Bank onboarding is governed by federal anti-money-laundering rules: banks must collect identifying information before opening an account and identify and verify a company's beneficial owners, with 2026 FinCEN relief allowing this once rather than at every new account. Cash transactions above 10,000 US dollars, cross-border movements of currency above 10,000 US dollars and foreign accounts held by US persons are reported. Deposits are insured by the FDIC up to 250,000 US dollars per depositor, per bank, per ownership category. Dividends paid abroad bear 30% withholding unless a treaty reduces it, and OFAC sanctions can freeze payments touching blocked parties.
Opening an account
Before opening an account a bank must obtain the customer's name, address and an identification number. For a newly formed US company that number is usually its EIN, which takes longer to obtain when the principal place of business is outside the US. For non-US individuals involved, a passport number and country of issue or another qualifying government document can be used. Foreign entities are also typically asked for Form W-8BEN-E to document their status for US withholding and reporting.
Under the federal customer due diligence rule the bank must identify and verify each individual who owns 25 percent or more of the company and one individual with significant control, such as the chief executive. Since FinCEN's ruling of 13 February 2026 a bank may do this when the company first opens an account and then rely on that information, with the customer confirming it is current, rather than repeating it for every new account. This bank-level check is separate from FinCEN's beneficial ownership reporting regime, which since August 2026 applies only to foreign-formed companies registered in a state. Expect banks to ask for ownership charts and identity documents for the whole chain up to the individuals.123456
Reporting, deposit insurance and sanctions
Banks file a currency transaction report for cash transactions over 10,000 US dollars, and anyone carrying, mailing or shipping more than 10,000 US dollars in currency or monetary instruments across the border must report it. A US company with foreign accounts whose combined value exceeds 10,000 US dollars at any time in the year must file an FBAR (FinCEN Form 114) by 15 April, with an automatic extension to 15 October. These are reporting duties rather than approvals.
FDIC insurance covers 250,000 US dollars per depositor, per insured bank, for each ownership category, and business accounts are their own category. Companies holding larger operating balances should plan how much sits at any one bank.
US banks screen payments against OFAC sanctions. Property of blocked persons that a US bank holds must be blocked and reported to OFAC within 10 business days, so a payment involving a sanctioned party or an entity it owns can be frozen rather than simply returned.78910111213
Repatriating profits
Dividends from a US subsidiary to a foreign parent are US-source FDAP income, taxed at 30% of the gross amount unless the Code or a treaty reduces the rate, and the US company withholds and reports the tax on Form 1042. Interest and royalties paid to group companies are treated the same way.
Planning repatriation means checking treaty eligibility, collecting documentation before payment, and aligning the timing of dividends with the annual withholding return.14151617
| Obligation | Trigger | Who files |
|---|---|---|
| Currency transaction report | Cash transaction of more than 10,000 US dollars | The financial institution |
| Report of cross-border currency movement | More than 10,000 US dollars in currency or monetary instruments at one time | The person transporting, mailing or shipping it |
| FBAR (FinCEN Form 114) | Foreign accounts with combined value over 10,000 US dollars at any time in the year | US persons, including US companies |
| OFAC blocked property report | Property of a blocked person comes into the holder's possession | US person holding the property, within 10 business days |
| FDIC insurance limit | 250,000 US dollars per depositor, per bank, per ownership category | Not a filing; limits protection of balances |
How it works, step by step
- Obtain an EIN4Internal Revenue Service
- Provide name, address and identification numbers for the company and identity documents for its 25 percent owners and a control person12US bank
- Provide Form W-8BEN-E where the account holder or payee is a foreign entity5US bank
- Diary the annual FBAR if the US company holds accounts abroad9FinCEN (BSA E-Filing)
No timings or fees are shown unless an official source states them.
Documents usually needed
- Certificate of incorporation or formation
- IRS EIN confirmation
- Ownership chart down to individuals holding 25 percent or more, and details of one control person
- Passport or other government identification for beneficial owners and signatories
- Form W-8BEN-E (foreign entities)
- Board resolution authorising the account and signatories
Common mistakes
- Leaving the EIN application until after formation, delaying the bank account.
