Questions and answers › Source of funds

How does a crypto company (exchange, fund, start-up) open a bank account?

Show a clear business model, regulatory status, a working AML programme and the origin of all capital.

In short

A crypto company opens a bank account by showing the bank a business it can understand and monitor: a clear business model, its regulatory status (the registration or licence required for virtual asset service providers where it operates, for example a MiCA authorisation in the EU), a working AML and KYC programme, its beneficial owners, and the origin of founders' and investors' capital, including any capital raised in crypto. Many banks limit their exposure to crypto businesses, so preparation and a realistic choice of bank matter as much as the documents.

What the bank looks at

The bank wants to know what the company does, who its customers are, which jurisdictions it serves and what flows will pass through the account. A key question is whether the activity is regulated: FATF Recommendation 15 asks countries to license or register virtual asset service providers and to supervise them for anti-money laundering, and many countries now do so. The bank checks the status in every country where the company serves customers, and it will not open an account for an activity that should be licensed or registered and is not.

Documents to prepare

  • Company register extract, articles of association and group structure chart.
  • Identification of directors, controlling persons and beneficial owners.
  • Business plan with expected volumes, customer types and countries.
  • Regulatory status: the licence or registration held in each country of activity, or a legal opinion explaining why none is required.
  • AML policies, KYC procedures, transaction monitoring tools and the Travel Rule solution in use.
  • Origin of share capital and treasury, including the on-chain trail of any funds raised in crypto.

Capital raised in crypto

If the company raised money through a token sale or received investments in crypto, the bank will treat that treasury like any other crypto-derived funds: it needs the list of contributing wallets, the investors' identification where required, and an on-chain analysis showing that the funds are not linked to sanctioned or criminal sources. Doing this analysis before approaching the bank avoids delays.

After the account is open

Banks keep monitoring crypto clients. Expect periodic reviews, questions on large or unusual flows and requests to update the AML documentation. Keeping client money separate from company funds, recording the Travel Rule data that must accompany transfers between crypto service providers (FATF Recommendation 16) and responding quickly to the bank's requests are what keep the account open.

How Advisorn helps

Advisorn assists crypto businesses with regulatory status, AML documentation and on-chain source of funds analysis of their treasury, and answers the bank's follow-up questions during onboarding.

Legal references

FATF Recommendations 15 and 16; FATF Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (2021); Regulation (EU) 2023/1114 (MiCA), as an EU example

Updated November 2026 · General information, not legal or tax advice on your specific case.

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