Open a UK bank account

One of the misconceptions people have about forming a new UK company is that it is a legal requirement to have a UK based bank account to trade in the UK. The UK allows you to use your bank account from abroad; however, businesses find it quickly becomes necessary in order to keep separate accounts. Most overseas companies trading or beginning to trade in the UK prefer a UK bank account to conduct business. For practical reasons it also makes sense to have a local bank account; imagine the difficulties of trying to make overseas transactions all the time.

Although you need a limited number of documents to form a limited company, opening a UK bank account for overseas owned companies can be very onerous process. Banks tend to be far more conservative and they commonly reject applications from overseas owned companies.

We receive a lot of questions regarding the residency of the directors and signatories. No, it’s not necessary to live in the UK in order to open a bank account. However, it’s wise to acquire UK residency before applying for a UK bank account. Most banks will not entertain an application unless you have UK residency. This is due to concerns over fraud and the additional administration costs incurred by them.

The UK has a huge retail and commercial banking sector, which is dominated by the ‘Big Four’: HSBC, Barclays, Lloyds Banking Group and Royal Bank of Scotland (RBS) Group. Each bank will have slightly different products available, so read the small print carefully – especially terms and conditions, and the section on banking fees and charges. It is common to find monthly account handling charges and fixed fees for banking transactions.

It may be possible to look beyond the high street banks. However, it is important to be aware of the difference between business bank accounts and the business banking services offered by some e-money firms. If you’re uncertain about what the firm is offering, the regulatory status (usually found at the very bottom of their website) will give a clue as to whether it is a PRA-regulated deposit taker or an FCA-regulated e-money firm.

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UK banks must undertake customer due diligence, prior to setting up a bank account for their new customers. This is part of the anti-money laundering (AML) regime and is a key requirement of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692).

Key shareholders (usually 10-25% or more) together with those individuals who will be named on the UK bank mandate will be asked to prove their identity and home address, with documents such as:

  • Proof of ID: passport, UK photo driving license or national ID card
  • Two forms of Proof of address: recent bank statement or utility bill, or council tax statement

If you’re applying from abroad, you will be asked to provide notarised translations of your ID and documents used to prove your address. If any of these documents are not in English, they will need to be translated.

While UK banks are experiencing unprecedented demand for opening business accounts, businesses are facing delays and refusals. This is alongside banks assessing their offerings for those not resident in the UK after Brexit. If you already bank with a large global institution in your home country, you may find that they can help you set up an account with their UK business.

There is no precise “how to open a UK business bank account for overseas owned companies” rulebook. Unfortunately, it is often easier for UK banks to decline to open an account, than it is to complete the hurdles and internal challenges they face from a compliance perspective.

The following provides a high-level overview as to the sort of data and detail that is required to open a bank account in the UK for overseas owned companies. It is by no means complete – there are multiple sign-offs internally, and if your application passes one hurdle, doesn’t mean the next level won’t have further questions relating to ownership, identification documents etc. A face-to-face interview is almost always required.

Key information about the parent company

  • Name of legal entity, registered address, shareholder data and percentages.
  • Addresses of main shareholders (usually 10-25% or more) and directors.
  • Description of parent company trading activities.
  • Jurisdiction for tax purposes of parent company.
  • Where the individuals are registered for tax, the banks require tax registration details for anyone registered for tax and social security outside of the UK.

Key information about the UK company

  • Name of legal entity, registered address.
  • Director addresses.
  • Description of UK business trading activities; the banks are looking to fully understand why a UK account is required.
  • Projected turnover of the UK company.
  • Details of expenditure, outgoings, potential suppliers and potential customer names.
  • Details of directors and whether they are registered for tax in any other country other than the UK.

UK bank mandate details

  • Details of signatories who will have access to the UK bank account.
  • What currency accounts, if any, are required.
  • Internet banking: simple or enhanced; access only, key payments, authorise payments etc.

Anti-money laundering data

  • Notarised Proof of Identity and two forms of home address documents such as a recent bank statement and utility bill, showing home address of the individuals. This data will be required for the majority shareholder(s) and those who are to have access to the UK bank account.
  • Covering letter from the Notary addressed to the UK bank confirming they have met with individuals, and notarised copies of passports/bank statements/utility bills.
  • Where the documents are not in English, they will need to be translated.

Resident for Tax Purposes

  • Under FATCA regulations, UK banks are required to know where the company is resident for tax purposes – if it’s part of a group, other such jurisdictions may need to be noted also.

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