- Assuming the August 2026 narrowing of FinCEN beneficial ownership reporting removes bank-level beneficial ownership checks; it does not.
- Keeping large operating balances at a single bank without regard to the 250,000 US dollar FDIC limit per ownership category.
- Forgetting the FBAR when a US subsidiary is added to a group bank account held abroad.
- Paying dividends abroad without the recipient's treaty documentation in place.
When the business crosses borders
- Treaty-reduced withholding depends on documentation from the recipient before payment.
- Banks will look through foreign holding companies to the individuals who own 25 percent or more, so groups with layered or nominee structures should prepare evidence early.
- US dollar payments cleared through US banks are screened against OFAC lists and may be blocked, even between two non-US parties.
- Moving more than 10,000 US dollars in cash or monetary instruments across the border must be reported, whichever direction it travels.
Questions businesses ask
Is tax withheld when profits are sent abroad?
Dividends, interest and royalties paid to foreign persons are generally subject to 30% withholding unless a treaty or the Code reduces it.1415
Will the bank ask about our parent company's owners?
Yes. Federal rules require banks to identify and verify each individual who owns 25 percent or more of a company opening an account, directly or indirectly, plus one individual with significant control. Since February 2026 banks may do this once at the first account rather than at every account.23
How much of our deposit is insured?
Up to 250,000 US dollars per depositor, per FDIC-insured bank, for each account ownership category. Company accounts are a separate category, and only deposits are covered.10
Do we need approval to move money in or out of the US?
The federal rules reviewed here impose reporting duties, such as cash transaction reports, cross-border currency reports and FBARs, rather than approvals. Sanctions can block specific payments. The absence of general exchange controls was not confirmed on an official page.78911
What this guide does not yet confirm
These points need checking with a qualified local professional in the United States before you rely on them.
- Exchange controls: the absence of general exchange controls was not confirmed against an official source (the IMF AREAER could not yet be checked).
- Federal and state rules on bank chartering and state money transmitter licensing for payment businesses were not researched.
- Treasury International Capital (TIC) and BEA reporting of cross-border financial flows by businesses, beyond the BE-13 survey, were not researched.
- FinCEN's April 2026 proposed rule on AML/CFT programme requirements was identified but not read; its effect on onboarding is unknown.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Before opening an account a bank must obtain at least the customer's name, address and an identification number; for a company the address is its principal place of business or other physical location, and for a non-US person the number may be a US taxpayer identification number, a passport number and country of issue, an alien identification card number, or another qualifying government-issued document number. Federal customer identification programme rule for banks, 31 CFR 1020.220(a)(2)(i)(A). Banks may ask for more under their own risk-based procedures.
The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register.
Covered financial institutions must identify and verify the beneficial owners of a legal entity customer when it opens an account: each individual who owns 25 percent or more of the equity interests, and a single individual with significant responsibility to control, manage or direct the entity. Federal customer due diligence rule, 31 CFR 1010.230(b) and (d). Separate from, and not replaced by, the narrowed FinCEN beneficial ownership information reporting regime. See us-banking-g03 for 2026 relief on repeat account openings.
The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register. eCFR text up to date as of 15 October 2026; no 2026 amendment to this section was shown.
Under FinCEN ruling FIN-2026-R001 of 13 February 2026, covered financial institutions may identify and verify a legal entity customer's beneficial owners only when it first opens an account, when they have information calling earlier data into question, and as needed under their risk-based procedures, instead of at every new account. Federal. Optional for each institution. Where an institution relies on earlier information in a risk-based review, the customer must certify that it is up to date and accurate. Other Bank Secrecy Act obligations, including suspicious activity monitoring, continue.
Linked from FinCEN's CDD Final Rule page.
An applicant for an employer identification number (EIN) whose principal place of business is outside the US can apply by phone, fax or mail; online application is available where the principal place of business is in the US. Federal (IRS). The IRS limits applicants to one EIN application per day. International applicant phone line: +1 267-941-1099.
