We are a State charter community bank and we don't bank foreign businesses. We consider them high risk and requiring frequent monitoring (by policy and risk assessment). We've had inquiries in the past. We've required them to provide articles, by laws, state licensing and provide at least one beneficial owner (human being) before considering opening the account. We need to understand the business and the expected activity. Since these prospects are unable/unwilling to provide all the information we don't bank any. One of our Bank executives is asking to reconsider this policy now. My question is: Do you know if Federal/National Banks are free to bank foreign businesses or is this a risk decision made by each bank? Or is this done at the State level? The prospect is an insurance company and I think it would be best to refer them to a bigger bank that has the resources to bank/monitor them.

Would they even know what the proper corporate document from (pick your favorite non-English speaking country) look like?

There is a sticky post at the top of this forum with a link to a 60 Minutes story about money laundering. One of the lawyers there recommends that the individual go to a smaller bank as the bigger banks are more "serious" about these issues.

"Training by television" would probably be a step up and appropriate for your executive. He or she should watch the video.

If a customer is coming to you because you have expertise, that's a good thing. If a customer is coming to you because you have no expertise, that's something else altogether.

We recently turned down a request from an insurance business that was registered in Turks and Caicos that sounds similar to your customer request. The individuals did not appear to have any previous experience in the insurance industry but was claiming that this account would see dollar volumes in the millions of dollars. We had zero comfort level with it and turned down the accounts. We have a few foreign businesses that are subsidiaries of well established local companies, but generally stay away from foreign accounts for the same reasons that you have listed.

You can open an account for any customer you want, foreign or domestic. However, as other have already pointed out, it's somewhat unusual to enter into this business line without the appropriate expertise and resources.

have to say, Ken, that your ability to break the issue down into a concise, yet memorable, phrasing is awesome.

And this is why we looooooove Ken!