Luxembourg: corporate bank account opening

Obtain the company's registered particulars, constitution, managers or directors and business details. The Luxembourg registry guide explains RCS extracts and RESA filings. Use home-country records for an overseas customer and local branch records where applicable.

Ownership and control

Article 3 of the AML law requires identification of beneficial owners, reasonable verification measures and an understanding of the ownership and control structure. For companies, the law treats 25% plus one share, or an ownership interest above 25%, as an indication of ownership; examine control through other means as well.

Obtain the relevant shareholder and control records. Use the senior-managing-official fallback only after exhausting the other means on the law's conditions, with the enquiries and difficulties recorded. A professional director's name is not a substitute for tracing a known corporate owner.

Verify the person acting for the company and their authority. Obtain the account mandate and any delegation, checking the constitution and registered representation rules for joint signatures.

Activity and approval

Record the proposed account use, principal transactions and funding. For a holding company, request the acquisition, distribution or intercompany-financing documents relevant to the expected payments. Apply enhanced measures to higher-risk relationships, including the applicable PEP approval and funding enquiries.

Complete the required CDD before acceptance unless a permitted timing exception applies. Monitor transactions and update the ownership and mandate when they change. The AML law sets a five-year retention baseline with separate triggers for relationship and transaction records.