accepted everywhere.

Tax residence is confirmed through self-certification under the CRS standard and, where necessary, by a certificate issued by the tax authority. A discrepancy between the declared country of tax residence and the address shown in the documents is a common reason for additional questions.

Source of Funds and Source of Wealth

These concepts are often confused, although banks deliberately distinguish between them. Source of Funds refers to the origin of a specific amount that will be credited to the account: the sale of an asset, salary earned over a certain period, dividends. Source of Wealth refers to the origin of the person’s overall capital — in other words, how the applicant accumulated their wealth.

For moderate transaction volumes, the first may be sufficient. As the amounts increase, the bank moves to the second — and this is where many applications stall: it is easier to document a single transaction than an entire financial history.

Online opening or a personal visit?

Remote onboarding is mainly offered by payment institutions: video identification and an account opened within a few days. Traditional banks are more likely to require a personal visit or the signing of documents before a notary or at a consulate.

An online option is available in many cases, but it narrows the range of institutions: where lending, notarised settlements or large account balances are required, it may not be suitable.

How does the KYC/AML review work?

Compliance is the bank’s attempt to understand whether the client may create regulatory problems. The bank reviews not only the documents but also the logic behind them: whether the declared turnover is consistent with the documented income.

Additional questions arise when:

• turnover significantly exceeds documented income;
• the ownership structure includes offshore companies or nominee directors;
• the client or a family member is a politically exposed person (PEP);
• the activity is high-risk — crypto-assets, gambling, dual-use goods;
• counterparties are registered in jurisdictions subject to enhanced monitoring.

None of these factors is automatically fatal, but each requires an explanation prepared before the questionnaire is submitted.

Why do banks refuse?

Refusals are rarely random. Typical reasons include:

• there is no economic connection with the bank’s jurisdiction;
• the document package is incomplete or contradictory;
• the source of funds is explained verbally rather than supported by documents;
• the selected bank simply does not work with this type of client profile;
• negative information appears in public sources or compliance databases.

One costly nuance is that the bank may not explain the reason for refusal, while the fact of the refusal remains in its internal systems.

What should be considered after the account is opened?

Foreign income received by a Ukrainian tax resident is subject to personal income tax and the military levy, with an annual tax return required; tax paid abroad may be credited in accordance with the applicable double taxation convention. Information on account balances and turnover is reported to the tax authorities under the CRS standard.

There is also a technical side: the bank periodically updates the client questionnaire and may request supporting documents for individual transactions. An ignored request or prolonged inactivity is a common reason for account restrictions or blocking.

How do we help open an account with a foreign bank?

Opening an account is a project, not a one-off procedure. It begins long before the questionnaire is completed: with an analysis of the transactions the client intends to carry out and which jurisdiction can accommodate that profile without unnecessary questions.

The Prikhodko & Partners practice in international corporate law is built around this preparatory stage. Our lawyers assess the business structure and sources of funds from the perspective of a compliance officer, build documentary evidence of the origin of capital, select an institution suited to the client’s objectives and manage correspondence with the bank.

Prikhodko & Partners has experience with institutions in the EU, the United Kingdom, Switzerland, the UAE, Türkiye and the United States, including higher-risk clients such as IT companies, crypto projects and trading structures. The result here depends on the accuracy of the analysis, not on the number of applications submitted.

Are you planning to open a personal or corporate account with a foreign bank? The lawyers at Prikhodko & Partners will analyse your profile, help select the country and financial institution, prepare Source of Funds and Source of Wealth evidence, compile the KYC/AML package and support communication with the bank.