Bank-readiness self-check for trade businesses

Run this before you apply for a business account, so you find the mismatches instead of the bank. It is general know-your-business (KYB) practice and it does not predict what any bank will decide. Each bank sets its own requirements, so confirm its list before you apply.

The idea behind the list: a bank has to understand who owns the company, what it does and why it wants the account. Under FinCEN's customer due diligence rule, covered banks keep procedures to identify customers, identify and verify beneficial owners, understand the nature and purpose of each customer relationship, and monitor activity. Your job is to make that easy to see, and to make every document tell the same story.

How to use it: tick each box, and where you can't, write down why. A gap you know about can be explained. A gap the bank finds first is harder.

1. Entity and EIN

• The legal name on your formation documents is exactly the name on the EIN letter, the application and the website footer. Compare "Inc." vs "LLC", commas and spelling.
• You have your formation documents (articles of organization or incorporation) and, if the bank asks, a current good-standing certificate from the state.
• You have the IRS letter that confirms your EIN. The IRS lists ways to confirm an EIN, including Letter 147C by phone, if you have lost the original.
• The entity type matches what you tell people. If you say "we are a corporation" but formed an LLC, fix the wording.
• Your state registration is active and your registered agent is current.

Non-US owner without an EIN yet? See how does a non-US owner get an EIN for a US business.

2. Registered address vs operating address

• You know which address is the registered address (often a registered agent) and which is where the business actually operates, and you can say why they differ.
• The address on the application matches your proof of address, such as a lease, utility bill or official letter. Banks differ on what proof they accept, so ask.
• The same address, or a clear explanation, appears on your website, invoices and marketplace profiles.
• If goods ship from a warehouse or a 3PL, write that down. A bank reading "Wyoming LLC" and a Miami warehouse should not have to guess.

3. Owner residency and ownership

Banks look at where the owners are as part of understanding the customer. The FFIEC exam manual lists the geographic location where the customer does business among its risk factors (FFIEC BSA/AML Manual, Customer Due Diligence). Living abroad is not a disqualifier by itself. It is something to state plainly.

• You can list every owner, their percentage and their country of residence, and the percentages add up to 100.
• Your ID is current and not about to expire. Name and date of birth match the ownership records.
• You have proof of residential address for owners if the bank asks for it.
• If owners live outside the US, the application says so up front instead of leaving it to be found.
• You know who will use the account day to day, and that person can provide ID.

4. Beneficial owners and control person

FinCEN's CDD rule requires covered banks to identify and verify each individual who owns 25 percent or more of a legal entity customer, plus one individual who controls it.

• Every person with 25 percent or more is named, with full legal name, date of birth, address and ID number. The exact fields vary by bank form.
• One control person is named, such as a CEO, managing member or other senior manager.
• If ownership runs through another company, you can trace it to the individuals at the end.
• Your operating agreement or cap table matches what you wrote on the form.
• You plan to tell the bank if ownership changes later.

5. Website matches the business description

A reviewer will often look at your website. Treat it as a document.

• The site exists, loads and is not a placeholder or "coming soon" page. Some banks accept businesses without a site, so ask.
• The company name, address, email and phone on the site match your application.
• The products and services on the site are the ones you describe to the bank. If you say "wholesale electronics" and the site sells perfume, change one of them.
• The customer type matches. If you tell the bank you sell to retailers, the site should not read like a consumer shop, or it should explain both.
• Your marketplace or storefront profiles say the same thing as your website.
• You have removed claims you can't back up with a document.

6. One product and industry description, everywhere

• You have written one or two plain sentences: what you buy, where from, who you sell to. Example from our account documents guide: "We import consumer electronics from suppliers in Asia and sell to US retailers."
• That sentence is the same on the application, website, invoices, supplier contracts and any deck you send.
• The industry code or category you pick on forms fits the sentence. Forms often use NAICS codes, so check the bank's wording.
• If your product category needs a permit or special handling, you have checked that with a professional.
• You have checked the bank's list of businesses it won't serve.

7. Expected volumes and counterparties

The FFIEC manual says anticipated account activity can be a key factor in a customer's risk profile. A volume you can support beats a big number you can't.

• You have a realistic monthly estimate of money in and out, and roughly how many payments that means.
• You can say which countries you pay suppliers in and receive customer money from.
• You can name your main suppliers and customers, or describe them by type if names are confidential.
• You know how customers pay you (wire, ACH, card, stablecoins) and how you pay suppliers.
• You plan to tell the provider before volume, countries or payment methods change materially. See why banks close or freeze trade accounts.
• Customers will pay you directly, and suppliers will be paid in their own names, not through unnamed third parties.

8. Source of funds and proof of trade

• You can explain where the money entering the account comes from: customer payments, owner funding, loans.
• Owner funding has a paper trail, such as a transfer from the owner's own account and a note on what it was for.
• You have a few recent invoices, purchase orders or contracts that fit the story. For exporters with sales history, see how small exporters prove past export sales to banks and lenders.
• If the business is new, you can offer supplier quotes, purchase orders or a short business plan, and you say plainly that it is new.
• Personal and business money are not mixed.

9. Final consistency pass

Lay the documents side by side and compare each field.

• Every cell matches, or you have a written reason it doesn't.
• Scans are complete and readable, not cropped.
• You can answer follow-up questions the same day.

If something doesn't match

Fix the source document if you can. If you can't, add a short factual note to the application ("registered agent address in X, operations in Y"). Don't change facts just to make the forms agree. Banks decide case by case, and passing this self-check does not mean approval.

Next step

Once the self-check is clean, look at Shield business accounts. Owners can live outside the US, with a US company.

Sources

• FinCEN, Customer Due Diligence Requirements for Financial Institutions
• FFIEC BSA/AML Manual, Customer Due Diligence
• IRS, Employer ID Numbers