United States: corporate bank account opening
US bank customer identification, the 25% ownership and control tests, and FinCEN's February 2026 relief for repeat accounts.
United States · Banks · FinCEN / federal and state bank supervisors
Corporate customers, including overseas companies · Account opening: AML/CDD review
By Matthew Lee
The bank's Customer Identification Program collects the company's name, physical address and identification number and verifies identity using its documented procedures. Obtain formation documents or an official registration record from the state of formation; a federal EIN identifies the taxpayer but does not replace corporate-identity verification.
Owners and one control person
For a non-exempt legal-entity customer, the CDD rule generally requires identification and identity verification of each individual owning 25% or more of equity, directly or indirectly, and one individual with significant responsibility for managing the entity. The control person is required even if no owner reaches 25%.
Obtain the beneficial-ownership certification or equivalent information and the required identity particulars. A state company search may omit owners, so request shareholder records and an ownership chart where needed to identify the relevant individuals. Record any customer or account exclusion used.
Additional accounts after the first
FinCEN's February 2026 order removes automatic beneficial-owner identification and verification at every additional account for an existing customer. The initial-account requirement remains, as do refresh checks when facts call earlier information into question or the bank's risk-based ongoing CDD requires them.
Obtain the company mandate for account operators, expected payment activity and funding information. Resolve sanctions issues and apply enhanced review where the risk warrants it. Keep the CIP and CDD evidence, mandate and approval with the account file; update ownership information through ongoing monitoring when relevant changes become known.