Foreign entities document their status as beneficial owner for US tax withholding and reporting on Form W-8BEN-E. Federal. Typically requested by US banks and other withholding agents at onboarding and before paying US-source income.
Supported by the form title as linked from the NRA withholding page.
FinCEN's final beneficial ownership information (BOI) rule, effective 14 August 2026, permanently exempts US companies from BOI reporting and removes the need to report US persons as beneficial owners. Federal rule under the Corporate Transparency Act. Applies nationwide; makes permanent the exemptions first introduced by the interim final rule of 26 March 2025.
Final rule published in the Federal Register on 14 August 2026 (document 2026-16576); the Federal Register page was seen in search results but not yet checked.
Financial institutions must file a currency transaction report for each deposit, withdrawal, exchange of currency or other payment or transfer involving a transaction in currency of more than 10,000 US dollars. Federal, 31 CFR 1010.311. Applies to physical currency, not wire transfers. FinCEN geographic targeting orders can set lower thresholds for specified businesses and areas.
The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register.
Any person who physically transports, mails or ships currency or other monetary instruments totalling more than 10,000 US dollars at one time into or out of the United States must report it. Federal, 31 CFR 1010.340(a). A reporting duty, not an approval requirement.
The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register. The form number (FinCEN Form 105) was not confirmed on this page.
A US person, including a corporation, partnership or LLC, with a financial interest in or signature authority over foreign financial accounts whose combined value exceeds 10,000 US dollars at any time in the calendar year must file FinCEN Form 114 (FBAR) electronically, due 15 April of the following year with an automatic extension to 15 October. Federal. Applies to a US subsidiary that holds accounts abroad, for example with its foreign parent's bank.
FDIC deposit insurance covers 250,000 US dollars per depositor, per FDIC-insured bank, for each account ownership category, and covers only deposits at FDIC-insured banks. Federal. Corporation, partnership and unincorporated association accounts form their own ownership category. Non-deposit investment products are not covered.
A US person, including a financial institution, that holds blocked property under OFAC sanctions must report it to OFAC within 10 business days of the property becoming blocked, and file an annual report of blocked property held at 30 June by 30 September. Federal, 31 CFR 501.603. In practice a US bank that blocks a payment will freeze the funds and report them, so a payment touching a sanctioned party can be held indefinitely.
The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register.
The Office of Foreign Assets Control (OFAC), part of the US Treasury, administers and enforces US economic and trade sanctions, using asset blocking and trade restrictions against targeted countries, regimes and persons. Federal. Programmes include Russia-related, Iran, North Korea, Cuba, Venezuela-related, counter-narcotics and cyber-related sanctions.
Under OFAC's 50 percent rule, entities owned 50 percent or more in the aggregate, directly or indirectly, by one or more blocked persons are themselves treated as blocked, even if not named on the sanctions list. Federal; OFAC programmes. Indirect ownership through other entities counts. Control without majority ownership is not captured by the rule but can still create risk.
Only the question text and opening of FAQ 401 were visible on the index page; the full FAQ page could not yet be checked. The point on control is general knowledge, not from the page.
Dividends paid by a US company to a foreign shareholder are FDAP income subject to 30% US tax, or a lower treaty rate, usually collected by withholding. Federal. Relevant to profit repatriation from a US subsidiary.
Fixed, determinable, annual or periodical (FDAP) income from US sources paid to a foreign person, such as interest, dividends, rents and royalties, is taxed at 30% or a lower treaty rate, with no deductions or netting allowed. Federal. Usually collected by withholding at source. A reduced rate or exemption may apply under the Internal Revenue Code or a tax treaty.
Under a US tax treaty, residents of the treaty country receive a reduced tax rate or an exemption from US income tax on certain income they receive from US sources. Federal. Relief depends on the specific treaty and on meeting its conditions.
Withholding agents report tax withheld on US-source income paid to foreign persons on Form 1042, an annual withholding tax return. Federal.
Supported by the form title as linked from the NRA withholding page; filing deadlines were not confirmed.
Questions on this topic
10 statements on banking, payments and repatriation in the United States
