Business integrity checklist
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Business integrity checklist
Navigate the banking landscape with business integrity checklist and best practices

As banking regulations in the EU and US tighten, opening acquiring and corporate bank accounts is becoming increasingly challenging. The table below contains simplified lists of DO and DO NOT recommendations to help you navigate the complexities of the ever-changing banking landscape.

If your company falls under any of the red flag practices, you may trigger enhanced due diligence from the bank. This may result in a longer process and additional questions regarding your company’s substance, financials, source of wealth for the UBOs, and more.

DO DO NOT
Include in your group only companies incorporated in reputable jurisdictions. Include companies from "grey/black" jurisdiction lists in your ownership structure, such as Bulgaria, Croatia, Seychelles, Mauritius, and others.
Ensure your group has no trusts or nominee shareholders. Include a trust deed between beneficial owners and nominee shareholders.
Have a simple ownership structure, for example, a holding company and an operational company. Have a multilayered ownership structure with multiple legal entities in the ownership chain.
Have the company owned by known and publicly exposed UBOs. Have the company owned by "no public presence" or nominal UBOs without a proper business background.
Employ at least 2-3 local employees or contractors in the country where the company is incorporated to support operations and financial forecasts. Have no local employees or contractors to support operations and confirm the local substance.
Demonstrate an operational history (unless a company is a start-up). Have a company that has been inactive for years and only recently started operating.
Ensure the company's name relates to the business or product offered. Ensure that the company's name is unrelated to its business or products.
DO DO NOT
Provide audited financials for the previous year (Big Four audit report is a plus). Rely only on management accounts or have no financials or business plan (applicable only to start-ups).
Ensure that the company's contact details align with its jurisdiction or operations. Have the company's contact details provided from third countries and are not relevant to the jurisdiction of registration or operations.
Include in your financials reasonable expenses, such as employees, contractors, rent, and marketing. Maintain in your financials risk factors such as the absence of rent or employee expenses, significant "Other expenses", large outflows, and minimal or no profit.
Include market analysis, product positioning, and detailed financial forecasts in your business plan (applicable only to start-ups). Have a business plan that lacks detailed financial projections and does not align with UBOs' financial capabilities.
Ensure the company is profitable. Have a non-profitable company with high cash flow through marketing/reseller agreements to other companies.
DO DO NOT
Lease office space that accommodates several employees at a reasonable price. Lease office space for one person, such as one desk in a co-working space.
Ensure the company office is in a designated business area, not a residential or industrial zone. Have your company office in a residential or industrial area with no visible business presence.
Employ local employees and contractors to confirm the company's substance. Have no employees or contractors in the country where the company is incorporated.
DO DO NOT
Have a reputable, well-suited director along with a strong management team. Have a nominee director who manages hundreds of other companies without actual business involvement.
Ensure the director or manager has proof of address in the country of incorporation. Have a director or manager residing in a different country.
DO DO NOT
Ensure employees associate themselves with the business and some of them are local or their LinkedIn states this. Have no employees visible on social media associating with the company.
Provide a local phone number. Provide a phone number that belongs to another country.

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