Bank account for a licensed company

A licence lets a company provide regulated services; it does not give the company a bank account. For payment institutions, e-money institutions, crypto-asset service providers, credit servicers and money services businesses, the accounts are often the hardest part of the launch — harder than the authorisation itself. This guide explains why licensed companies need specific kinds of accounts, why banks treat them cautiously, what the law does and does not guarantee, and how to prepare an onboarding file that a bank can say yes to. Our banking introduction services are on the compliance services page.

One rule runs through the whole guide: bank and payment accounts are granted solely at the discretion of the financial institution. Nobody — including us — can promise an account. The guide is general information, not legal advice.

Which accounts a licensed company needs

Most licensed companies need two different things.

• An operating account for the company's own money: share capital, salaries, rent, taxes and supervision fees.
• A client-money or safeguarding account for the money of customers, kept separate from the company's own funds. Whether and how this is required depends on the licence.

The second type is where the law is strict:

• A payment institution providing most payment services must safeguard users' funds. One method is to keep them from being commingled with other funds and, if they are still held at the end of the business day after receipt, to deposit them in a separate account at a credit institution or invest them in secure, liquid, low-risk assets (Directive (EU) 2015/2366, Article 10).
• An e-money institution must safeguard the funds received in exchange for e-money, at the latest five business days after the e-money is issued (Directive 2009/110/EC, Article 7).
• A crypto-asset service provider that holds clients' funds other than e-money tokens must have adequate arrangements to safeguard the clients' ownership rights and prevent the use of clients' funds for its own account (Regulation (EU) 2023/1114, Article 70(2)).
• An Estonian credit servicer that receives borrowers' payments must keep them on a separate payment account and may not use them in its own business (Credit Servicers and Credit Purchasers Act § 47). If it wants to hold borrowers' funds, the payment account details are part of its licence application.

For some licences, therefore, the account is not only a practical need but a condition of the authorisation file.

What the law guarantees — and what it does not

The Payment Services Directive requires Member States to ensure that payment institutions have access to credit institutions' payment account services on an objective, non-discriminatory and proportionate basis, and a credit institution must give the competent authority duly motivated reasons for any rejection (Directive (EU) 2015/2366, Article 36). That is a real protection, but it is not a right to an account at a particular bank, it applies to payment institutions, and it does not remove the bank's own anti-money-laundering obligations. Crypto-asset businesses, money services businesses and credit servicers have no comparable rule.

In practice every bank decides on the basis of its own risk appetite and its own due diligence.

Why banks are cautious

A bank that opens an account for a licensed company takes on part of that company's risk: its customers, its countries, its products and the quality of its controls. The bank must understand where the money comes from and where it goes, and it answers to its own supervisor if it gets that wrong. Common reasons for a refusal or a long delay are:

• an ownership chain that is hard to follow, or beneficial owners who cannot explain their source of wealth;
• a business model that is not clear from the documents, or target markets the bank does not serve;
• high-risk products, such as crypto-asset exchange or cross-border remittance, without evidence of matching controls;
• no local substance — no staff, office or management in the country of the licence;
• a compliance function that exists on paper only.

What goes into a good onboarding file

• The licence or the application status, with the scope of services.
• Corporate documents: articles, registry extract, the full ownership chain up to the individuals, board and key staff.
• Source of funds and source of wealth of the owners, with evidence.
• The business plan in short: products, customers, countries, expected volumes and transaction patterns for the first year.
• Compliance: the anti-money-laundering policy, the risk assessment, the customer due diligence procedure, the transaction monitoring set-up and the name and background of the compliance officer.
• Flows of money: a simple diagram of which account receives what, and where client money is safeguarded.

The same documents also serve the authorisation, which is why we build them once and reuse them. Consistency matters: a bank that reads a different story from the one in the licence application will stop.

Plan it early

• Start the banking conversation during the authorisation, not after it. For licences that need a safeguarding or payment account in the application — for example a credit servicer that will hold borrowers' funds — you have no choice.
• Approach several institutions in parallel. Banks, e-money institutions and specialised providers have very different appetites.
• Keep the capital account separate. The share capital of a licensed company must usually be paid in before the licence is granted, so an operating account is needed early.
• Expect repeat reviews. A change of ownership, new products or new countries will trigger a new review — including after buying a ready-made company or a registered MSB.

If an institution says no

A refusal is common and rarely final. Ask whether the institution can say which part of the profile did not fit — country, product, ownership or volume — and fix the file before approaching the next one. Do not send the same file unchanged to many institutions at once, and never give different institutions different stories: banks talk to each other through their correspondents and compliance networks.

How we help

On the compliance services page we offer extended banking onboarding with introductions to six banking and payment partners, a premium banking onboarding, an introduction to an e-money institution that works with crypto-asset businesses, multi-currency IBAN account set-up and card issuing or BIN sponsor introductions. In each case we prepare the onboarding file and present your company to institutions that are likely to consider it. An introduction is not an account: the institution decides, and no partner is obliged to accept you. Our fee is our professional fee for that work.

Types of institutions

• Banks (credit institutions) offer the widest services, including safeguarding accounts and access to payment systems, and usually the strictest onboarding.
• E-money institutions and payment institutions can offer operating accounts and IBANs, often in several currencies, and some specialise in regulated or crypto-asset clients. They cannot take deposits in the banking sense.
• Card issuing and BIN sponsors are needed only if the company issues payment cards; they come with their own programme requirements from the card scheme.

A realistic plan often combines them: an operating account at one institution, a safeguarding or client account at another, and a specialised partner for cards or currencies.

Keeping the account

Opening the account is not the end of the review. Institutions monitor the account against the business described at onboarding, and ask for updates when volumes, products or countries change. Keeping the onboarding file current — and telling the institution about material changes before they happen — is the simplest way to avoid an account being restricted or closed.

Frequently asked questions

Related guides

• MiCA CASP licence in Estonia
• Estonian credit servicer licence
• Canada MSB and FINTRAC registration
• State fees and capital for EU licences