16/10/23

Refusal to Open and Account Blocking by Banks: How to Prevent it?

In recent years, it has become more and more challenging for foreign investors to open an account with banks in Belgium, as well as in other jurisdictions like Germany or The Netherlands. 

Banks prefer to refuse new client or quickly block an account to minimize their exposure to fines for failure to fulfill due diligence requirements imposed by anti-money laundering laws.

However, the following solutions could help avoid these unpleasant surprises. 

  1. Turning to less conventional/traditional financial institutions – provided they are recognized in Belgium – such as Alpha FX or Revolut. Faster and more accessible, they guarantee fast processing of requests.
  2. When establishing a Belgian company, a certificate from a bank established in another Member State such as Luxembourg is sufficient for issuing a bank account opening attestation to any Belgian notary.
  3. Another solution could be to leverage one’s professional network: many companies and non-profit organizations manage to open an account with a bank if one of the directors is a reknown and/or long-standing client of the bank. Therefore, companies from countries identified as “at risk” wishing to incorporate a company in Belgium and provide it with a Belgian bank account could appoint a reputable Belgian resident as an independent director. 
  4. Finally, as a last recourse, the newly introduced basic banking service can be sought. This service, available to individuals, businesses, and diplomatic missions, requires banks to provide a minimum service to those who have been rejected by at least three different financial institutions for account opening. In this context, banks cannot refuse to open an account for a non-profit organization unless there is a suspicion of money laundering.


Authors: Stéphane Bertouille and Stijn De Meulenaer

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